Concern over planning reforms

The proposal to encourage new settlements (para 19/20) is also concerning – the area required for entirely new settlements is far greater than that required for just the housing. Councils are already encouraged in the current NPPF to bring forward new settlements. The proposed new policies could serve to force local people to accept large speculative schemes in unsuitable places that had been previously rejected in recent local consultations.

The idea of more quickly bringing forward development on brownfield sites in the Green Belt was trailed in the Spending Review. We believe each case must be considered carefully as brownfield in the Green Belt often contains valuable open land and open parkland that should not be developed. Paragraph 49, meanwhile, suggests that councils will be able to designate parts of the Green Belt for small developments of ‘starter homes’, entertaining the possibility of urban sprawl and drawing focus away from brownfield sites that have connections to existing infrastructure and amenities.

CPRE will be submitting a response to the consultation, the submission date for which is the 25 January 2016.

Paul Miner, planning campaign manager at the Campaign to Protect Rural England, said:

“This consultation is really concerning. Instead of addressing the current difficulties in bringing forward the right sites for the right homes, it proposes to release yet more land for development, often in the countryside and possibly in the Green Belt.

“The current policy isn’t working, but these proposals will make things worse. Releasing unlimited amounts of greenfield land will not deliver the Government’s welcome pledges to regenerate brownfield sites.”

December 9th 2015

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document