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 – 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