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LTC Local Refinement Consultation – simply not good enough from National Highways
Lower Thames Crossing: CPRE Kent believes there needs to be a further and final round of consultation
CPRE Kent has responded to the Lower Thames Crossing Local Refinement Consultation.
As with the previous National Highways consultation, our main takeaway has been yet further frustration with the lack of detail provided, as well as the piecemeal fashion in which it is being provided.
There remain gaping holes in the information being provided; the documentation is very hard to navigate; key bits of information are buried in other documents from previous rounds of consultation; and key questions remain unanswered. There are also extremely important surveys such as air pollution surveys still yet to be done.
This is simply not good enough.
Sleek presentations, online videos and glossy brochures are one thing; however, it is the substance of the consultation that matters.
It is for these reasons we strongly believe there needs to be a further and final round of consultation which brings together and updates all elements of the evidence base. This should be undertaken as a full statutory and be presented in cohesive and transparent manner.
While this will never overcome our in-principle objection to the LTC project, this is the minimum that must be done to allow the people of Kent to fully understand the environmental, social and economic impacts of the LTC scheme.
- CPRE Kent’s detailed comments on the consultation can be found here
- For more on the Lower Thames Crossing, see here
Wednesday, June 22, 2022
- 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
