District chairmen's reports... in their entirety!

In the Autumn/Winter 2019/20 edition of Kent Voice, we carried reports from our district and committee chairmen from around the county. Space restrictions meant we couldn’t bring you them in their entirety, so here they are…

Ashford –
Christine Drury

• CPRE Ashford would love to have more volunteers bringing their local knowledge to help us make relevant and constructive comments on planning applications, large and small. We also now have a separate meeting looking at wider issues that may help us make early suggestions for the next Local Plan, as well as immediate issues. If you are interested in either, please contact the office on 01233 714540.
• Since the 38-minute high-speed train service to St Pancras started in 2009, the Ashford area has become a developers’ honeypot. That has been good for the long-awaited regeneration of the town centre, although it has lost its M&S and will lose its Debenhams. Flats are being built, a cinema and brewery have arrived and restaurants, leisure and culture are the next priorities for the town centre. We support this brownfield regeneration.
• The Local Plan includes the development of large swathes of countryside to the south of the town, adjacent to the now-emerging Chilmington Green urban extension. Together these are now designated as South Ashford Garden Community. We have commented formally and are engaging to ensure these are well-planned developments including provision for cycling and walking, with 10-minute bus provision assured. Outline plans are too car-dependent.
• The pressures outside Ashford town are now huge. The borough is one of the largest in the county and, like most of Kent, is more than 75 per cent countryside. Houses in villages sell at a premium. If developments comprise fewer than 10 properties and are in a small plot they avoid the 40 per cent affordable requirement. Cumulative impacts are being ignored. In the absence of buses, shops and local school places, they are car- and delivery-dependent, putting huge pressures on rural roads as well as being against the direction in which we need to move to be climate-behaviour-compliant. Ashford CPRE generally supports small infill development, but in combination with allocated sites the cumulative strain on parishes is destructive. Some are outrageously opportunistic: Wates’s proposal for a further 250 homes in Tenterden is not in the Local Plan and would destroy the character of a small town where the green spaces reach deep into its heart from the surrounding AONB. Tenterden already has a lot of approved development and an inadequate bus service.
• We collaborate wherever we can in the borough – currently with Rural Means Rural and the Limes Land Protection Group in Tenterden. Do contact us if you are part of a group not yet working with CPRE.

  Canterbury – Nick Blake

• After Barrie Gore’s report in the previous edition of Kent Voice featuring the city council’s own application for a park-and-ride at Wincheap, it has reacted to a huge amount of objection but only by moving the edge back a few metres from the River Stour. This fails to recognise the impact on the Stour’s setting in this edge-of-city location. The floodplain is fairly narrow at this point, but the presence of trees means the river setting survives the proximity of Wincheap Industrial Estate. It seems our city council has no passion or eye for detail. Members of the planning committee will be in the difficult position of voting on their own council’s application. It is possible many might feel unhappy about the application but be compromised by the situation.
• The so-called heritage champion is now also the leader of the council, which we feel is a potential conflict of interest. He has not championed any heritage cause – all we get are meetings and strategies but no positive action. The city has what look like effective policies to protect the environment, but they are not implemented. We focus so much on well-written documents, driven by hours at the desktop rather than going out and seeing.
• Housing developments are stalled because of stakeholders not meshing together. At Sturry the council’s ‘green gap’ highlighted in the Local Plan is ridiculously narrow and will not prevent the visual merging of that village with Canterbury. The adjacent woodland that is to be retained has wedges of housing thrust into it and no plan for its maintenance. No countryside protection there!
• The A28 Sturry relief road is short of finance and is set between planned housing developments. Have you noticed how much new housing is sited next to busy roads yet such locations have been shown to be bad for health? The nearby development at Hersden looks just like any other estate. Why do we have policies asking for local distinctiveness when we get the same mediocre housing all over the country? So not a jot of cheer from our city, I’m afraid.

Dartford and Gravesham – Alex Hills

• The Bean interchange public inquiry began at the start of October. The Highways England proposals will not achieve their objectives, having a greater impact on the environment and residents than they should. Creating an additional eastbound slip road at Bean on to the A2 will have a negative impact on the strategic road network. It is concerning that no peak-flow forecasting work was done for the project or analysis of what the impact would be if the new Thames crossing was built and one of the crossings was closed.
• It seems the only thing that will stop the new Thames crossing going ahead now is funding. This is totally wrong; however, now is the time to stop fighting the proposals and focus on making the project as good as we can. Getting as much of the road underground and minimising the impact on Kent roads must be our objectives. The crossing will have a large impact on Dartford, Gravesham, Maidstone, Tonbridge & Malling and even Dover.
• It is not possible for the crossing to include a rail link due to topography on the Kent side and the required larger tunnel bore would cause the tunnel to rise.
• There is a viable £3 billion project being developed that would see a new railway line linking HS1 with the London Gateway deepwater port in Essex. Having witnessed the problems CPRE has had over HS2 and how evidence has come to light showing the project is not in the national interest, I would urge caution with this scheme.
• I would like to make a plea to not support any cycle lanes that are just painted lines in the road as research in this country and in Australia has proved it makes the road more dangerous for cyclists. The reason is that cars drive closer to cyclists when there is a painted cycle lane than when there is no road marking. Pedestrians, cyclists and motorists should be separated by some form of physical barrier.

Dover – Derek Wanstall

• Dover District Council is progressing with its Local Plan review. At a recent meeting, concerns were expressed about infrastructure and the amount of traffic exiting Deal at peak times, which is causing frequent hold-ups at upper Deal roundabout and on the Dover, Deal and Sandwich bypasses towards Thanet. Of course, development on the edge of these towns exacerbates the problem.
• Lydden Hill racing circuit will soon be up for discussion, with new plans for expansion being submitted. Noise and access is a serious problem, in conjunction with the proposed increase in race days, along with concerns relating to the AONB.
• We await further news on Farthingloe and Western Heights. Nearby, The Citadel is up for sale as it is not being used for immigration detainees. With heritage refurbishment also on the agenda, perhaps the future of the whole area should be reviewed. It is good to see progress being made.
• CPRE both nationally and locally is discussing ways of increasing membership, helping to keep our countryside for the future. Developers who try any way possible to achieve their ambitions by ignoring AONB and Green Belt designations must not be supported. CPRE has always stated its support for development but in the right places. Proposed developments should always consider properties for low-paid workers and people who wish to downsize.
• Air pollution is a great concern, with more vehicles on the roads, engines left running in hold-ups and so on. Developers should plant more trees and retain them on development sites, improving the health of the nation. Sadly, the continual increase in the population only means an increase in the number of properties required.
• Members and non-members alike are invited to the Dover AGM on Tuesday, November 5 (11am), at The Royal Hotel, Beach Street, Deal CT14 6JD. Refreshments and nibbles will be available.
• Finally, at the Dover AGM I shall not be seeking re-election as chairman. With important issues in the area, hopefully a good turn-out will bring forth both a new chairman and a minutes secretary.

Maidstone – Gary Thomas

• The review of the Maidstone Local Plan is taking place, due to be in place for 2022. The responses to the recent Call for Sites are due to be publicised very soon. We have responded extensively to the review, both in writing and through meetings. The increased annual rate of building from 882 dwellings to 1,236 from the start of the new Plan in 2022 presents huge problems and is due largely to the government’s ‘adjustment factor’ imposed on local authorities. This appears to just make a bad situation worse by concentrating development so heavily in the South East. The failure to match the need for improved infrastructure alongside the increasing population is obvious, but Maidstone Borough Council has no responsibility for most of what is needed (for example traffic, roads, health, education, waste disposal and public transport) so this severe mismatch is set to continue.
• Three proposals for large ‘garden communities’ are causing great concern. Two are from developers – one just north of the county showground, the other alongside Marden – and one apparently organised by the borough council (secretly!) for Lenham Heath. We will be responding more as the plans develop.
• There are other planning applications in Lenham that are not in the Local Plan. Lenham Neighbourhood Plan appears to be being seriously delayed.
• Two new Gypsy and Traveller applications feature large built ‘dayrooms’ on each pitch. Gypsies and Travellers have policies not available to the rest of the population due to their culture of living in caravans in the countryside, allowing them to continue in this way. Building ‘dayrooms’ appears contrary to the reason for this policy and is a development we think should be challenged.
• The Glover review into national landscapes has, disappointingly, ruled out expansion of the Kent Downs AONB, at least for the time being.

Medway – David Mairs

• A petition with hundreds of names was sent to Medway Council urging it to reject applications for large-scale development in and around “the important green lung” of Lower Rainham and Lower Twydall, including a proposal for 1,250 dwellings in the Pump Lane area and housing plans to the north of Rainham. If the proposals are accepted, they will remove a significant part of the greenfield buffer preventing a continuous urban sprawl between Lower Rainham, Twydall and Gillingham.
• As with the rest of the county, Medway faces huge challenges if it is to retain substantial areas of countryside. CPRE Kent is, however, under-represented in the district, so we are keen to hear from anyone who lives in Medway and would like to get further involved with what we do. Please feel free to call the office on 01233 714540.

Sevenoaks – Nigel Britten

• We have embarked on the final stage of the Local Plan, the examination in public. The central question for the inspector is whether the plan is ‘sound’, meaning whether it complies with policy requirements in all respects. Within that, the key issue is housing. The government’s formula for calculating housing need stipulates that 13,960 dwellings should be built during the 20-year Plan period, 2015-2035. Instead, the Plan proposes a total of 10,600, with the justification that in a district that is almost entirely Green Belt and two-thirds AONB there is nowhere to put so many houses. We have commented at all stages of the process and are grateful to our two professional planners at the CPRE Kent office, Paul Buckley and Julie Davies, who have given us invaluable support and been presenting evidence at the examination. One major purpose will be to challenge the intention at some future date to build some 2,500 dwellings on what is now Pedham Place golf course. Committee members have been attending on as many days as possible over the four-week period, commenting in particular on proposed sites at Edenbridge and Fort Halstead.
• Threats to the countryside are everywhere. The committee is always ready to welcome new members, so we hope anyone reading this will think about giving a little time to help protect the district’s wonderful countryside.

Shepway – Graham Horner

• Folkestone & Hythe District Council planners have published an initial response to Folkestone & Hythe’s planning application for Otterpool Park. It echoes many of the concerns we have raised, including requesting the applicant to provide more information on and/or reconsider:

• strategy for dealing with a major road (A20) cutting through the
middle of the town

• more detailed proposals for the town centre (‘Tier 2’ design)
and how it will integrate with the proposed public park, Westenhanger station,
Westenhanger Castle and the A20

• the rationale for the ‘overarching spacial concept’ (for
example, heights, legibility and key views)

• a ‘21st-century transport vision’ as opposed to ‘predict and
provide’

• better non-motorised transport links within the development and
to Sellindge and Folkestone

• merging of neighbourhoods planned south of the A20

• clarity on strategy for delivery: definition of ‘master
developer’ and long-term stewardship/governance

• a more joined-up approach to green infrastructure and provision
for leisure

• the level of detail to be agreed at this stage, especially for
later phases

FHDC has bought Westenhanger Castle after a long negotiation.
Objectors have branded this a waste of money, but it will open opportunities to
integrate it better into the public realm.

• I have, wearing my parish councillor’s hat, toured new developments in the Cambridge area (Alconbury to Saffron Walden) at FHDC’s invitation. The economy around Cambridge is significantly different to that in Shepway. We saw some high-quality housing but learned it comes at a price unlikely to be sustainable in our area. Letchworth is a model for what is now called ‘land value capture’; the town owns almost all the land and takes in £12 million a year from rents and other sources to be used for maintenance and community projects. FHDC will not own all the land at Otterpool Park. At all projects visited, there was a design code that could be enforced by mechanisms with more teeth than planning conditions (such as financial penalties).
• There is no news on the examination of the draft Core Strategy review, without which Otterpool Park should fail at the first jump.
• FHDC has just published for consultation a draft Gypsy and Traveller Strategy to address a shortcoming of the Places and Policies part of the Local Plan.
• Development of Princes Parade was formally given consent, despite a vote in full council to abandon the project.

Swale – Peter Blandon

• Swale’s administration changed after May’s local elections and a new alliance is now in control. Several of its members have a track record of opposing large-scale developments and, true to form, they have now refused planning permission for two large schemes. These are:

• up
to 675 homes at Wises Lane in Borden, with associated schools, surgeries and transport
links. This is a deeply unpopular development that goes a long way to merging
Borden with Sittingbourne.

• up
to 700 homes at Barton Hill Drive, Minster, on the Isle of Sheppey

Both these proposals are on land allocated for housing in the adopted Local Plan and both had been recommended for approval by planning officers. In January, the previous administration had resolved to grant planning permission to the Borden development subject to a satisfactory S.106 agreement. However, when the new committee considered the scheme, it voted 13-2 to refuse permission. The developers agreed to a short extension to the application (it was originally submitted in October 2017) and, when that expired, immediately appealed on the grounds of non-determination. The appeal is to be decided by the Secretary of State rather than a planning inspector. The Barton Hill development had almost been refused in February with an 11-4 vote against it. But, as happens in Swale, the head planning officer called in the application, effectively nullifying the vote. The proposal returned to the committee in July with a recommendation to approve but was refused. The grounds given were harm to landscape; the setting of Parsonage Farm, a listed building; insufficient affordable housing; and transport.
The developer has said there will be an appeal, but so far none has been lodged.
So, developments totalling almost 1,400 dwellings have been refused since the change of administration. This is about two years’ housing under the adopted Local Plan and against a background of Swale failing the government’s Housing Delivery Test, meaning it must now apply a 20 per cent buffer to its housing land supply. So more sites will need to be allocated for housing. As both planning applications seem likely to go through on appeal, Swale’s new administration might be playing a dangerous game.

Thanet – David Morrish

• Lots of valuable work done has been done for us by the team at Charing over the past six months; I and the committee thank them for their professionalism and dedication – we are fortunate to have such a good team to back us up.
• The last days of our two big inquiries (Local Plan and Manston airport) were enlivened by the shock news from RiverOak, the applicant for the Manston Development Consent Order, that Stone Hill Park Ltd had agreed to the Acquisition by Agreement by RiverOak MSE Ltd on July 2 for the purchase of all the land SHP had owned at the airport site. This effectively means that the largest obstacle to the potential reopening of the airport (the opposition of SHP to RiverOak’s bid for a compulsory purchase order) has apparently been overcome. However, at the DCO inquiry, it was apparent that little progress had been made with regard to the acquisition of the many parcels of Ministry of Defence-owned land covered by the DCO, including the navigational apparatus. There is also the question of who are the RiverOak backers, which will not be answered in public until Grant Shapps, Secretary of State for Transport, has made his decision. Apparently, neither the counsel for SHP nor for RiverOak had been informed of any details of the purchase other than the price and the associated provision for SHP to retain all income from the ‘temporary’ lorry park at Manston should Brexit necessitate its use, so we await Mr Shapps’s considered judgement in the new year.
• In the meantime, Thanet District Council planners need to decide how to revamp the draft Local Plan now that the housing land originally planned by SHP has been taken out of the equation. Meanwhile, housebuilding flatlines in Thanet (and newly-built houses await buyers) as, presumably, building operatives flock to more profitable pastures elsewhere in Kent.

Tonbridge and Malling – Mike Taylor

• It has been a troubling time, largely due to Tonbridge & Malling Borough Council’s deeply flawed draft Local Plan. It has fragmented the borough into areas that support parts of it but who are terrified that any revision will fall on them and areas that have been unfairly loaded with housing proposals. Despite lodging the Plan in January, there is no sign of the appointed inspectors accepting it, which has left the door open to the usual suspects like Gladman to attempt ‘windfall’ applications because of the swiftly diminishing housing land supply.
• The latest bombshell for TMBC is that the inspectors will split the examination into two phases, if it ever happens. Phase 1 will examine three issues – procedures, Green Belt and selection – while Phase 2 will not proceed until the inspectors are satisfied with Phase 1. We have long said that TMBC’s selection process was deeply flawed, allocating some 4,000 homes in the Green Belt while ignoring plots in the Call for Sites that were deemed ‘suitable and achievable’ and non-Green Belt, which could have provided 11,700 homes. This tends to explain the inspectors’ requirements for the Phase 1 examination.
• It has been difficult here because traditionally we have been composed largely of parishes in the north-west of the borough, one of the areas hit hardest by the Local Plan proposals, but we are aware it would be desperately unfair to use our position on the committee to push through an official CPRE response that has a strictly local benefit, and so we have limited the number of meetings held in recent months.
• While the government continues to swear it will protect the Green Belt, many refusals for Green Belt development are being overturned after higher intervention and so we have supported parishes in drafting a petition that demands the government properly defend Green Belt nationally: see here

Tunbridge Wells – Liz Akenhead

• The draft Local Plan has at last been published, with Regulation 18 consultation to run to Friday, November 1. We are struggling to get to grips with its 518 pages, along with the 217 pages of almost unintelligible Sustainability Appraisal (in which the economic and social elements are generally held to outweigh the environmental) and hundreds of pages of other supporting documents such as the final Strategic Housing and Economic Land Availability Assessment (SHELAA), the Distribution of Development Topic Paper and the Draft Infrastructure Delivery Plan.
• The Plan states that overall some 5.35 per cent of the Green Belt within the borough is to be de-designated and that “in accordance with the NPPF the Plan does not designate other land as ‘replacement’ Green Belt to replace that to be removed, but rather sets out how compensatory improvements to the environmental quality and accessibility of remaining Green Belt land can be made”. On a first reading, I have not noticed much evidence in the Plan that these improvements will materialise.
• In a borough where 70 per cent of the land is AONB, 22 per cent (some of which overlaps with the AONB) is Green Belt, 16 per cent is ancient woodland, 7 per cent is floodplain, almost all ‘rural fringe’ land has already been allocated, brownfield opportunities are limited. With a reluctance to build high-rise in historic town centres, there are no painless ways of accommodating the housing numbers required under the government formula together with their associated development. Surely if there is anywhere the government’s policy exception to the requirement to provide for the full Objectively Assessed Need (OAN) for housing should apply, it ought to be Tunbridge Wells, with its protected areas such as Green Belt and AONBs. However, not only does the draft Local Plan aim to meet the full OAN, it proposes to exceed it by 9 per cent!
• As well as massive development at Paddock Wood (4,000 dwellings in addition to the 1,000 already allocated there but construction reported to be halted because of problems with foul drainage) and 2,500-2,800 dwellings proposed at Tudeley, up to 800 dwellings will be allocated in the AONB at Cranbrook and some 700 in the AONB at Hawkhurst. New secondary schools are planned on AONB and Green Belt land at Spratsbrook Farm/Ramslye Farm south of Tunbridge Wells (with more than 200 dwellings as well) and on Green Belt land containing ancient woodland on the edge of Tonbridge. The villages have smaller allocations.
• In addition to safeguarding land for the dualling of the A21 from Kippings Cross to Lamberhurst, three new roads are proposed to serve the proposed new developments, which will partly pay for them: an offline A228 Colts Hill bypass; a partly new, partly upgraded road (whose alignment remains to be decided) between Tonbridge and the new A228 bypass to serve the proposed Tudeley settlement; and a new road at Hawkhurst to partially bypass the Highgate crossroads. Very little information has been provided about the environmental effects of or justification for these new roads.
• We shall be responding robustly to these issues, but the draft Plan is not all bad: many of the proposed Development Management Policies deserve support and where this is the case we shall give it.

Environment – Hilary Newport

• The environment committee has a new chairman in David Wood, who took on the role after Graham Warren stood down after 16 years in the position. Graham was given a gift as a sign of appreciation for his contribution to CPRE Kent and, in particular, this committee.
• The main topic has been the proposed Cleve Hill solar farm and committee members have made a range of contributions to the ongoing CPRE Kent submission to the public examination.
• Graham Warren prepared a report for the campaign group at Dunsfold, Surrey, contesting plans for shale-gas exploration there.
• Other issues covered by the committee have included land use, food security, waste and water resources.

Historic Buildings – John Wotton

• The Historic Buildings Committee again partnered with the Kent School of Architecture and Planning to make the annual Gravett Award for Architectural Drawing. From a large field of entries on the theme of Norman architecture, the judges, chaired by architect Ptolemy Dean, chose Ayako Seki as the winner for her drawings of Dover Castle. She was presented with the award at the school’s end-of-year show and prize-giving.
• The proposed development at Prince Parade, Hythe, between the Royal Military Canal and the sea remains a concern to the committee. We objected to the application and the council’s granting of planning permission to itself remains controversial, especially after May’s local elections. The branch will be supporting a campaign to save Princes Parade.

• 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