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CPRE Kent supports county MPs in attack on 'inherently unreasonable' new housing targets

Elementary Admin
By Elementary Admin &
13th September 2020

CPRE Kent, the countryside charity, is backing a group of the county’s MPs who have written to government powerfully expressing their concerns over increased housing targets.
Kent fares particularly badly in the revised totals proposed in the Changes to the Current Planning System consultation, with almost all its district authorities facing annual housebuilding hikes of up to 125 per cent.
If the figures, based on what has already been described as “another rogue algorithm” and following analysis by Lichfields and Savills development consultancies, are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already eye-wateringly high.
In total, the county would be required to build 14,908 homes a year – up from the current figure of 12,045. And even the latter figure is critically flawed as it is based on outdated household-projection statistics from the Office for National Statistics.
The 2014 ONS figures used by the government have been superseded by two further forecasts, in 2016 and 2018, each forecasting a much-reduced figure for necessary new homes.
The MPs’ letter, addressed to Ministry of Housing, Communities & Local Government and Housing Secretary Robert Jenrick, has been headed by Helen Grant (Maidstone and The Weald) and signed by 10 other Members.
The burden on Kent does seem particularly unacceptable given that it has already delivered so much housing in recent years.
As the letter, which pulls no punches, says: “The proposals also appear inherently unreasonable, particularly to those local authorities in Kent who have already successfully worked with the Government to build the homes we need. One has to question the propriety of constantly increasing targets with completely unrealistic timescales…”
A report from the UK Centre of Ecology & Hydrology released in July this year showed Kent had already lost more land to urbanisation than any other county between 1990 and 2015.
The report revealed a net increase in urban areas in the county of 33,606 acres, substantially ahead of anywhere else – Essex (27,923 acres), West Yorkshire (27,182) and Surrey (24,711) came the closest.
Mrs Grant’s letter to Mr Jenrick has been signed by Rehman Chisti (Gillingham and Rainham), Greg Clark (Tunbridge Wells), Tracey Crouch (Chatham and Aylesford), Sir Roger Gale (North Thanet), Damian Green (Ashford), Gordon Henderson (Sittingbourne and Sheppey), Gareth Johnson (Dartford), Craig Mackinlay (South Thanet) and Tom Tugendhat (Tonbridge and Malling).
Dover faces the greatest increase of all – a scarcely credible 125 per cent hike on its current target. It could be told to build 1,279 homes a year, almost three times the number to have gone up over the past three years.
Other substantial increases would be imposed on Dartford (85 per cent on top of current target), Tonbridge and Malling (71 per cent), Swale (43 per cent) and Folkestone and Hythe (38 per cent). 
The current situation has echoes of a government consultation three years ago into changing the planning system in a bid to boost the amount of homes being built, notably in the South East.
The proposed change in methodology, laid out in the document Planning for The Right Homes In The Right Places: Consultation Proposals, detailed a total of 3,400 extra dwellings a year – a rise of 8 per cent – on targets across the region.
Staggeringly, two-thirds of these were earmarked for Kent, a county already having to accommodate some of the highest levels of housebuilding in the country.
It appears the inequitable focus on Kent has not disappeared.
The consultation closes at 11.45pm on Thursday, October 1.   

Sunday, September 13, 2020


  • 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