Lodge Hill decision called in

A public inquiry is to be held over plans to build more than 5,000 homes at Lodge Hill on the Hoo Peninsula after the proposals were called in by the government.

Ministers said they would decide on the plans for the Chattenden site following requests from residents, Natural England, the RSPB and Kent MPs. The RSPB has said the land is home to 84 pairs of breeding nightingales.

Medway Council approved the plans for Lodge Hill in 2013. Proposals put forward for the former military site, owned by the Ministry of Defence, include housing, four schools, a healthcare centre and shops.

This ex-MOD site had been identified in the last draft of the Medway Local Plan as a significant strategic location for around one-third of all Medway’s identified housing needs to 2026.  While this site was technically designated as brownfield in 2007, it has more recently been identified as one of the most important breeding sites for nightingales in the country; as a result of this, Natural England recognised its significance in 2013 by designating it a Site of Special Scientific Interest (SSSI)*.

This important designation was one of the significant reasons that the Inspector charged with testing the Medway Local Plan in 2013 advised that the Plan was sufficiently flawed that it should be abandoned; she wrote “… I am not convinced that the social and economic benefits … would outweigh the harm to a site of national importance.”  She went on to state that the modifications that would be needed to prevent damage to the SSSI were “…so significant as to amount to the Plan being re-written”.

Let’s hope that the Secretary of State will give this decision the scrutiny it deserves. The National Planning Policy Framework makes it clear that in exceptional circumstances, the need for development might outweigh the importance of an SSSI or other important habitat.  In this case, the independent Inspector made it equally clear that it does not.  Let’s further hope that our National Planning Policy Framework lives up to its name this time.

*Natural England describes SSSIs thus: “…the country’s very best wildlife and/or geological sites. SSSIs include some of the most spectacular and beautiful habitats: wetlands teeming with wading birds, winding chalk rivers, flower-rich meadows, windswept shingle beaches and remote upland peat bogs.”

• 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