CPRE slams Dover Core Strategy
Published: 26-03-2009
CPRE Kent and CPRE Dover have objected in the strongest terms to Dover District Council's Core Strategy. The Core Strategy, which will set the Council's development strategy for the next 20 years, promotes a high growth strategy that would see 14,000 new homes, which will mainly be built on greenfield land. In particular it will include 5,750 new homes on land around the village of Whitfield.
Brian Lloyd, CPRE Kent's senior planner considers the strategy to be high risk, undeliverable and inappropriate. First of all it does not accord with the South East Plan, which is likely to include a target of 10,100 dwellings - already 4,000 higher than was included in the draft South East Plan. By providing an even higher level of growth means that there could be implications for the whole of East Kent, and these implications have not been assessed.
Interestingly, at the South East Plan Examination in 2006, even though it had considered a target of 14,000 dwellings the District Council was adamant that a strategy based on 10,000 homes was the optimum fit between dealing with the identified issues, the availability of land considered to have development potential, and the viability of delivery. They considered that this could be achieved with just under 60% of housing development taking place on brownfield land. This remained the Council’s Preferred Option in the consultation undertaken on the Core Strategy in March 2008, and it’s unclear why the Council has now changed its mind at this late stage in the plan making process.
The Council point to Dover being made a Growth Point to justify the high growth strategy, but in fact the award of Growth Point status is very specific and seeks to increase Dover’s housing target for a clearly defined period – for 2008-2017. This has been taken fully on board in the South East Plan, and the target of 10,100 set.
Delivering 14,000 new homes will mean a building rate of 700 homes a year. Having only achieved 434 homes a year over the last five years - at the peak of the housing boom - it is clearly unrealistic to expect such a massive increase in building, especially at a time of recession. Even delivering the South East Plan target of 10,100 dwellings will be a challenge. This is especially so when the Council's own research describes the housing market in Dover as isolated and self-contained and increasingly fragile.
The basis of the Council’s strategy is that by promoting housing growth, it hopes to expand the population of working age by attracting people into the District. It is difficult to see how this will actually be achieved in a housing market which the Council’s own research describes as isolated and self contained. It will also be the case that Dover will be in competition with all the other East Kent authorities who also have to accommodate extra housing
Particularly concerning to CPRE is that the strategy will mean significant encroachment into the countryside and the use of greenfield land. The vast majority of the new dwellings will be on greenfield land, most notably at Whitfield where 5,750 are proposed but also at Aylesham, Sandwich, Deal and many of the district’s villages. When Government is saying that at least 60% of development should be focused on brownfield land, we think it is fundamentally wrong for the Council to embark on such a damaging strategy.
And it will be very damaging, a fact confirmed by the Council’s own appraisal of the strategy. The Council has undertaken a Sustainability Appraisal of the strategy. The first objective of the Core Strategy, which is at the heart of the high growth strategy, is to “foster population growth particularly in working age families to support forecast growth in the local economy – focused at Dover”. This is assessed against 14 sustainability objectives, but under 11 of these objectives the SA is unable to identify any positive outcomes – it’s full of uncertainty and question marks.
In fact the appraisal concludes that this high growth option has the most uncertainties associated with it and that a target of 10,000 homes was likely to be more deliverable during the plan period, and cause less environmental harm. Again, this begs the question why change the strategy at the last moment?
It is also doubtful that the strategy will deliver the jobs that are claimed. Much importance is given to the introduction of the high speed train service to London, but rather than bringing people into Dover the Council’s own studies report that commuting from Dover Priory will increase by 52%. It also cautions that London-based commuters with higher disposable incomes will push up the price of housing meaning that many people will actually be forced to move away from Dover. This is totally the opposite effect that the Council thinks the strategy will have.
CPRE think that the Council has become over focused on the need to create jobs, at the expense of other considerations. It has had limited regard to the impact that the strategy will have on the countryside and people’s quality of life. It is, in short, an unsustainable strategy that is high risk and unrealistic. We agree that action needs to be taken to promote jobs in the district – and of course people need homes. But the Council needs to adopt a realistic strategy that addresses environmental as well as economic and social needs. We have called on the Council to abandon this damaging high growth strategy and adopt a strategy that is in line with the South East Plan, and one that is focused on the regeneration of Dover town. There may need to be some greenfield development, but not on the scale currently proposed. The strategy needs to ensure that greenfield development is kept to a minimum, and that it is in the must appropriate locations.
Read our Dover LDF Consultation Response