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Shepway Places and Policies Plan
We have today submitted our response to the Shepway District Council consultation on its Places and Policies Plan, which follows the adoption of the Core Strategy in September 2013 setting out the general development strategy for the district until 2026.
One of the purposes of the plan is to identify sites to help meet the housing target of 8,750 new homes. The council says that sites for 3,355 new homes need to be provided in the plan. We dispute this and think that sites for under 900 new homes need to be identified, because the council has not given regard to existing planning permissions and sites already identified.
We have also raised concern about the way in which the council is proposing to spread the development between the towns and villages in the district.
CPRE Kent Senior Planner Brian Lloyd said: “We agree with the council that most new development should go to Folkestone, the district’s principal town, particularly on brownfield land. We also accept that there are opportunities elsewhere. However, we do not agree with the top-down way that the council is proposing to impose housing on towns and villages. We think that the council needs to proactively engage with local communities to find out what they think is an appropriate amount of development for them to take and where it should go. Such bottom-up planning is the essence of localism.”
A particular issue that the council asked for views on is potential development at junction 11 of the M20 Motorway. We consider this location as unacceptable and unsustainable because development would be located in the open countryside completely unrelated to and detached from any existing settlement. It would also involve the loss of precious agricultural land. We would rather see development at junction 13 of the motorway, where opportunities involving brownfield land are available.
We have also asked for a number of additional points to be addressed in the plan, including a commitment to producing a local list of heritage assets and protection of the district’s tranquillity and dark skies.
Mr Lloyd added: “Shepway is a unique part of Kent with a rich historic and natural environment that needs to be safeguarded and protected. The plan needs to provide a strong set of policies to ensure this. Pioneering work by CPRE nationally has shown that the Romney Marsh area is one of the most undisturbed and tranquil parts of Kent and this needs to be recognised in the plan and preserved.”
To view the consultation response click here.
March 11th 2015
- 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
