Massive increase in housebuilding: a developing tragedy for the Tunbridge Wells countryside

Tunbridge Wells Borough Council is in the process of completing its Local Plan, a key part of which is meeting a housing target in line with government methodology. This will mean a huge increase in housebuilding.
Under the new formula imposed by the government, the borough will be required to build 13,500 dwellings by 2036 more than double the number required under the previous Core Strategy.
Many housing developments have already been permitted on valuable Area of Outstanding Natural Beauty (AONB) and Green Belt land, such as at Brick Kiln Farm, Cranbrook, resulting in the loss of part of one of the finest remaining medieval landscapes in Europe. 
The proposed new ‘garden village’ (or new town) at Capel has already been announced, but this is the tip of the iceberg: smaller developments will happen across our rural areas.

A chance to protect the AONB and Green Belt missed
The planning system allows TWBC to protect the Green Belt, but in the case of Capel it appears it has chosen not to do so. This is despite the council’s Green Belt Study identifying “release” of this broad area from the Green Belt as causing a very high level of harm to the Green Belt (Tunbridge Wells Green Belt Study Stage 2, Land Use Consultants, 2017).
Paragraph 11b and Footnote 6 of the National Planning Policy Framework (NPPF) 2019 provide an exception to the requirement to meet housing ‘needs’ where the application of policies in the NPPF protecting Green Belt, AONB, irreplaceable habitats, heritage assets and areas at risk of flooding provide a strong reason for restricting development.
Some 70 per cent of the borough is designated as AONB and 22 per cent as Green Belt, while Flood Zone 3 covers almost 7 per cent. This compares with some 25 per cent of England that is National Park or AONB, and 12.5 per cent of England that is Green Belt.

Land lost based on incorrect housing need forecasts 
There is a prevailing false assumption that simply building more homes, of any kind, will bring down prices. Councils are placed under ever-increasing pressure to meet unrealisable housing targets, compelled to release more land for development and grant more planning permissions, even while many sites (such as the brownfield cinema site in Tunbridge Wells) that already have permission are not built out.
Last year, the final report of Sir Oliver Letwin’s review of build-out rates found that the largest housebuilders were consistently delivering expensive homogenous homes only as fast as the open market could absorb them without lowering prices.
This business model deliberately and explicitly fails to result in the reduction in house prices assumed by those who advocate unconstrained market housebuilding as a solution to the affordability crisis.
It does not and cannot deliver the kind of homes that communities need; rather, it will continue to cover the countryside in poor-quality, piecemeal development.
Worse still, because the ‘standard method’ for estimating local housing need is based on the relationship between house prices and incomes, building more expensive homes, especially in rural areas, leads to an increase in the apparent demand for housing calculated using this method and the cycle of unaffordable speculative housebuilding continues.
The most recent figures from the Office for National Statistics on housing affordability in England and Wales show worsening levels of affordability over a five-year period across most of the country, despite the consistent weakening of the planning system.
At present, the planning system actively reinforces market trends. The standardised method for calculating ‘objectively assessed need’ for housing in each local planning authority area, which takes household growth projections as a baseline and adjusts them according to market signals, concentrates growth and investment in areas that are already economically buoyant and have overheated housing markets.
In the long run, this simply stokes more demand, further inflating rents and house prices, straining local services and exacerbating the oppositional nature of the planning process. Moreover, it further unbalances the national economy.
Government planning policy, as set out in the revised and updated 2019 National Planning Policy Framework (NPPF), prioritises driving up the overall quantum of homes delivered over other considerations, including tenure mix.
It also holds local authorities to account for things outside their control, such as the failure of the volume housebuilders to build out sites quickly.
The introduction of the Housing Delivery Test (recently failed by 108 authorities) places councils under such pressure to deliver more homes that it is difficult for them to reject proposals for inappropriate developments, including those that do not comply with local affordable housing policies.
Moreover, many applications that initially propose to meet local affordable housing requirements are later renegotiated by developers on the grounds of viability.
CPRE’s 2018 research with Shelter found that rural sites where a viability assessment was used saw a 48 per cent drop in the number of affordable homes delivered.
CPRE’s report on the State of the Green Belt 2018 demonstrated that building on the Green Belt was not solving the affordable housing crisis and would not do so.
Last year, 72 per cent of homes built on greenfield land within the Green Belt were unaffordable by the government’s own definition.
Of the 460,000 homes that were planned at the time of the report to be built on land released from the Green Belt (a figure that doesn’t include the 4,500 additional houses now planned for Capel and Paddock Wood), the percentage of unaffordable homes would increase to 78 per cent.
Local authorities with Green Belt land have enough brownfield land for more than 720,000 homes, the report found, much of which was in areas with a high need for housing and existing infrastructure.

Land lost due to low-density housebuilding
TWBC may do its best to put homes on ‘brownfield’ sites, and on areas outside the Green Belt or AONB, but the target is so high that many houses will have to be on Green Belt or AONB land.
An important way to reduce the amount of land required is to maximise the density of each development.
There are two reasons this is difficult in practice. The first is that it is more profitable for developers to build big houses with plenty of land. Secondly, neighbours, faced with a planning application, often ask for the number of homes to be built on a site to be reduced, minimising the impact.
We all need to realise the result of that: another piece of land will need to be sacrificed to take the houses not built here.
The Campaign to Protect Rural England and TWBC both recognise 30 homes per hectare as a fair target for new developments.
Many of the planning applications received are for 15-20 homes per hectare. This means that up to twice as much land is needed for the same number of homes.
Somewhere else? No, your village will have to provide some of the land.  Future generations will ask why we sacrificed land in this way – land that might still be green.
There is another reason density is important. The borough desperately needs more affordable housing. Many parish councils have heard from residents that their children are being priced out of the area, and the supply of new affordable homes in the villages is way below the need. Low density simply means more expensive housing.
Higher-density housing does not need to be ugly. Some of the most desirable properties in our area are terraced cottages on village streets: the high-density housing of the past. There are clusters of homes in converted buildings around old farmyards that use land very efficiently. Even in modern developments a village atmosphere can be created with terraces, while maisonettes and other three-storey developments can be an attractive part of the development.
Higher-density development makes public transport more viable.
Some sites are not suitable for higher-density housing. The answer in most cases is not to accept the low density but to leave the land green.
Over the planning period, the amount of land sacrificed by low-density development could be up to 1,000 hectares – 1,400 football pitches.
We suggest that an opportunity cost should be applied to proposals for low- density development: the land to be sacrificed in the future. A five-hectare plot built at 15 to the hectare has sacrificed 2.5 hectares of land that might still be green.
Meanwhile, despite clear government guidance that “where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site” (NPPF para 123), TWBC has been granting planning permission on many sites at low densities.
For example, on a partially brownfield site in the Green Belt at Five Oak Green the borough council is applying to grant itself permission for three four-bedroom and two five-bedroom market houses on a half-hectare plot, a rate of a mere 10 dwellings per hectare, with no affordable housing (19/01586/OUT Land West Of Sychem Place Five Oak Green).
Future generations will ask why we both sacrificed land in this way – including some of our most precious landscapes – and failed to build the homes our young people need.

Monday, July 22, 2019

• 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