Summary of Main Objections to the Preferred Development Path Option SO3 from Protect Kent
Published: 27-07-2009
Summary of Main Objections to the Preferred Development Path Option SO3 from Protect Kent
The following provides a summary of Protect Kent’s main objections to the Council’s preferred development path option SO3. The summary draws in particular on our responses to questions 3, 7, 19, 25, 29, 30, 32, 33, 34 and 36 of the preferred options document, though it is not intended to be a substitute for our full response.
Protect Kent objects to the preferred development path option SO3 for the following reasons:
• Option SO3 promotes a strategy that will involve housing development potentially significantly (38%+) above that planned for by the South East Plan making it contrary to that strategic Plan.
• No case for the growth now proposed was made by the Council during the preparation of the South East Plan, and the level of development considered appropriate for Shepway in the South East Plan was arrived at in the context of wider strategic considerations in the Ashford and East Kent Sub-region and the major environmental constraints present in Shepway. Shepway is not identified as an area of growth in the South East Plan, and to seek an alternative strategy through the Core Strategy that seeks to do this is entirely inappropriate and would be contrary to the statutory strategic planning process.
• The selection of the preferred option does not clearly flow from the Vision and Strategic Objectives as required by PPS12. The Vision and Strategic Objectives are vague and unclear making it impossible to see what the Council is seeking to achieve by promoting increased development in the district.
• Appendix 2 of the Sustainability Appraisal (SA) does not present a detailed assessment of all four options, making it impossible to compare their respective sustainability credentials and to see why option SO3 is considered the most sustainable option. We consider that option SO4 is the most sustainable of the options presented.
• Option SO3, unlike all the other options, expresses potential development as a range (6,000 – 8,000 dwellings and 4 – 14ha employment land). This is vague and lacks the precision and certainty that a development plan should provide. It also means that the SA must be treated with caution as it is unclear what exact level of development has been used in the appraisal. The preferred options document suggests, though, that the intention of option SO3 is to deliver a level of housing at the top end of the range. To present option SO3 as a range of housing is consequently misleading. It should simply have been presented as an option for 8,000 dwellings, or presented as two options - for 7,000 and 8,000 dwellings respectively - and assessed by the SA on that basis.
• The SA of option SO3 is overly positive, even if it is considered in the context of 8,000 dwellings. We consider that the preferred option cannot be scored ‘significant positive’ under SA objectives 1, 2, 5, 8, 9, 11, 12 and 15. We also consider that the appraisals of the proposed strategic sites at New Romney, Westenhanger, Sellindge and Lympne are also overly positive.
• We dispute the claim that option SO3 can respond to all three strategic issues, and that it is the most sustainable option. We find it difficult to see in particular how option SO3 complies with strategic objective B. As a result of promoting more development than necessary, especially in the rural parts of the District, it will inevitably result in more greenhouse gas emissions as a result of more construction and travel, and will result in more development than necessary being located in areas vulnerable to sea level rise and flood risk. These were all factors taken into account in preparing the South East Plan and arriving at 5,800 dwellings (i.e. option SO4).
• We dispute the claim that option SO4 would jeopardise the delivery of urban regeneration opportunities in Folkestone. This was not the conclusion of the South East Plan Panel who stated in their report that “the District Council did not provide any evidence to suggest that the proposed levels (of housing) would not give adequate flexibility to meet its objectives of regenerating the Folkestone seafront and other initiatives.” We can see no reason why the strategic regeneration sites proposed for Folkestone and Hythe could not equally feature under option SO4, securing the Council’s regeneration objectives.
• The statement that option SO3 “is based on an assessment of the capacity to deliver change and meet the structural challenges Shepway faces” has not been demonstrated in the evidence base.
• The achievement of option SO3 relies upon significant development in the rural areas including a number of strategic sites. The benefits expected to accrue to the settlements affected are unclear, and the selection of the sites seems to be purely opportunistic rather than in accordance with the sustainability credentials of the settlements involved or any identified deprivation or social inequalities, or deficiency in local services or facilities. Furthermore, most of the strategic sites proposed in the rural areas do not have the critical mass to deliver even a basic level of local services. The outcome is an unsustainable pattern of development that will inevitably result in increased reliance on the private motor car to access most services and facilities and jobs, contrary to Strategic Objective B and regional and national planning policy.
• By focussing the vast majority of development on strategic sites in the North Downs area, the preferred approach is contrary to the views expressed at issues and options stage where respondents favoured small scale housing development.
• Contrary to statements made in the preferred options document, all but one of the strategic sites in the North Downs area fall in the countryside, and we disagree that the preferred option maximises the use of large brownfield sites as all of the strategic sites involve greenfield land.
• Option SO3 will place pressure on existing infrastructure and will create demand for new infrastructure (i.e. transport, utilities, social and community services). However, no details are given as to what new infrastructure is needed and how and by whom it will be delivered. The identification and delivery of essential new infrastructure is an essential part of a Core Strategy, and the document fails to show how this will be achieved under the preferred option.
• Option SO3 will increase pressure on an already stressed water supply, and there is no evidence demonstrating that this level of proposed development can be accommodated. The Sustainability Appraisal acknowledges that this is uncertain.
• Mention is made of strategic commercial development, but the Core Strategy does not put forward any specific proposals for employment development to support the ‘strategic’ housing development proposed.