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Landscape Heritage?
By Rose Lister
In my last article I asked what you think of when someone mentions heritage. Have I opened your eyes to the idea that heritage covers more than just bricks and mortar? Now let me ask you, what about hills? What of the valleys and rivers that stand stretching and winding through our county? What of the farmlands that make us the Garden of England? Our landscape is something we all use and rarely consider to be an inheritance, a place of magnificence that holds the secrets of our past. Our landscape feeds us, clothes us and gives us shelter. It gives us the air we breathe. Do we really appreciate it?
In recent years our built heritage has been making waves in the planning system showing that what we created in ages past is precious. Don’t you think that the landscape this lies in deserves to make the same waves? Areas such as National Parks and Areas of Outstanding Natural Beauty have long been recognised and now the settings of historic buildings are also making their mark. In 2014 Barnwell Manor in Northamptonshire won an appeal case that affected the setting of a Grade I listed building. 2015 saw a home win for CPRE Kent when the Waterside Park application was quashed due to the developments negative effects on the setting of the Grade I listed Leeds Castle.
However, although landscape that was the main issue, it was the attachment to the heritage asset that made it worth saving. Surely the same curtesy should be extended to our landscape heritage?
Since 2014 CPRE Kent has been fighting a battle to save our landscape heritage. The Kent Downs Area of Outstanding Natural Beauty has been the subject of a skirmish between developers and defenders. The prospective development at Western Heights and Farthingloe is threatening our landscape heritage. Much of the AONB is carefully managed – it is home to much of Kent’s historic fruit farming industry, it thrives with ancient woodland, the landscape holds the stories of generations long gone, even some of the species that live there are endemic. As such this beautiful and versatile landscape has been threatened for the very reason it was designated. It is a beautiful place and people will pay a premium to live in it.
However, if we build in a place because we think it’s beautiful, does it remain so? We at CPRE Kent think not. Something as precious as our AONB cannot be enhanced by building six hundred homes in it. That is not to say that no development should be allowed, the villages that nestle within the protected landscape think very hard before making a commitment to small developments that enhance the area around them, the six hundred proposed would be an entirely new village on the outskirts of Dover that would harm its surroundings.
In important cases like these it is important to follow the law and government guidelines. Therefore the 2012 National Planning Policy Framework states that building within a protected area such as an AONB must fit certain criterion:
- Is the development in the public interest?
- Is there no other place to develop?
If (A) and (B) are met then, and only then, can you the development be approved; providing that:
- Any and all mitigation is put in place to protect the designated landscape.
In the case of Western Heights and Farthingloe only one of these conditions is met. The electoral pledges of the Conservative government to build three million houses by 2020 make any development that addresses the housing crisis a matter of public interest. Thus fulfilling point (A). Yet when it comes to point (B) there are at least a dozen other places within the Dover area that would fit a development that size without causing irreparable harm to the AONB. The issue of mitigation is then addressed figuratively. In short, the development doesn’t suggest nearly enough. In the words of Meatloaf, ‘two out of tree aint bad’, In this case they barely scrape 1.
It is therefore of utter amazement that this development has been allowed to go so far as a judicial review and now an appeal (by us) to the Court of Appeal. We will soon know the result and whether we have defended this stunning heritage landscape from desecration. For future updates on the case keep an eye on the CPRE Kent website.
- 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
