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

The battle for Marden makes its mark far and wide

The young have voices, too: protestors at Marden
Yellow and black has become the colour scheme of choice in the village
The message is clear…

Proposals for a 2,000-home garden community at Marden have sparked a huge wave of opposition.
After almost 2,000 people marched through the village (still!) in protest during the spring, a petition carrying almost 3,000 names was handed to 10 Downing Street on Friday (July 12).
The March for Marden, on Saturday, May 18, organised by Marden Planning Opposition, had seen protestors take to the streets wearing yellow and black – the colours that have bedecked much of the village on window posters and hedge banners over recent weeks.
Meanwhile, the group has set up a website (see here); drawn national media coverage; and seen its Facebook group attract more than 1,000 members.
Chairman Claudine Russell said: “The scale of this proposal is truly shocking and has united the people of Marden in fighting this development.
“We simply don’t have the infrastructure or services to support 2,000 more houses and two new schools, and it would mean Marden would cease to be a village and instead become a town.
“We are determined to show the council the strength of opposition as early as possible in the process. The scale of this development, which effectively doubles the size of Marden, is unthinkable in terms of traffic congestion on country roads, loss of wildlife habitat and negative impact on both the village’s heritage and the well-being of the people who live here.”
The proposals have been submitted to Maidstone Borough Council by three landowners, developer Countryside Properties and consultancy DHA Planning in response to the local authority’s Call for Sites ahead of its Local Plan review in 2022.
Countryside Properties has argued that Marden would benefit from the scheme through new facilities and better links to Maidstone town centre; it also says it is speaking with people who live and work in the village.
The campaign against the plan is supported by Helen Grant, MP for Maidstone and The Weald, who said: “We need to make sure the homes we need are built in the right places with the required infrastructure, and this proposed development is simply not in keeping with the beautiful rural community of Marden.”

You can learn more about the campaign at:

  • Web: www.savemarden.com
  • Twitter: @save_marden
  • Facebook: Marden Planning Opposition Group
  • Email: mardenplanningoppositionpr@gmail.com

Monday, July 15, 2019

Government chooses not to take over Thanet Local Plan: was this the ‘easy way out’?

Thanet… what next?

Heard the one about Thanet District Council’s Local Plan?
Of course you have.
Well, there’s more…
This comitragic tale has been well covered (see herehere, herehere and here), so it will suffice for now to say that it is back in the news.
Eventually approved in July last year, the draft Plan is now in the phase leading up to the Examination in Public, scheduled to begin in April.
Despite this, the council has been slated by James Brokenshire, Secretary of State for Communities and Local Government, over its lack of progress and failure to deliver new housing. Mr Brokenshire has, however, stopped short of direct intervention, saying only that the situation would be “closely monitored”.
Mr Brokenshire’s predecessor, Sajid Javid, had threatened to take over production of the isle’s Local Plan, along with those of Castle Point in Essex and Wirral in north-west England.
Writing to Bob Bayford, leader of the council, he said: “Thanet have consistently failed to bring forward a Local Plan in accordance with its Local Development Scheme as legally required.
“Based on Thanet’s revised Local Development Scheme, it is unlikely that Local Plan production would be accelerated by my department taking over.
“In my judgement, given the authority’s track record of persistent failure in plan-making, the intervention I have decided upon will provide more certainty and is the best way of ensuring that a Local Plan will be produced.
“I am also, for the avoidance of doubt, now putting on public record my concerns about the low level of housing supply and delivery in Thanet.
“I expect planning decision-takers to have regard to these concerns as a material consideration when deciding local planning applications.”
Critically, at least as far as the local authority is concerned, Mr Brokenshire concludes: “I have decided not to prepare the Thanet Local Plan. However, I will continue to closely monitor your Local Plan progress.
“I appreciate the constructive way Thanet District Council have engaged in this process so far and I trust that you and your officers will continue to engage positively.”
Commenting on a situation in which no one seems very happy, David Morrish, chairman of Thanet CPRE, said: “The government’s Housing Delivery Test 2018 shows that from the years 2016-18 Thanet had a new-homes delivery rate of just 44% of target.
“The only thing the table demonstrates is that the calculation of housing for Thanet is completely ridiculous and that a housing projection of around 8,000 – back where we started in 2014 – is what the Thanet requirement should be. Such a target could be accomplished without using valuable Grade 1A agricultural land.
“When will Mr Brokenshire realise that a flawed model is being applied that is of no help to anyone whatsoever?
“The government targets are derived using an algorithm to develop targets for each council based on government policies but take no account of the deprivation and lack of jobs and employment prospects in an area.
“The houses that have been built in Thanet are in large part attributable to development at Westwood Cross. It is rumoured persistently that this is being earmarked for social-housing tenants moving in from London, yet Thanet people find it next to impossible to find social housing themselves.
“If nothing else, Thanet council needs to clarify the situation to help calm local disquiet.
“Also, Thanet has the highest proportion of empty homes in Kent but makes no attempt to bring some of them into use to house its homeless.
“I think it is probable that Mr Brokenshire’s Chief Planner realised, after taking a close look at the shambles of Thanet’s poorly-thought-out planning regime that has placed all the power in developers’ hands, that it is not something  anyone with any sense would want to take direct responsibility for sorting out.
“Instead, he has taken the easy way out by letting the two Local Plan inspectors carry on with their invidious task of inspecting in detail the existing mess of the draft Local Plan, neatly wrapped up in 4,000 pages of planning speak on the Thanet council website.
“This inspection begins in Ramsgate in April, with public hearings in May, while  another, separate, quartet of inspectors based in Margate are already grappling with 5,000-plus pages of evidence relating to Manston airport, with public hearings in March and a conclusion in July.
“Never, as far as we are aware, will the two sets of inspectors meet formally, and by the middle of this year two different ministers – Mr Brokenshire and Chris Ayling, Secretary of State for Transport, will be given the two different reports upon which to make their own individual decisions.
“It would test the patience of a saint and the genius of an Einstein to unravel this muddle.
“What is certain about this farrago is that the only winners will be the developers, who will continue to receive licences to build wherever they want in Thanet at the current leisurely speed, further increasing pressure on strained public services and with the community having as much certainty of the public costs being paid for by developers – as happens elsewhere in Kent – as a philosophy student at McDonald’s has of paying off their student loan.”

Monday, February 25, 2019

Sevenoaks: the sites that could be taking a housing hit

Are the diggers heading your way?

Planners at Sevenoaks District Council have revealed the Green Belt sites they have identified for major housing development – greenfield sites with no development at present.
They are satisfied there are “exceptional circumstances” to justify changing the Green Belt boundary for these cases, their verdict coming after this summer’s consultation on the district’s draft Local Plan.
If the proposals are approved by cabinet on Thursday (December 6) they will be included in the final consultation on the Plan (the Regulation 19 stage) before it goes to public inquiry in the spring.
The government’s Objectively Assessed Need formula has arrived at a figure of 13,960 properties to be built in Sevenoaks district from 2015-2035. Sites on previously developed land (PDL) are expected to take some 6,000 properties.
At the Draft Plan consultation stage (Regulation 18), 12 ‘exceptional circumstances’ Green Belt sites were proposed for potential development. Of those, the following are being taken forward to consultation:

  • Four Elms Road, Edenbridge (350 units)
  • Sevenoaks Quarry (600 units)
  • East of London Road, Dunton Green (240 units)

In addition, Pedham Place, land in the AONB near Swanley, is identified as a “broad location for development” for 2,500 houses.
At the Planning Advisory Committee meeting on Thursday, November 22, councillors voiced strong objection to the site, but a motion to exclude it was lost by a 5-6 margin.
Further consideration will be given to the release of this site from the Green Belt when the Plan is reviewed in the mid-2020s.
The local authority received 8,500 comments on the draft Plan from some 6,000 representors, including CPRE’s Sevenoaks committee, the majority objecting to the allocation of these ‘exceptional circumstances’ greenfield sites in the Green Belt.
Nigel Britten, the chairman, said: “Justification for making changes to the Green Belt boundary now is justification for making more changes in the future.
“But the Green Belt and the two Areas of Outstanding Natural Beauty are what define the special quality of the Sevenoaks countryside and we will do our utmost to protect it.”
The council received additional site submissions for greenfield Green Belt sites during the draft Plan consultation. The following are considered potentially suitable for inclusion in the Local Plan and will be consulted on alongside the Regulation 19 consultation:

  • South of Redhill Road, New Ash Green
  • Between Hartfield Road and Hever Road, Edenbridge
  • West of Childsbridge Lane and south of the recreation ground, Kemsing
  • North and south of Kemsing station

The Regulation 19 version of the Plan will include the associated Supplementary Planning Documents – Affordable Housing SPD, Development in the Green Belt SPD and Design Review Panel SPD.
The council will ultimately publish the Regulation 19 version on the basis that it considers it to be sound, legally compliant and prepared in accordance with the ‘duty to cooperate’ with neighbouring planning authorities.
Prior to the submission of the Plan for examination, the council will prepare an Issues Paper to demonstrate that an appropriate approach has been taken with regard to density.
It must also show the supply of housing sites is deliverable (for the first five years of the Plan) and developable (years 6-10). Further, it must provide evidence that all non-Green Belt sites have been fully explored before going through a peer review process with the Planning Inspectorate.
It is anticipated public consultation on the pre-submission version of the Plan will take place from Tuesday, December 18, to Sunday, February 3, followed by submission and examination in the spring or summer of next year, with adoption by the end of 2019.

  • For more on this story, see here
  • To read the papers for the cabinet, see here
  • To track the changes being made to the Local Plan, visit Appendix 5 of the Cabinet papers here

Monday, December 3, 2018

Ashford council told to drop 500 new properties from Local Plan

The Hothfield area is the greatest beneficiary from the inspectors’ report, with some 400 homes slashed from the building target (pic www.hothfield.org.uk)

Inspectors have ordered Ashford Borough Council to chop some 500 new properties from its Local Plan.
Sites at High Halden and Hothfield are to be deleted altogether, while five plots in other villages must be reduced in size.
The new Plan, which identifies where 13,521 homes will be built up to 2030, was approved by the council in December last year, but it must now be amended.
The Hothfield area is the greatest beneficiary from the inspectors’ conclusions, with a total of 400 proposed homes axed at Tutt Hill, near Holiday Inn, near Hothfield Mill and near Coach Drive. It is believed isolation from the village and damage to trees were the primary reasons for their exclusion.
Fifty properties at Stevenson Brothers petrol station between High Halden and Bethersden also failed to convince the inspectors.
Sites at Brook, Mersham, Aldington and Wittersham all have reduced numbers of houses to be built.
Thankfully, the inspectors have said the borough does not to add sites to compensate for those that have been dropped.

Monday, October 15, 2018

Don’t forget, now is the time to comment on the Thanet Local Plan

What future for the Isle of Thanet?

We have covered the tortuous tale of Thanet District Council’s draft Local Plan with some intensity over recent months, so we’ll keep this reminder brief…
You have some five weeks to view and comment on the draft Plan, which was approved by the council in July and is intended to provide the isle’s planning blueprint until 2031.
This ‘pre-submission stage’ began on Thursday, August 23, and ends at 5pm on Thursday, October 4, with comments received going straight to the planning inspector; respondents might be then invited to speak at the Plan’s Examination in Public.
To view the Local Plan and make comments, visit here

It is also available at The Gateway in Margate, Pierremont Hall in Broadstairs, Custom House in Ramsgate and in any public library in the district.

For (a lot of) background on the Thanet Local Plan, visit herehere, herehere and here

Friday, August 31, 2018

Learn about the draft Sevenoaks Local Plan: you still have time to comment

More demand on the River Darent seems certain (pic Glen Humble, flickr)

Consultation on the Sevenoaks draft Local Plan (2015-35) ends on Monday, September 10.
CPRE Kent has taken calls in recent weeks from residents across the district concerned what a proposed housing target of 13,960 new homes might mean for them and for the status of the Green Belt.
In response, we have produced a briefing that covers the core issues relating to new-housing allocation within the draft Local Plan. We also make our own observations on the document.
You can see the briefing and our observations here
Sevenoaks District Council has organised a series of drop-in sessions, where you can learn more about the Local Plan. You can still make two of these:

  • Swanley Link (BR8 7AE): Wednesday, August 29, 2pm-8pm
  • Sevenoaks District Council (TN13 1HG): Wednesday, September 5, 2pm-8pm

We can not stress strongly enough that if you have concerns about what is proposed by the council in its Local Plan, or you simply want to be involved in the future of Sevenoaks district, you need to respond to the consultation by Monday, September 10.
You can do that here

Wednesday, August 22, 2018

Sevenoaks draft Local Plan: a briefing and CPRE Kent observations

What future for the Green Belt in Sevenoaks district? (pic Susan Pittman)

Sevenoaks District Council’s Local Plan strategy

The draft Local Plan (2015-35) sets out the council’s strategy of:

  • providing 13,960 homes to meet its local housing need
  • focusing growth at existing settlements and maximising supply (through increased density)
  • redevelopment of previously developed land (and of locally-defined brownfield land in sustainable locations)
  • development of greenfield Green Belt land only in exceptional circumstances, where social and community infrastructure is being proposed in addition to housing, which could help address evidenced infrastructure deficiencies in the local area

 

Locally-defined brownfield land
Sevenoaks District Council is seeking to introduce the concept of locally- defined brownfield land as a means of gleaning as many housing sites as possible to contribute towards the requirement of 13,960 homes.
This definition goes beyond the (Nationally Planning Policy Framework) NPPF definition of previously developed land (PDL) – and could have serious repercussions for other Kent Green Belt authorities.

Locally-defined exceptional circumstances
The council is also seeking to include a local definition of exceptional circumstances.
The draft NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified.
The council is exploring in its draft Local Plan whether its Green Belt boundaries should be altered to meet its housing need. Twelve exceptional-circumstances sites have been put forward for consideration.
The council acknowledges that Sevenoaks is a highly constrained district, with 93% being Green Belt and 60% (Area of Outstanding Natural Beauty) AONB.
It is explained at para 1.14 of the draft Plan that consultation is taking place on all these sites to receive stakeholder comments… and that the inclusion of these sites in this consultation does not guarantee their inclusion in the final draft Local Plan.
The table below lists the 12 exceptional-circumstances sites.

Location                               Policy            No. of units            Site area (hectares)

Sevenoaks
Sevenoaks Quarry                 MX43             600                            94

Land west of Chevening        MX49             26-30                        1.7
Road, Chipstead                    HO53

Land east of London             MX50             40                              8.5
Road, Dunton Green             HO70

Swanley
Land between Beechlea       MX54a/b         750                            39.5
Lane and Highlands Hill,      HO188
Swanley

Pedham Place, Swanley/      MX48             c2,500                       117.6
Farningham/Eynsford

Edenbridge
Land south and east of        HO189 &        515                             27.2
Four Elms Road or              HO190
———————————— MX25 &
———————————–  MX26
———————————— HO223

Land at Crouch House        MX51              250                             18.4
Road or                              HO158

Land at Breezehurst            MX10             450                             18
Farm

and
Land west of Romani          MX44             80                               6.7
Way

Westerham
Land north and east of        HO371 &       600                             21.8
Westerham                          HO372
————————————-HO373 &
———————————— HO374
———————————— EM17

Fawkham/Hartley
Corinthian and                     MX52 &         Corinthian 570        74.6
Banckside                            MX53             Banckside  230
———————————— HO162 &
———————————— HO163

Halstead/Pratt’s
Bottom

Broke Hill golf course        MX41             800                             60.2

Subtotal       6,800

CPRE Kent observations on the Sevenoaks Local Plan

In general, CPRE Kent supports a development strategy that meets the following criteria:

  1. Prioritises the redevelopment of appropriate, sustainably-located previously-developed land. It does not support development on locally-defined brownfield land in unsustainable locations.
  2. Does not lead to the loss of best and most versatile agricultural land, Green Belt, AONB and other designations.
  3. Focuses growth at existing settlements and maximises supply through increased densities at sustainable locations.
  4. Recognises the acute need for rural affordable housing.

 

CPRE Kent is concerned about the level of housing proposed. It is noted that the 2015 SHMA sets out objectively assessed need based on the Office for National Statistics (ONS) 2012-based sub-national population projections and 2012-based household projection figures.
These figures will need to be reviewed in light of the 2016 mid-year figures and the household projections (expected next month).
Following the decline in population (2012-2016), it would seem reasonable to assume that household projections will also be in decline. However, we wait with interest to see what the government’s stance on this will be.

CPRE Kent has serious reservations that the construction industry will be capable of delivering the proposed level of housing. Average housing completions for the district are noted as 250dpa (dwellings per annum) over the last 10 years. With the suggested local housing need of 13,960, this would rise to 698dpa.

CPRE Kent has serious reservations over the need to deliver homes in accordance with the standard methodology for calculating local housing need, for the following reasons:

  1. The NPPF states that the government attaches great importance to the Green Belt – it states that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of Plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the Plan period”.
  2. One of the Green Belt purposes is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Resisting development in the Green Belt will help encourage the bringing forward of previously developed land in the urban area.
  3. New housing in the Green Belt is likely to be for large properties that won’t meet the demand of local people who genuinely require housing in the villages and settlements within, or washed over, the Green Belt.

CPRE Kent does not consider that allocating land to meet local housing need with the promise of social and community infrastructure sufficiently demonstrates exceptional circumstances.
CPRE Kent is concerned that the harm caused to the purposes of the Green Belt designation and other considerations would not be outweighed by the requirements of the local housing need requirement.

Wednesday, August 22, 2018 

Thanet’s draft Local Plan to go to public consultation

Yes, the question of Manston still dominates…

Thanet is a step closer to having a Local Plan.
After months of political posturing and squabbling, including the rejection of an earlier version, district councillors voted on Thursday evening (July 19) to recommend the draft Plan go to public consultation.
The full council’s backing, by 31 votes to 21, of ‘Option 2’ for the Plan represents a decision, certainly, but a large degree of uncertainty still clouds the way forward.

After the public consultation, the Plan will go back to the council, which will decide on any amendments before submitting it to an inspector for the Examination in Public.
A main sticking point had been the status of the Manston airport site, but last night’s decision, which went against the recommendation of officers, sees it retained for aviation use, at least in the short term.
That means the 2,500 homes that had been earmarked for Manston in the earlier – and subsequently rejected – draft Plan will now be redistributed elsewhere across the isle:
Westgate-on-Sea (1,000 homes)
Birchington (600)
Westwood (500)
Hartsdown (300)
Tothill Street, Minster (100)
The total housing target is 17,140 new homes up to 2031.
The decision to recommend the Plan comes against the backdrop of potential airport operator RiverOak Strategic Partners (RSP) having submitted a revised application for a Development Consent Order (DCO), which could force site owner Stone Hill Park Ltd to surrender it if it is classified a Nationally Significant Infrastructure Project (NSIP).
As for Stone Hill Park, the company has lodged a planning application for a mixed-use project at Manston that includes 3,700 new homes.
Further, the council’s Local Plan process is ‘in intervention’, with the Ministry for Housing, Communities and Local Government having stepped in to ensure the local authority finally delivers its Local Plan. It is unclear to what extent the ministry drove the latest proposals, or indeed to what degree it will be involved from here.
There were two amendments to the draft, resulting from the earlier meeting of the executive, policy and community safety scrutiny panel:

  • The 2,500 homes reallocated from Manton would be phased towards the second half of the Plan period, which ends in 2031.
  • The status of the Manston site would be reviewed after a minimum of two years if a DCO or compulsory purchase of the land had not been agreed by that date.

What are we to make of it all?
Geoff Orton, secretary of Thanet CPRE, said: “It’s common sense that you can’t develop a coherent Local Plan for Thanet without the future of Manston having been decided, so we can only wait on that one.
“The county council document Growth without Gridlock puts emphasis on Manston as the economic driver for east Kent, so it is difficult to see how the employment needs of Thanet and beyond will be met without the airport, especially considering the potential arrival of thousands of new households.
“Even if we do get an airport and it produces 10,000 jobs, they are unlikely to offset the job losses predicted to be caused by technological change – a possible 15,000 in Thanet.
“As for the housing, what developer is going to invest in houses that won’t get sold? And who are those houses targeted for anyway?”
The public consultation is due to run from Thursday, August 23, to Thursday, October 4. Any comments must be submitted during that period as earlier submissions will not be considered.
These, together with the (possibly amended) draft Plan will then go to the inspector for the Examination in Public, with public hearings expected to start in February next year.

Friday, July 7, 2018

For more, visit here, herehere and here

The debacle that is passing for planning in Thanet… the next step

Thanet… a great place to live but for how much longer?

The troubled, if not farcical, saga of the Thanet draft Local Plan is expected to make progress of a kind tonight (Wednesday, July 11, 2017) when it goes before the district council’s executive, policy and community safety scrutiny panel.
This latest stage follows last week’s adoption by the council cabinet of an option that could see the Manston airport site retained for aviation and more than 17,000 homes built on the isle by 2031.
The news came as no great surprise as the other option had been rejected by the council in January, a move that saw the UKIP administration subsequently lose control of the local authority.
That first option had allocated Manston for mixed-use development and 2,500 homes, sparking further conflict between those who wanted to see the return of an airport and those who believed commercial aviation was a not a viable concern there.
Last week’s cabinet decision, made on Monday, July 2, went against the recommendation of officers and means that the 2,500 homes that had been earmarked for the airport site in the original Plan will now be redistributed elsewhere across the isle.
As things stand, the extra homes are likely to be targeted for:
Westgate-on-Sea (1,000)
Birchington (600)
Westwood (500)
Hartsdown (300)
Tothill Street, Minster (100)

The cabinet decision will be welcomed by potential airport operator RiverOak Strategic Partners (RSP) as it proceeds with its application for a Development Consent Order, which could force the owner of the site, Stone Hill Park Ltd,  to surrender it if it is classified a Nationally Significant Infrastructure Project (NSIP).
To confuse matters just a little further, Stone Hill Park has lodged a planning application for a mixed-use project at Manston that now includes 3,700 new homes.
So what happens if the DCO application fails… will the housing allocation return to Manston?
Or – and here’s where it could all get even uglier – will Manston be built upon, in addition to the alternative sites that have been put forward?
And will the final housing target end at 17,000, or will new (and widely derided) government methodology push the figure north of a frankly ridiculous 20,000?
Then, of course, there’s the little matter of central government having threatened the council with losing control over its own Local Plan if it doesn’t get it published… and soon.
Shambles? The word doesn’t come close…

For more on this story, if you can bear it, click herehere and here
Wednesday, July 11, 2018

The Medway plan… some good, some bad?

The Medway… what does the future hold?

CPRE Kent has applauded Medway Council’s intention to protect the north of the Hoo peninsula – that wonderful swathe of Cliffe and Cooling Marshes, one of the last remaining areas of tranquillity in the county.
Taking part in the consultation on the Medway Development Strategy, we were keen to applaud this and similar countryside protection policies but did object to some potential scenarios presented in the strategy.
We recognised the constraints facing the council in the development of its new Local Plan, particularly in relation to housing development, but maintain that the government’s proposed methodology for calculating local housing need is flawed.
The methodology is based on market demand rather than need, providing no understanding of how Local Plans can reflect a move from these abstract targets to a realistic, deliverable and sustainable housing requirement.
In Kent, particularly, the methodology is leading to disproportionately high targets that will be impossible to deliver sustainably.
We welcomed the council’s renewed commitment to delivering regeneration of brownfield sites but retain significant concern at the inclusion of Lodge Hill as a strategic option for housing.
We acknowledged the presence of a residual brownfield footprint at this site but stressed that the National Planning Policy Framework is clear previously developed land should be re-used “provided it is not of high environmental value”.
Chattenden Woods and Lodge Hill’s designation as a Site of Special Scientific Interest precludes it from being realistically considered as still brownfield.
The future of the site has received intense media coverage, not least because, with 85 pairs, it hosts the largest population of nightingales in the country.
The development masterplan indicates significant building incursion on the SSSI, while earlier work in support of a withdrawn application made it clear it would not be possible to adequately mitigate harm to the nightingale population.
We suggested that proposed development at Hoo St Werburgh should be broadly supported by the local community and must deliver genuinely affordable housing for local needs, while we also highlighted the fact that the whole region is classified by the Environment Agency as “severely water stressed”.
The future of Medway is clearly far from straightforward.

Friday, June 29, 2018

Thanet and its Local Plan… where are we now?

Manston has hogged the Thanet headlines for so long… perhaps too long?

We have reported the machinations of Thanet and its Local Plan before on this website – and the tale is set to develop as district councillors prepare for the latest stage in this lengthy saga.
To remind you of the backdrop, in January Thanet district councillors voted down the draft Local Plan that had been presented to them, the future of Manston airport the most high-profile issue contained within it.
The council’s cabinet had earlier approved the draft Plan, which included an allocation of 2,500 properties at Manston; this appeared to be endorsement of site owner Stone Hill Park Ltd’s plans to build 2,500 homes (a figure that could rise to 4,000), business units and sporting facilities there.
However, January’s vote by the full council saw that draft Plan rejected.
Divisive an issue as Manston is, many saw the voting as politically motivated and indeed the leader of the council, UKIP’s Chris Wells, stepped down from his role the following month, Conservative Bob Bayford subsequently taking over as leader of a minority administration.
No sooner had this unfolded than, in March, Sajid Javid, Secretary of State for Communities and Local Government – frustrated with the local authority’s “persistent failure” to produce its Plan – wrote to Cllr Bayford, announcing he would be sending Chief Planner Steve Quartermain to the isle to intervene.
It is understood that two government planners have been left effectively in situ to ensure the Plan is finally published. In other words, the government has taken over production of the Thanet Local Plan from the district council.
This month councillors will receive a set of papers briefing them on the forthcoming adoption of the Plan, which will map out the isle’s development until 2031 and is due to be published this summer.
There is uncertainty over how matters will proceed from here and to what degree Thanet councillors will have any say in the Plan’s adoption. Indeed, how much public consultation will there be?
What we do know, in a situation that still seems very from clear, at least to the wider public, is that the council has put together three options for the Manston site in the Plan:

  • Manston is designated for aviation use, with 2,500 homes allocated for other sites in Thanet. It is understood these are Westgate (1,000 extra homes), Birchington (600), Westwood (500), Hartsdown (300) and Minster (100).
  • A  decision on Manston is deferred by the council for two years, allowing RSP, the group behind plans for a cargo hub airport, to push for a Development Consent Order, which would force Stone Hill Park to hand over the site.
  • Manston would be recognised as appropriate for aviation use, but it would not be designated as such for two years.

Quite what’s going on with the third option might not be readily apparent, but, either way, Thanet CPRE hopes to be involved in the Plan’s development:
“We are looking forward to engaging with the Chief Planner,” said chairman David Morrish. “A lack of public consultation was highlighted by the DCLG earlier this year as a failing in the Thanet process, so we hope that doesn’t repeat itself this time round.
“And with crazily high – and unsustainable – figures of some 21,000 new homes being rumoured, it’s important as many people as possible get involved.”
It is also worth recalling the earlier words of Geoff Orton, Thanet CPRE secretary, in relation to Manston airport: “What would be the point of building 21,000 homes without it. If there’s no airport, what economic future does Thanet have?”
As for those ridiculous housebuilding targets, Mr Orton said: “The official figure of 17,000 was already a hike on the previous 12,000 – now we could be looking at a figure north of 20,000. And all this without the airport?
“Further, we’ve lost the deaf school in Margate, along with two care homes – and more rumoured to be going. And with retail becoming more automated, what are Thanet’s young people going to do for work?”

For more on this saga, see here

For more on the Manston airport site, see here

For CPRE Kent’s response to RSP’s Manston Consultation last year, see here

Wednesday, June 13, 2018

Is Gravesham Green Belt up for grabs?

More Gravesham countryside could be lost to housing. This is Shorne Woods (pic Paul Buckley)

Fears of our Gravesham committee for the future of Metropolitan Green Belt land in the district appear to have been well founded.
The borough council has launched a consultation on proposals for the review of its Local Plan core strategy, which suggest 2,000 more homes than previously anticipated will need to be built in Gravesham.
The majority of options to cater for them entail the “release of land from the Green Belt for development”.
Gravesham CPRE belongs to Gravesham Rural Residents Group, a group formed in 2011 to defend the Green Belt, and Alex Hills has been active in the campaign.
Anticipating what was to come, the CPRE Gravesham chairman said in November last year: “The group is ready to fight again as people in Gravesham care about the Green Belt.
“In this area healthcare is at breaking point, air pollution is at dangerous levels – every one of our services is at breaking point, water supply and flooding risk in Kent are now pressing questions and our roads face gridlock – the Thames crossing alone will cause a doubling of the traffic on the A227, which runs north to south right through Gravesham.
“Is it not time we questioned the growth targets?”
Now the council, in launching its eight-week consultation, has identified three main areas for review:

  • How much development is needed
  • Where this development should be
  • If and how the Green Belt or any other policy constraints need to be changed to accommodate development

The local authority says a strategic housing market assessment carried out as part of the evidence base of the review found Gravesham had “a higher housing requirement of 7,900 homes, more than the 6,170 in the current plan”.
Further, it claims that an analysis using the government’s proposed standardised housing need assessment methodology suggests this should rise again to 8,000.
The council statement says: “When all urban sites and planning permissions are taken into account, Gravesham is about 2,000 homes short of its 2028 requirement.”
The options for housing allocation include:

  • Intensification of existing settlements
  • Expansion of existing urban areas
  • Creation of “a single new settlement through the merger of existing settlements”
  • Creation of a free-standing new settlement

The council document does not identify specific Green Belt sites for development but highlights an area running from Culverstone Green in the south of Gravesham up the A227 to Higham in the north as “a primary area of search”.
Council leader David Turner said: “With no Local Plan, the Green Belt could lose virtually all protection it has, allowing the local planning process to be sidestepped.
“Ideally, we would avoid building on Green Belt land. However, as part of this process, the council must look at all possible sites and rule them in or out.
“We are starting from the principle of brownfield land and other sites within the urban confines first but may need to seek additional land to meet our needs.
“When this consultation is complete, the council will draw up more detailed options and everyone will get the chance to comment again on those next year.”
The council intends to consult on a submission draft of its Local Plan in 2020, leading to submission, examination and adoption in 2021.
The consultation runs until June 20, 2018. If you would like to take part, visit bit.ly/2HDpjCF

Monday, April 30, 2018

Permission for judicial review on Woodcut Farm is refused in High Court

Woodcut Farm… ripe for development, believes Maidstone Borough Council

CPRE Kent, in its application to the High Court for a judicial review, was not granted permission by the Honourable Mrs Justice Lang DBE against Maidstone Borough Council’s inclusion in its Local Plan of land at junction 8 of the M20 (Woodcut Farm) as a designated site for development.
CPRE had submitted a pre-action protocol letter to the High Court  in November 2017 against the council making a decision on the Roxhill Developments planning application for the site.
In spite of our action and considerable protest from parish councils and local groups, the council chose to grant outline planning permission for the site.
Richard Knox-Johnston, vice-president of CPRE Kent, said: “This is very disappointing and rejects the views of local people who are being ignored by Maidstone council.
“It also flies in the face of two inspectors at previous inquiries that the setting of the Area of Outstanding Beauty, the visual amenity and that it will be in the setting of a heritage asset were enough grounds to reject previous applications in the same area.
“We believe that the inspector and Maidstone councillors have been misinformed by their planning officers and that this will come to light in the future.
“We also believe that the dismissal of considerable evidence on deterioration of air quality in Maidstone not only affects health in the borough but is especially dangerous for young children.
“Their application, at present, is only an outline application and we shall continue to examine the details in the future, particularly those that affect the environment.”

Wednesday, February 14, 2018

There’s a storm over Thanet… so the time is right for CPRE’s district committee to meet

There’s more to Thanet than Manston! This is Joss Bay, Broadstairs

These are tumultuous times in Thanet, following the district council’s rejection of its own draft Local Plan last week (Thursday, January 18).
The political fallout for the country’s only UKIP-led local authority has yet to settle, with the council leader under pressure to step aside, largely due to his stance over the future of the Manston airport site.
When, in October last year, the local authority cabinet approved a draft Local Plan that included an allocation of 2,500 houses at Manston, it appeared to be backing plans by owner Stone Hill Park Ltd for housing (the figure could rise to 4,000), business units and sporting facilities there.
However, last week at a meeting of full council 35 members voted it down and now adoption of a revised Plan is likely take anything up to 18 months.
The concern is that Sajid Javid, Secretary of State for Communities and Local Government, will now step in, with his department imposing its own plan on Thanet, possibly including an increased housebuilding target – up from 857 a year (a total of 17,150 up to 2031) to 1,063 (more than 21,000) – if proposed new government methodology is accepted.
Meanwhile, would-be airport operator RiverOak Strategic Partners (RSP) says it has the plans and the funding in place for the site to be revived as a freight hub.
So… Manston and the Local Plan are certain to be discussed during tonight’s (Thursday, January 25) meeting of CPRE’s Thanet district committee at Monkton nature reserve, but they will not of course be the only issues covered.
Other topics on the agenda include heritage strategy, the government’s 25-year plan for the environment (A Green Future), planning applications and Neighbourhood Plan updates.
Tonight’s meeting is at Monkton nature reserve at 6pm.

You can read more on Manston and the Local Plan here and here
For CPRE Kent’s response to RSP’s Manston Consultation last year, see here