Is Gravesham Green Belt up for grabs?

Fears of our Gravesham committee for the future of Metropolitan Green Belt land in the district appear to have been well founded.
The borough council has launched a consultation on proposals for the review of its Local Plan core strategy, which suggest 2,000 more homes than previously anticipated will need to be built in Gravesham.
The majority of options to cater for them entail the “release of land from the Green Belt for development”.
Gravesham CPRE belongs to Gravesham Rural Residents Group, a group formed in 2011 to defend the Green Belt, and Alex Hills has been active in the campaign.
Anticipating what was to come, the CPRE Gravesham chairman said in November last year: “The group is ready to fight again as people in Gravesham care about the Green Belt.
“In this area healthcare is at breaking point, air pollution is at dangerous levels – every one of our services is at breaking point, water supply and flooding risk in Kent are now pressing questions and our roads face gridlock – the Thames crossing alone will cause a doubling of the traffic on the A227, which runs north to south right through Gravesham.
“Is it not time we questioned the growth targets?”
Now the council, in launching its eight-week consultation, has identified three main areas for review:

• How much development is needed
• Where this development should be
• If and how the Green Belt or any other policy constraints need to be changed to accommodate development

The local authority says a strategic housing market assessment carried out as part of the evidence base of the review found Gravesham had “a higher housing requirement of 7,900 homes, more than the 6,170 in the current plan”.
Further, it claims that an analysis using the government’s proposed standardised housing need assessment methodology suggests this should rise again to 8,000.
The council statement says: “When all urban sites and planning permissions are taken into account, Gravesham is about 2,000 homes short of its 2028 requirement.”
The options for housing allocation include:

• Intensification of existing settlements
• Expansion of existing urban areas
• Creation of “a single new settlement through the merger of existing settlements”
• Creation of a free-standing new settlement

The council document does not identify specific Green Belt sites for development but highlights an area running from Culverstone Green in the south of Gravesham up the A227 to Higham in the north as “a primary area of search”.
Council leader David Turner said: “With no Local Plan, the Green Belt could lose virtually all protection it has, allowing the local planning process to be sidestepped.
“Ideally, we would avoid building on Green Belt land. However, as part of this process, the council must look at all possible sites and rule them in or out.
“We are starting from the principle of brownfield land and other sites within the urban confines first but may need to seek additional land to meet our needs.
“When this consultation is complete, the council will draw up more detailed options and everyone will get the chance to comment again on those next year.”
The council intends to consult on a submission draft of its Local Plan in 2020, leading to submission, examination and adoption in 2021.
The consultation runs until June 20, 2018. If you would like to take part, visit bit.ly/2HDpjCF

Monday, April 30, 2018

• 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