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Overwhelmed by the development onslaught? This piece sheds a little light on what's going on...
Many of us are aware that our natural environment is threatened like never before. We experience it through the constant grind of cement-mixers and bulldozers, but sometimes the bureaucratic process is not so clear. Here planning expert and CPRE supporter Michael Hand casts some light on what is driving the current onslaught.
We are under relentless and unparalleled pressure to accommodate significant growth, in particular to meet the demand for new housing.
However, many developments are concentrating on three- and four-bedroom executive homes and not enough ‘affordable’ housing is being delivered.
Much of the South East is experiencing pressure for this unprecedented growth in housing, driven by the ‘housing crisis’ and associated government policy to increase the delivery of new homes by setting higher targets for local authorities to meet.
As guardians of the countryside, local members of CPRE Kent have a key responsibility in upholding the core values of the organisation and defending the beauty of the county against poor-quality and inappropriate new developments.
There are 13 Local Planning Authorities (LPAs) in Kent and in many Local Plans have not been adopted.
This void in the planning framework has resulted in opportunistic and speculative applications (by companies such as Gladman Developments Ltd) seeking to exploit councils’ inability to demonstrate a five-year supply of housing land.
The effect, already adverse, has been exacerbated by a recent change by the government to the National Planning Policy Framework (NPPF) through publication of a revised version on February 19.
Key changes include an amendment to specify that 2014-based population projections will provide the demographic baseline for the standard method of calculating local housing need rather than the lower 2016-based household projections, which could be used as a reason to justify lower housing need.
This clarification followed the publication of a major revision of the NPPF on July 24, 2018, which, inter alia, clarified the definition of ‘deliverable’.
To be considered deliverable, sites for housing should be available now, offer a suitable location for development now and be achievable with a realistic prospect that housing will be delivered on the site within five years.
As a consequence, it may be harder for LPAs to provide a five-year housing-land supply, as for example Local Plan allocations cannot generally be used in the calculation, except where “clear evidence that housing completions will begin on site within five years” exists.
The 2018 revision also introduced the Housing Delivery Test for LPAs, a failure in delivery of which kick-starts the “presumption in favour of sustainable development”.
The first round of Housing Delivery Test results was published in February this year, with 108 councils falling short and 86 required to add more land for housing to Local Plans as a result.
For a number of authorities, this confirms the need to apply a 20 per cent buffer to their housing requirement, with potential ramifications for their ability to demonstrate a five-year housing land supply.
A result of these changes is that speculative applications will still be common practice in the future – and that is why CPRE Kent needs to keep building a strong presence to monitor and respond to inappropriate development proposals.
Wednesday, May 15, 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
