Read the reports from our district chairmen... in full!

In the Spring/Summer 2019 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

• The Ashford Local Plan was adopted by the council on February 21. Time for a brief sigh of relief as it secures Ashford’s planning decision powers so long as the delivery rate can be maintained. On the Housing Delivery Test results finally published by the government in February, Ashford is one of the 34 per cent of local authorities that have gained a small cushion by coming off the 20 per cent buffer ‘naughty step’ to the standard 5 per cent buffer. The government issued further guidance in February on how delivery should be calculated: outline permission on smaller sites can count “unless there is evidence to the contrary”. Ashford has quite a lot of larger sites, so how these are delivered will determine whether the borough can keep its five-year housing land supply status. Work on the next Local Plan is likely to start this year!
• There is a complex set of sites on the green fields immediately to the south and east of Ashford town. Delivering those coherently with enough cycle paths and bus services to make them more transport climate friendly is the current challenge, alongside good design guidance and management of the flood risks. If we have to lose 200 acres of agricultural land, let it not be to bad development. CPRE Ashford put in a full initial comment and is involved in the masterplanning workshops. Safeguarding the villages, countryside and dark-sky area further south is one of our objectives. We hope to put in a full comment and also engage on the other large sites to the north of the town. As these are outline applications, it may be difficult to get as strong commitments to good design and green space structure as necessary.
• The Local Plan has some difficult challenges in the rural part of the borough, facing a much larger amount of development than it is practical to assimilate quickly in the villages. There are all the usual problems of sewerage capacity, drainage (now requiring SuDs), transport and parking as villages have entirely inadequate buses. Trains only meet part of the need, and only in those with stations.
• If we have the capacity, we will encourage more to work on Neighbourhood Plans. The Secretary of State says he is committed to them and now that Ashford has an up-to-date Local Plan they are unlikely to be overridden. So far, Ashford has two, Wye and Pluckley, but several are getting close.
• Mersham, Aldington and neighbouring villages are challenged by the squeeze of an expanding Ashford to the west and the threat of Otterpool garden town to the east. Two local councils, two MPs and a busy motorway between them and the AONB to the north make for tough challenges. CPRE Ashford is doing all it can to ensure that, as all this development progresses, the countryside is not forgotten and communities have a voice. We are working closely with the Rural Means Rural action group, so we can do more.
• And finally… ‘brownfield first’ is becoming a reality as the council puts a lot of its money and delivery priority into the regeneration of Ashford town. The residential, office, college and cultural development is finally happening after 20 years. CPRE Ashford celebrated this in March with its AGM at the new town-centre Picturehouse cinema. There is a long way to go, but it’s a start.

Canterbury – Barrie Gore

• The city’s heritage remains under attack. This time it is the section of the River Stour forming part of the historic setting of our World Heritage Site: the long-distance view of the city from Tonford and Stour Meadows. The Canterbury Conservation Appraisal identifies this as one of nine important views of the city, stating that the city’s landscape setting is part of its character and also that it is important visually and for its biodiversity. The city council has applied to build a large section of Wincheap park-and-ride on the bank of the Stour opposite the popular Great Stour Way on the other side. The council owns much of Wincheap Industrial Estate, so objectors feel strongly it should be using part of this unlovely commercial area for the park-and-ride. Sadly, the application was poorly advertised and the statutory notices were posted in locations that were primarily motorised rather than pedestrianised. None of the notices appeared on Great Stour Way. Consequently, almost all objectors learnt about the application by word of mouth. We have persuaded the council to extend the time for comments and to repost notices, hopefully in better locations. From the way in which our city’s heritage has been devalued, one would not believe we have a heritage champion at the city council.

 Dartford and Gravesham – Alex Hills

• The threat to the Green Belt in Gravesham is still there, but nothing will happen until after the May elections, during which it will very much be an issue. What the government is telling Gravesham council it must build is at odds with its Green Belt policy. Hopefully, the new administration will sit down with CPRE Kent to work out how defendable the Green Belt really is after the election.
• The Bean interchange upgrade is out to consultation. It appears Highways England has not been given the budget to do the work properly, while it has not listened to local residents or the parish council. The HE officials and thus the consultants working for them were not allowed to look at the impact on the strategic road network. This could explain the inclusion of a new eastbound slip road that will increase congestion on the A2. CPRE Kent remains committed to helping protect residents’ quality of life from this terrible plan. This project proves that Kent needs a sustainable countywide transport plan. The only good thing that can be said about the project is that walking and cycling routes have been improved. In addition to these improvements, Atkins Global has been given the task of spending the designated funding money for NMU (non-motorised user) routes in the area. As chairman of the local cycling forum, I arranged a productive meeting with the company in February about the design concept routes – if we only get half of them built, it will make a big difference to walking and cycling safety in the area. The route concepts were due to be put forward for feasibility studies at the end of March.
• CPRE Kent has been offered a stand at the Gravesend Rotary Club charity bike ride on Sunday, May 12, to promote active travel and sustainable transport. The event has three distance options: 15, 30 and 45 miles. All routes are well marshalled and refreshment stops provided. Commuter cyclists and leisure cyclists have very different requirements; however, they can cross over given the right encouragement. Cycling in a group is a lot safer and a good way of meeting like-minded people, also helping to build riders’ confidence. Commuter cyclists can be encouraged to use their bikes for leisure if there are safe routes in the right place. Having shorter beginners’ rides in the area is something that should be encouraged. Too often in transport consultations the questions is asked: “Where do you walk and cycle?” when the question that should be asked is “Where would you LIKE to walk and cycle?”. Pushing this point hard is now starting to deliver positive results locally.
• The KenEx tramline (which will be cycling-friendly) is still progressing well, if far too slowly for my liking. Rather than spending money on roads that will increase congestion, it should be investing more in active travel plans like the tramline and NMU routes.

Dover – Derek Wanstall

• With the Local Plan being reviewed, Dover District Council has organised a consultation on a green infrastructure strategy. This is very much welcomed. It also states it will operate alongside the Local Plan. Hopefully, it will be adhered to.
• As expected, the development proposal for Farthingloe and Western Heights has re-emerged, with CGI submitting “updated application documents” prior to redetermination by DDC. The plan seems little changed. However, with the Home Office placing the nearby immigration centre up for sale for redevelopment, there is a need to review policy for the whole area.
• With alternatives to Operation Stack still being considered, proposed widening of the A2 from Lydden to Whitfield Hill a constant theme, Lydden Hill racing circuit still causing issues and Dover immigration centre up for redevelopment, there will be much to discuss.

Maidstone – Henny Shotter

• Maidstone Borough Council has just begun its Review of the Local Plan for 2022 with a new ‘call for sites’. The recent relatively quiet time is coming to an end. A meeting was held with the director of regeneration and place and the strategic planning manager on February 6, when they confirmed that they think the government’s requirement for new housing in the borough will increase from 882 to some 1,200 per annum. How the consequent infrastructure needs will be tackled was less than clear. So much for the Garden of England.
• We objected on design grounds to a planning application for a development of eight dwellings in the AONB. The application was to convert a basic structure of corrugated barns from the 1970s and ’80s. Not much was done to reflect the vernacular in the area. This application is a follow-up to an earlier one that established development rights. With the changes to permitted development rights that came into force last year, the government took a further step to undermine Local Plan policies. Dispersed development in the countryside, which we had thought was a thing of the past, is back. There will be negative consequences for landscape and ecology, but it will also limit the ability of the agricultural sector to adapt to changes in farming.
• To end on a positive note, an appeal for the development of eight very large barns in the AONB that would have served as a warehouse for hay harvested from all over the county was turned down by the inspector.

Medway – Hilary Newport

• Publication of the next draft of the Medway Local Plan had been expected in December, but this has been delayed by at least six months. The local authority says the document cannot be completed until it learns the outcome of its bid for £170 million from the Housing Infrastructure Fund. This is anticipated in May and it is hoped the draft Local Plan will go out for public consultation in June or July.
• The hugely contentious plan to build homes at Lodge Hill has taken another twist with Homes England submitting revised plans for 500 new properties, rather than the 2,000 proposed previously. The whole sorry saga of this site began in 2014, when Medway Council approved a Land Securities scheme for 5,000 homes there – a decision that led to the inspector examining the Medway Local Plan in 2013 advising it was sufficiently flawed for it to be abandoned. The Chattenden Woods and Lodge Hill SSSI hosts some 85 pairs of nightingales, about 1 per cent of the UK population. The most recent application claims the revised scheme “will avoid direct Special Scientific Interest impacts on the Lodge Hill site”.
• Plans to build 450 homes at Gibraltar Farm in the Capstone Valley have re-emerged, with a fresh outline application submitted to Medway Council that includes two new access routes off Ham Lane. The local authority had refused proposals to develop the site, but two years ago the Communities Secretary overturned that decision, saying the benefits of the development outweighed the disadvantages of losing farmland.

Sevenoaks – Nigel Britten

• We are nearing the final stage of the new Local Plan process. Consultation on the Submission Version closed in February and we await a date for the examination, probably in the autumn. Much has changed since the first draft, in particular the whittling down of proposed Green Belt sites. What has not changed is the basis of the standard method to calculate housing need, in spite of the latest census data indicating in our case a considerable reduction in the 20-year projection. Data from 2016 would have justified a reduction in housing need from 13,960 to something nearer 10,000. Sevenoaks District Council has settled for a proposed Plan target of about 10,600 houses. As might be expected, promoters of ‘exceptional circumstances’ Green Belt sites who lost out in earlier rounds, such as Quinn Estates (800 units) and Squerryes (600 units, a bypass and landfill site), are known to be gearing up for a counter-attack at the examination. The call for sites was left open until last year, attracting three late proposals from Savills and adding a possible 750 units.
• As well as continuing to oppose these major developments in the Green Belt, with support from Julie and Paul in the CPRE Kent office we will focus at the examination on challenging the treatment of Green Belt agricultural development as previously developed land, contrary to the NPPF definition, thus allowing 360 houses to be built where there should not be any. Top of our list is the council’s identification of land at Pedham Place (at present a golf course) as a “broad location for growth” to be brought forward later in the Plan period as a site for 2,500 houses in the Green Belt and Kent Downs AONB.
• As a footnote, it has been encouraging to see some lengthy, detailed and strong submissions from the Kent Downs AONB Unit on sites such as Pedham Place and Fort Halstead. Inspector please note!

Shepway – Graham Horner

• Attention has been focused on the deluge of documents that arrived on the council’s website as the Regulation 19 consultation on the hastily prepared Core Strategy Review. This document, if found ‘sound’, will legitimise Otterpool Park garden town, which has attracted vocal local opposition. The plans for Otterpool are, in essence, to fill up all the available space in Folkestone & Hythe district that is not in the AONB or on Romney Marsh with housing – more than 10,000 homes. In the face of central government housing targets, it is difficult to argue against the idea in principle, but the council is kidding itself about how quickly the thing will be built. It appears to be assuming an insatiable demand for (un-‘affordable’) new homes in east Kent and infinite capacity of housebuilders to construct them. Our prime concern is that things will proceed a lot more slowly than anticipated, leaving the new ‘garden settlement’ as just another housing estate under construction for years, without supporting infrastructure and dragging on long enough for everyone to forget the lofty ideals of sustainability and high quality set out in the plan. The planning application for Otterpool has been submitted but not yet made public. We look forward to seeing the 10,000 pages it is reported to comprise.
• Princes Parade was approved by the council’s planning committee in August, but the consent has not yet been issued. The proposal will cause significant harm to the setting of the Royal Military Canal and destroy an urban green space unnecessarily. Campaigners are planning a legal challenge, which we support, but we fear the most that will come of it is delay rather than cancellation as the council is the landowner.
• The proposed holiday village in the Kent Downs AONB at Densole, which the council approved against officers’ advice, and approved again after a successful legal challenge, has been stalled by a second JR application. The council’s determination to try again and again to get the outcome it wants does not bode well for the Princes Parade campaign.

Swale – Peter Blandon

• Until recently, Swale’s housing land supply met the five-year target and so there was a defence against speculative applications for housebuilding. However, the government’s publication on February 19 of the new Housing Delivery Test found that the council’s land supply, as now assessed, is only 4.6 years. Swale Borough Council is now required to apply a 20 per cent buffer to its housing targets. This will influence a development under consideration in Wises Lane, Borden, for 675 houses. We objected to this on the grounds that it extended beyond the allocation agreed in the Local Plan, but that argument will now be set aside. The application looks set to be accepted, with officers having received delegated powers to negotiate S106 agreements. One condition is £583,200 as contribution to the local NHS. A recent report showed that Swale has the highest number of patients per GP in the country: 3,342 patients per doctor.
• The council is considering four ‘garden community’ proposals. Quinn Estates is pushing Kent Science Park and a new junction on the M2. Another proposal by Crabtree and Crabtree would see 2,500 new homes spreading from the A249, engulfing Bobbing and leaving, if the proposal map is to be trusted, about 50 yards between the new estates and the eastern end of Newington. The Duchy of Cornwall proposes to fill in the space between the M2 and A2 east of Faversham. A total of 2,500 homes is included in the plan, as well as proposals to ‘tame’ the A2. The final contribution, and the only one that really creates a stand-alone village, is south of the M2 in a pocket of non-AONB land. It runs along both sides of the A251 and would engulf the hamlet of North Street but otherwise is all on agricultural land. It is promoted by Gladman and would be between 1,500 and 10,000 dwellings in size. The council website states: “these submissions are currently being independently assessed. We will then decide whether any new communities should be shortlisted as one of the options to be considered by the next Local Plan.” Despite the fact that the idea of garden communities has not been formally approved or consulted upon, four job advertisements have appeared, all of which mention the garden communities projects. For example, one states: “This post offers a unique opportunity to progress and lead on the garden communities policy and masterplanning as well as having a direct involvement with progressing associated planning applications.” All four jobs are full-time and permanent.
• The scale of the proposed developments is causing fears not just about loss of countryside but also air quality. The Wises Lane application at Borden seems to cover this by the provision of charging points for electric vehicles. However, electric vehicles do not solve the problems caused by small particulate matter, PM2.5s in particular. These are mostly generated by tyres, brake linings and road erosion and do not depend on the types of car being driven. At recent focus meeting on AQMA5 [Air Quality Management Area 5], on the A2 at Greenstreet/Teynham, it was suggested that Swale council does not intend to invest any time or financial or physical resources in developing the evidence base for PM2.5_, ignoring the evidence of ‘harm’ being brought to its attention by central government last year and by the World Health Organisation (WHO).
• Finally, as reported last time, a development in Newington High Street, an AQMA area, is now being lived in. The original permission required non-opening front windows to reduce pollution and noise inside. An application in February last year to allow opening front windows was refused on air quality grounds, but an appeal has been submitted. The buildings have opening front windows, which, when I passed them on a recent warm day, were open.

Thanet – David Morrish

• Two inspectors from the Planning Inspectorate began examination of Thanet’s Local Plan in April; this process will end in May. Another, separate, quartet of inspectors are grappling with 5,000-plus pages of evidence relating to Manston airport for which public hearings started in March – a conclusion is expected in July. Never, as far as we are aware, will the two teams of inspectors meet formally, and by the middle of this year two different ministers – Communities Secretary James Brokenshire and Chris Grayling, Secretary of State for Transport – will be given the two separate reports upon which to make their own individual decisions. Manston is the first aviation proposal to be examined under the new infrastructure regulations.
• The Local Plan inquiry is taking place under 2012 NPPF guidelines, rather than the current NPPF, and the debate on housing numbers should be of national interest, with Thanet last year registering as the second-worst achiever of housing targets.
• There are serious concerns about the lack of an Infrastructure Delivery Plan; the county council has identified a £2 billion shortfall on the estimated £4b that is required in east Kent.
• The Transport Plan has not so far recognised the Margate/Ramsgate Road as the most dangerous in the country and there seems to be an indifference to public transport by bus. We hope the Planning Inspectorate may understand the shenanigans behind the efficacy of the Transport Plan and we look forward to the outcome of an inquiry into a transport strategy kept under wraps for years and not formally approved by the county council as highways authority.
• In the meantime, democracy has reared its lively head as the Thanet council planning committee unanimously rejected officer recommendations to refuse a 120-bed hotel next to Dreamland and gave its approval.

Tonbridge and Malling – Mike Taylor

• Our biggest issue is the Local Plan. We are in an awkward position as we believe it is unsound, largely due to the 3,000 houses planned for Borough Green Gardens to the north of Borough Green, across still-working sandpits and landfill sites. It is awkward because if this scheme is rejected by the inspectors, which it should be due to such considerations as Green Belt and AONB, traffic and air pollution, contamination and mineral plan sterilisation, it throws a huge extra housing burden on to the remainder of Tonbridge & Malling, with the added problem that should the Plan be declared unsound, the rest of the borough will have the extra 23 per cent housing as well, despite the Plan being lodged within the January deadline.
• It is worth noting that the council has ample sites deemed suitable and available, and on non-Green Belt land, to have completed its Plan without invading Green Belt.
• We have learnt that the appointed planning inspectors have written to the council demanding more evidence – evidence that should have helped form the Plan but was still being collected. The council had until March 29 to provide this and update its website with the Regulation 19 responses and résumé of those responses.

Tunbridge Wells – Liz Akenhead

• Our annual meeting will be held at 8pm on Monday, September 23, in the small hall at Bidborough village hall. This is an opportunity to come and meet your local committee, discuss local issues (especially the draft Local Plan, which will be in its final week of Regulation 18 public consultation) and enjoy some cheese and a glass of wine. Please put the date in your diary now. For catering purposes, it would be helpful if you could let me know if you are planning to attend: email elizabeth@akenhead.co.uk or phone 01233 714540.
• The current timetable for the production of Tunbridge Wells Borough Council’s new Local Plan, which will include land allocations to meet its Objectively Assessed Housing Need (OAN) as defined by the government and its economic and other development needs, is:

1. Late May 2019: draft Local Plan first published when it enters the borough council’s committee cycle (look out for it on the Planning and Transportation Cabinet Advisory Committee’s agenda)
2. August 5-September 27, 2019: public consultation (Regulation 18) on the draft Local Plan
3. Spring 2020: public consultation on the (Regulation 19) pre-submission Local Plan
4. Summer 2020: submission of the draft to the Secretary of State
5. Autumn 2020: formal Examination in Public of the draft Plan (ie public inquiry stage)
6. Spring 2021: adoption of the new Plan

Some developers are jumping the gun and making planning applications in advance of publication of the new Local Plan, relying on the fact that the council does not have an up-to-date Local Plan and cannot show it has sufficient allocations to meet its OAN. We are concerned the council will be under pressure to approve many of these, even though they are on Green Belt or within the High Weald AONB. Meanwhile, as Tunbridge Wells has met only 88 per cent of its Housing Delivery Test (net homes delivered over the three-year period to 2017-18 divided by housing need in those three years), it is required to produce an action plan in line with national planning guidance to assess the causes of under-delivery and address how to increase delivery.

Environment – Graham Warren

• Concerning the proposed Cleve Hill solar farm, CPRE Kent has registered as an Interested Party with respect to the implications for the loss of productive agricultural land.
• A draft of proposed guidelines has been prepared for use by districts in responding to planning inquiries relating to water resource and supply management.
• CPRE Kent has been continuing technical support for Sussex and Surrey offices in making representation against exploration and development in The Weald and downs.
• Air pollution is now a high-profile issue, as reflected in the government’s Clean Air Strategy. There is continuing concern about the ineffective monitoring of diesel particulates, with no indication of any decline in urban areas or the wider environment.

Historic Buildings – John Wotton

• Attempts were made, supported by the Kent Historic Buildings Committee, to have Heritage Hextable Centre, the former botany laboratory of Swanley Horticultural College, listed by Historic England. Those efforts were not successful, but the local authority is now consulting on options for development of the site, some of which would preserve the building intact.
• Committee members noticed plans were afoot to demolish Mount House, Teynham, an attractive and unmodernised early 19th-century house, unlisted but in the local conservation area. At very short notice, an energetic campaign was mounted to save this building from destruction. The local authority, with whom committee members were in close liaison, issued a building protection notice pending its application to have the building listed by Historic England. Sadly, just before the notice was served, some of the interior fixtures and fittings were destroyed.
• The committee made its second visit of the year, this time to Wickens Court, near Charing, a fine listed hall house with a fascinating history, courtesy of owners Tim and Corrie Bain Smith.
• We look forward to partnering Kent School of Architecture for a third year of the Gravett Award for Architectural Drawing.

Transport – Gary Thomas

• A major concern was the attempt by RiverOak Strategic Partnership to reopen Manston airport as a freight-handling terminal, having submitted an application for a Development Consent Order. CPRE Kent put in a statement of our position, questioning the viability of the operation, the contribution towards climate change from additional emissions and the effect on local air quality. We will be attending the inquiry.
• A paper had previously been put in giving our objections to the proposal for the Lower Thames Crossing. We also discussed our concerns over parts of the proposed scheme, including some of the interchanges and slip roads.
• We looked at some of the potential lorry parks being considered by Highways England to replace Operation Stack, attending some of the public meetings set up by local groups.
• Further points considered were the attempt to promote modal shift towards more walking and cycling, particularly in Maidstone, air quality and rail issues.

Wednesday, May 1, 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