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Emphasis on brownfield development welcomed in Swale Local Plan
CPRE Kent has welcomed many elements of Swale Borough Council’s draft local plan – in particular its focus on the development of brownfield sites and regeneration of urban areas. But we believe the jobs target of 7,000 is unachievable and want more greenfield sites protected.
“We support the brownfield regeneration opportunities which could breathe life back into Sittingbourne town centre and boost Queenborough and Rushenden on the Isle of Sheppey,” said Brian Lloyd, Senior Planner at CPRE Kent. “However, we believe that the extent of the greenfield allocations is unnecessary and will either damage the countryside or impinge on a sensitive countryside gap.”
CPRE Kent last week (January 30) submitted a full response to Swale Borough Council on its draft local plan.
In our comments, we accept the housing target of 10,800 new homes by 2031 and support the council in its reasons for not opting to include a higher figure despite demands for this from the house building industry. However, we believe the employment target of 7,000 new jobs by 2031 is unachievable and will unnecessarily increase the pressure for more housing. We suggest that 4,000 would be more realistic.
We also believe the housing supply has been underestimated and so some greenfield housing sites could be removed from the plan – in particular land north of Key Street, Sittingbourne (30 homes) and land north east of Sittingbourne (106 homes).
We generally accept the following major sites:
- NW Sittingbourne – although a large greenfield site, this is a self-contained area between the town and the A249 and will offer substantial opportunities for housing and the provision of open space and major landscaping;
- Frognal Lane, Teynham, which also has the support of the Parish Council
- Sites at the Western Link and Oare Gravel Workings in Faversham – both brownfield sites.
Mr Lloyd said: “We are generally supportive of much of the plan and are particularly pleased it recognises the importance of tranquillity and it has reinstated the important local countryside gaps, retained designated areas of high landscape value and also designates a number of local green spaces.”
CPRE Kent continues to oppose the proposed greenfield mixed-use site at Lady Dane Farm on the east of Faversham. Although Swale Borough council has already resolved to grant permission, we are opposing a proposed second phase of development here.
We object to the following proposed greenfield employment sites:
- Land south of Kemsley Mill, Sittingbourne;
- Land at West Minster, Sheppey;
- Land at Whiteway Road Queenborough;
- Land north of Swale Way, part of the larger development in NW Sittingbourne.
“We don’t believe these sites are needed – if developed into factories and other industrial buildings it would have a huge impact on our landscapes and, in the case of Swale Way, remove a precious green gap between Sittingbourne and Iwade” said Mr Lloyd.
In transport issues, CPRE Kent objects to the final leg of the Sittingbourne Northern Relief Road around Bapchild and the identification of an ‘area of search’ for it, saying it is neither needed nor justified. And we are concerned that the plan takes no action to improve Junction 5 of the M2 even though the plan openly admits this “is the single greatest transport constraint in the borough”.
We have also objected to the identification of longer term development opportunities at Sheerness Port and the Kent Science Park and for a Sittingbourne Southern Relief Road (SSRR). We contend that it is premature to signpost these proposals for the future without providing more detail about what exactly is proposed and the evidence that justifies them.
Mr Lloyd explained: “These are major development proposals, and, in the case of the expansion of the Kent Science Park and the provision of the SSRR, will be very damaging to the landscape south of Sittingbourne. We are most concerned that their inclusion in the plan now will in the future be used as the justification for including them in a future plan, even though nobody would have had the chance to challenge them now. If these are important longer term proposals then the Council needs to set out in this plan what they have got in mind so that people can make informed comments on them now.”
To read our comments in full click here
To read a summary of our main points click here
February 3rd 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
