Read the full reports from our district chairmen

In the Autumn/Winter edition of Kent Voice, we carried reports from our district and committee chairmen from around the county.
They were comprehensive and entailed a lot of work on their part, but space restrictions meant we couldn’t bring you them in their entirety, so here they are…

Ashford – Christine Drury
Ashford has a five-year housing land supply. That was the advice of the Local Plan inspectors at the end of June. In Ashford’s case it is six years as the borough council carries a 20 per cent buffer for non-delivery against previous high housing targets as a growth area. At more than 1,400 dwellings per year, the target is still high. Will developers build, and could they sell that many? The next hurdle will be when the government publishes the first housing delivery results in November. This is a new test in the revised National Planning Policy Framework published in July.
Three appeals by Gladman Developments Ltd were withdrawn at the time the inspectors’ advice was published, less than a week before the Brabourne Lees appeal was to be reconvened, before the Charing appeal was due to report and as Biddenden was in preparation. It was a relief to see those three appeals abandoned, but the much larger one in the countryside beyond Kennington remains a threat. None of these sites are in the Local Plan. Gladman’s predatory business model causes a great deal of anger and stress for communities and cost for councils.
Outline planning applications are being submitted for sites that are in the Plan.  The one dubbed Large Burton Farm will be difficult to absorb next to Kennington on the edge of Ashford unless it is very well designed and phased. Local engagement is proving difficult when so many people find it so wrong.
Where sites are smaller, they can be cumulatively disproportionate for villages. Rural Means Rural is campaigning strongly on precisely this point. The inspectors listened and the modifications requested reflect that they can only be effective if we are all vigilant in monitoring what is being proposed and whether it is in character in terms of its scale and design. Cumulative effect must also be considered.
CPRE Kent is advocating that the highly successful green corridors plan for urban Ashford be adapted for rural areas, too. It is needed because this Local Plan includes more development in and around the borough’s villages. In urban areas the corridor is the Stour riverbank and floodable areas alongside the river. It is a popular non-motorised route with commuters and children cycling to school, forming part of the Sustrans National Cycle Network (Route 18).
Charing and Hamstreet are two villages that appear to score well on sustainability criteria as they each have a railway station, school and doctors’ surgery, together with a modest high street. However, they both have sensitive drainage and run-off risks that are not being recognised.
Construction of junction 10A on the M20 is proceeding to plan, although it should have been built 14 years ago. The ‘shaving away’ of trees to make way for the bulldozers and pile-drivers was a visual shock, but planting and time will heal after the junction opens in the summer. The new junction will help realise more brownfield housing development on the old Ashford railway works.

Canterbury – Barrie Gore
Canterbury City Council has bought a former student block for conversion to social housing. It has also announced it will build more social housing elsewhere. So, although rather late, these are welcome steps to redress the imbalance between private and genuinely affordable housing. We don’t yet know if housing associations will be involved.
The council has applied for a judicial review of the decision by the Secretary of State for Housing, Communities and Local Government (James Brokenshire – how apt) to overrule the refusal of planning permission for housing at Strode Farm, Herne. We don’t yet have the grounds for the review but, as the site was allocated for housing in the Local Plan, we are intrigued, especially as the council has announced an AQMA [Air Quality Management Area] for Herne as other massive developments along the Thanet Way and at Sturry will cause serious traffic and air pollution problems in the village. We have supported the determined and excellent Herne and Broomfield Parish Council throughout. We are all disappointed at the minister’s decision and welcome the review.
The long-threatened application for an enormous development in the Kent Downs AONB at Highland Court Farm, Bridge, has now been lodged. It is for a large leisure complex for tourists and includes upmarket housing, proposed new grounds for Canterbury football and rugby clubs, plus tennis courts and other holiday facilities. There has been a growing trend to win support for unsuitable developments from sports and health organisations by offering them new facilities.   We, together with the Kent Downs joint advisory committee, the Barham Downs Action Group and many others, will be opposing the application. It is another glaring example of attacks by developers on valuable open spaces in the countryside. The government is doing nothing to stop this, leaving under-funded local authorities to cope as best they can.
There are increasing attempts by applicants to deface conservation areas in the city by applying for unsuitable advertising material and shop fronts despite the protection given, but sadly not always applied, by the Local Plan. Unfortunately, the councillor who was appointed Canterbury’s heritage champion wears two hats as he is also on the planning committee, when most of us believe he should only be involved in heritage issues and not be part of planning decisions.
Although years too late, the council is in the process of preparing a draft heritage strategy for public consultation. The consultation process has been good, but still no draft has appeared, so it seems we have little or no protection for our heritage assets even though we are a cathedral city with three World Heritage Sites.
Gradually the threat to public health from air pollution seem to be appearing in the council’s consciousness, although we still do not have enough monitors, sited where pollution and traffic jams are greatest, to provide technical information in everyday terms to residents, many of whom are subjected daily to diesel particulates and petrol fumes.
Particulate Matter 2.5 remains in the body for ever, unlike the larger particulates, which can eventually be discharged. Even the government now accepts that 40,000 deaths a year are caused, or contributed to, by traffic pollution. Why, then, isn’t a moratorium ordered to prevent large developments in already overcrowded and polluted areas? Contrast this with steps taken nationally to reduce road deaths, which are less than one-tenth of deaths attributable to pollution. Although there is, at last, some tinkering with travel methods, we need something more drastic than that.
On the subject of air pollution, two residents have issued a judicial review in respect of a 4,000-dwelling development in south Canterbury – the Mountfield Park site – most of which would be on high-quality agricultural land. The main ground is that the air would become even more polluted in the city, as well as within the development itself. There was a two-day hearing in the Court of Appeal and judgement has been reserved. Meanwhile, the development has been put on hold.   We and many others supported this review, but we wonder, with government emphasis on more and more houses, whether the court may be minded to allow the original decision to stand.
[Note: A judicial review is not a re-run of the merits of the original planning decision, but a challenge to the lawfulness of that decision]  

Dartford and Gravesham – Alex Hills
The first phase of the consultation on the Green Belt boundary review has ended and we are waiting on the response from Gravesham Borough Council. CPRE Kent was part of the Gravesham Rural Residents Group (GRRG), which ran a very effective campaign using social media, public meetings (the council had refused to hold any) and hard facts to galvanise support for the Green Belt. Special thanks to Richard Knox-Johnston for some brilliant speeches.
The complete lack of any thought to sustainability or air quality in the government’s housing target came up at all the public meetings. Kent’s health services, transport infrastructure, water supply, social care and much else are all struggling now – there is no way they can cope with the ridiculous housing targets the government is pushing.
The controlling Conservative group in Gravesham has been in a state of flux after the leader and deputy leader were rejected as candidates for May’s council elections. This has resulted in 10 councillors quitting the party, although not all were going to stand in May anyway. I have made clear that CPRE Kent and GRRG are non-political and thus neither organisation would comment on what was happening. Time will tell how this will affect the fight to protect the Green Belt.
There has been encouraging progress on improving NMU (non-motorised user) routes and establishing new ones in the area. There is a growing trend for dual-use NMU routes, which I have grave concerns over as many are not wide enough and there is a lack of understanding by many on how to behave on them:

• Dog-walkers, please keep your dogs on a short lead
• Walkers, please keep to one side
• Cyclists, please be aware pedestrians may not be able to hear you coming and may not be expecting you to be travelling so fast
• All users need to be aware that people with a range of disabilities use the routes

We need more journeys to be done via walking and cycling as this improves people’s physical and mental health, reduces congestion and cuts pollution. For this to happen, walking and cycling must be made safer.

Dover – Derek Wanstall
There are still discussions relating to Operation Stack, although a recent backlog of lorries parked along the left side of the road into Dover kept traffic moving smoothly. However, when lorries come from the Jubilee roundabout at Whitfield they can cause drivers annoyance when joining the entrance into the docks.
Port alterations are progressing and can now be viewed. Visiting cruise ships have been quite frequent, but it seems visitors do not stay in Dover, preferring destinations such as Leeds Castle, Canterbury Cathedral and London.
On August 29 a well-attended area meeting was held, with Farthingloe and Western Heights dominating the agenda, which I attended along with Christine Drury. Three residents from Western Heights also attended and brought some updated information on the land owned by China Gateway and the bridge over the moat on Military Hill, as well as details on a proposed open day. Attempts will be made to hold a meeting for residents in the Maxton area, close to Farthingloe.
Work at Connaught Barracks seems to be progressing at last, unlike at Eastry hospital, where developers seem to be still dragging their feet.
Developers have started putting in planning applications where property demolition is required to gain access to neighbouring land. However, some good news is that Greenlight Developers had an application for a care home and 48 properties turned down by Dover District Council due to highway issues. We await an appeal.
With so much development in the Deal area and with more approved, traffic jams have become more frequent at peak times, causing long queues towards Dover and on the A256 to Sandwich. Residents now need to leave 10-15 minutes earlier to get to work or appointments on time, with parking spaces in Deal being at a premium. This highlights how infrastructure must be considered alongside new developments.

Maidstone – Henny Shotter
Maidstone Borough Council has withdrawn £10,000 funding for the Kent Downs AONB but has allocated a similar figure for the creation of a new ‘Greensand’ AONB. Although it is desirable to protect the Greensand Ridge, such a move throws up the question as to where the next ‘lot of houses’ will go.
Councillor Patrick Garten (North Downs ward) wrote in his newsletter: “In order to deal with the increasing housing demand, members across the political spectrum expressed a preference for a garden village or town for achieving the housing need. The council should take an active role as master planner for new communities.”
I wonder whether these decisions by MBC are strategically connected and will have an impact on other districts.
The head of planning at MBC said during the inquiry into the last Local Plan that development in front of the AONB should not be a problem as “the whole of Maidstone is in front of the AONB”.
I am concerned the creation of a new AONB will undermine the status of the Kent Downs AONB. The Kent Downs are important not only because of their AONB status but because the downs aquifer stores, as far as I know, 75 per cent of our water supplies.
The immediate area in front of the AONB is not only a traffic corridor (A20/M20/ High Speed Rail Link), it also includes the line of springs that are the source of the Rivers Len and Stour.
Recent developments in Lenham are on the spring line and it seems that groundwater and surface water is joining the Upper Stour, which can lead to flooding elsewhere. The county council’s flood-management management team and the internal drainage board are both reportedly concerned.
Major development at the foot of the downs would increase traffic across the downs and could lead to urbanisation along these routes.
An example of such potential urbanisation is a planned large development in the AONB immediately north of the Kent Showground. It was raised at the Local Plan hearings in November 2016 but taken no further.
The site, which is partly brownfield, is still being heavily promoted. There was a presentation in July, where much support was shown alongside the objections.
It includes several thousand houses plus claimed benefits in road improvements, school space, open space and so on.

Medway – Hilary Newport
Publication of the next draft of the Medway Local Plan is expected in December, followed by a final stage of consultation prior to submission for examination in March. It remains to be seen whether Medway will maintain its commitment to delivering homes at Lodge Hill, a Site of Special Scientific Interest and home to one of the largest populations of nightingales in the UK.

Sevenoaks – Nigel Britten
My last report said “a technical exercise has indicated that the district needs 12,400 new dwellings over the next 20 years”. The government then introduced a new formula, adding almost 1,600 to that impossible figure and increasing the so-called ‘housing need’ to 13,960 over that period.
The draft Sevenoaks Local Plan says this is the number of dwellings for which the district must find room in an area that is 93 per cent Green Belt and two-thirds AONB.
Once all the brownfield sites have been redeveloped, including some in the Green Belt, the only place to build would be in the Green Belt. The Plan proposes 12 major ‘exceptional circumstances’ sites, from fewer than a hundred dwellings per site to 2,500, all requiring changes to the Green Belt boundary. Public opposition has been fierce.
The Local Plan consultation, including 19 policies and more than 100 development sites, has been the focus of the committee’s work. It is not for us to make the choices now facing the council; our job is to protect the countryside, not to choose between the unacceptable, so we have not supported any of the 12 sites for housing. National policy says clearly that Green Belt and AONB protection can override the requirement to meet the full ‘housing need’. We want the council to test that to the limit.

Shepway – Graham Horner
Otterpool Park Garden Town grinds through a design phase and we are promised a planning application by the end of the year. There are still no clear answers to questions of sustainability:

• Where will the water come from and where will it drain?
• How can the roads cope with 30,000 new residents?
• Where will all these people work?

Outline permission for 150 dwellings and a hotel at Princes Parade, Hythe, was granted by Folkestone & Hythe District Council’s planning and licencing committee in August. The plans include an ugly leisure centre on open ground that offers valuable unstructured recreational space and is vital to the setting of the Royal Military Canal.
We are supporting campaigners considering a legal challenge.A ‘listening exercise’ by Highways England to gather views on lorry parks didn’t tell us more than we already knew and probably didn’t tell HE officials more than they knew (or should have known three years ago).
The good news is that the prospect of a mega lorry park does seem to be receding and facilities for overnight parking, not just in Kent, seem to be higher up HE’s agenda.

Swale – Peter Blandon
Swale Borough Council is in the process of developing its next Local Plan. The idea seems to be the development of separate ‘garden villages’, rather than incremental development over a wide area – it is apparently better to really upset a relatively small number of people rather than slightly upset a large number.
The housing requirement is likely to be more than 1,000 dwelling per annum, and this raises issues of infrastructure. The report for the council from Peter Brett Associates contains ‘An Important Reminder for Developers and Landowners’. In a larger font than the rest of the report, it is stated:
“We can expect that each home built in Swale on strategic sites will be likely to need between £30,000-£50,000-worth of supporting infrastructure spend. In the absence of a master developer or similar structure, this is likely to be collected by either CIL [Community Infrastructure Levy] or S106 [agreement between local authority and developer with an obligation concerning use of the land or developer contribution towards infrastructure and facilities].
“Without this infrastructure spend, no planning permissions can be granted, meaning that there is no development opportunity.
“It is important to bear in mind that CIL and S106 are ultimately paid out of land values. This means that land with residential planning permission may be worth much less than landowners currently anticipate. It is critically important that this point is well understood by landowners, so that they do not have unrealistic expectations about the value of their land.
“Equally, developers should be careful to ensure that these costs are factored into their bids for land. The council will be unsympathetic to claims that development on greenfield sites is unviable.”
While we can support these sentiments, exactly how unsympathetic the council will be when the inevitable requests from developers come in asking to be relieved of requirements to provide a certain level of CIL funding, or to reduce the number of affordable/small houses in a development, remains to be seen.
Two applications for sites in the Local Plan are under consideration. A site at Teynham for 130 dwellings brought this response from the parish council:
“Teynham is identified in the current Local Plan as a ‘sustainable location for development for its good range of local services, facilities and rail link’. Having had our rail services halved, our medical surgery facilities halved, the loss of Sure Start children’s facilities, no tangible improvement in bus public transport and no evidence that schooling facilities are to be improved to meet the forthcoming influx of new residents, we question what is now left that is ‘sustainable’.”
At the same time, the council’s head of environmental protection is recommending refusal on air-quality grounds.
The plan for Cleve Hill solar farm is expected to be submitted to the Planning Inspectorate by the end of October. Swale Borough Council does not seem to have involved itself with the application.
A development in Newington High Street, an AQMA [Air Quality Management Area], has been completed. The original permission required non-opening front windows to reduce pollution and noise inside. An application in February to allow opening front windows was refused. The buildings have been completed and have opening front windows. The houses are now on sale.

Thanet – David Morrish
“August is that last flicker of fun and heat before everything fades and dies…” the  line from author Rasmenia Massoud was particularly apposite for my report after a glorious sun-kissed summer on Thanet’s gorgeous coastline.
But the clouds are gathering and, urged on by the government’s Chief Planner, Thanet District Council has lumbered into action by deciding to publish and be damned its latest daft [sic] Local Plan.
Thankfully, the council listened to common sense (and CPRE Thanet) and opted for a six-week final consultation stretching into October, thankfully, we hope, encapsulating September’s publication of population forecasts just to ensure there is a substantial basis for the likely initial challenge to the predicted household forecasts.
The consultation will also, most importantly and very belatedly, be the first official opportunity for the public to comment on the county council’s long-awaited transport study. Why has it not been published until now?
This complicated process appears to have been already predetermined, hence the planning application (a lovely case study of the county council acting as advocate, judge and jury in considering its own application) for the latest Thanet White Elephant: Thanet Parkway station.
Thanet CPRE has duly opposed this scheme despite its supporting documents and the expectation is a planning decision by November.
Our committee is still very keen, active and meeting monthly – it is hoped that in the run-up to the Local Plan Examination in Public we may attract more members as many do not appear enamoured with ‘local planning’ in Thanet.

Tonbridge and Malling – Mike Taylor
Tonbridge and Malling Borough Council’s Planning and Transportation Advisory Board is the body charged with drafting the Local Plan, and I am a member. On July 24 the PTAB met with the sole task of recommending the draft Local Plan to cabinet and full council in September. Thirteen members of the board were present, as were 18 non-member councillors and some 50 members of the public, one of whom videoed proceedings.
There was two and half hours of intense debate, with strong opposition to much of the Plan, culminating at 10pm with the chairman asking for agreement to recommend the Plan but, instead of the normal chorus of “Agreed”, there was a deathly hush. He then asked for a show of hands, which was all a bit confused, but resulted in the chairman declaring 5-5 with three abstentions. His casting vote carried the recommendation.
Many members voiced concerns about the vote but were assured it was correct.
However, analysis of the video showed one board member leaving before the vote. A month later, the council agreed there was a “miscount” and declared the recommendation refused. It then decided it didn’t matter anyway – the PTAB is only an “advisory board” – and so our vote would be noted but would not prevent the non-recommendation going to the cabinet and full council.
On September 12, the full council agreed the draft Local Plan with a 39-6 vote.
Democracy is alive and well at Tonbridge and Malling Borough Council…

Tunbridge Wells – Liz Akenhead
We have objected (mostly successfully) to several planning applications that have come forward on unallocated sites in the High Weald AONB. These sites are vulnerable to speculative applications for development because the borough council cannot demonstrate a five-year supply of housing land. We continue to await publication of the draft Local Plan, which now seems to be scheduled for early next year.
Until a new Local Plan is adopted, and perhaps even after that if the government keeps moving the goalposts, our countryside will remain vulnerable to speculative applications.
Rumours abound as to how much housing will be proposed for each settlement, though we understand parish councillors and neighbourhood plan steering groups have been given some indications confidentially. The council is reviewing the Green Belt and we fear a considerable amount of building in the Green Belt and AONB will be proposed.
A recent paper on park-and-ride, produced as part of the evidence base for the new Local Plan, seems to show that a new park-and-ride service will neither give value for money nor resolve the traffic problems in Tunbridge Wells, yet alarmingly it seems the council may still want to press ahead with the proposals, some of which will needlessly cover green fields with tarmac.

Environment – Graham Warren
The recurring theme for most of the summer (while keeping our fingers crossed for an end to the drought) was Brexit and what it could mean for the future management and protection of Kent’s increasingly vulnerable environment.
We learn that the roles played by the European Commission and the European Court of Justice – bodies that have powers to enforce compliance with environmental legislation – will, post-Brexit, be taken up in the UK by a new body, the Environmental Enforcement and Audit Office (EEAO), heralded by the government as a “world-leading body to protect the environment”.
Unfortunately, its remit will be confined to monitoring and advice only ─ a watchdog that will simply watch. A poor legacy, this, for a nation that was the first to put climate change on the UN agenda and the first G7 member to phase out coal-based power, last year generating more than half of our energy from renewable sources.
As if that wasn’t enough bad news, we now have government proposals to review the legislation controlling shale gas exploration and development, effectively moving planning control from local authorities to central government and denying local communities any means of making representation (a move CPRE Kent has challenged with a 175,000-signature petition).
This action reflects a determination by the government to force through the permitting of invasive development of fossil fuels, ignoring the implications for our commitment to the Paris Agreement in the increasingly urgent programme for climate-change control.
But now some good news and congratulations to Surrey CPRE for the victory at the Battle of Leith Hill ─ another shale-gas exploration site where Kent provided technical support in opposing permission. The oil company has been seen off and has withdrawn its application.

Historic Buildings – John Wotton
Kent Historic Buildings Committee was pleased to partner Kent School of Architecture again this year for the Gravett Award for Architectural Drawing, named in honour of Kenneth Gravett, an author on historic buildings in Kent and a former chairman of the committee. The judging panel was again chaired by Ptolemy Dean and the award was made to Jake Obichere.
The committee has participated in a campaign to save from demolition Hextable Heritage Centre, the former botany laboratory of Swanley Horticultural College, the first institution in England to admit women horticultural students. Swanley was taken over by Wye College after the Second World War and the botany laboratory is the only surviving college building.
The committee visited Queen Court at Ospringe, an outstanding Wealden hall house with fine barns and outbuildings, largely unmodernised and with much deferred maintenance required to the structure and fabric. The house is empty after the ending of an agricultural tenancy and it is possible that development will be proposed on the site. The committee will monitor the situation.

Monday, November 19, 2018

• 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