Thanet finally sees a Local Plan on the horizon... and an awful lot more housing

Thanet might be close to having a Local Plan.
A seemingly interminable saga (see here, here, here, here, here and here) appears to be nearing a conclusion, with the two inspectors examining the draft Local Plan informing Thanet District Council on March 23 that the document has an ‘appropriate basis’ to be adopted as long as a list of modifications is included.
There is also a requirement that the Plan be reviewed within six months of adoption.
The inspectors’ report has now to be considered by full council, with adoption anticipated by summer, depending in part on the Covid-19 lockdown.
The Plan, which covers the period to 2031, was submitted for examination on October 30, 2018, with public hearings held between April 2 and July 18 last year.
The Report and the recommended Main Modifications to make the Plan ‘sound’ can be viewed on the council’s website. Social-distancing restrictions mean no paper copies of the document are available for inspection at Thanet Gateway, but it can be viewed online.
One of the most contentious features of the draft Plan has been housing numbers and this makes provision for at least 17,140 new homes up to 2031.
Manston airport is to be safeguarded for airport-related uses, with future use and development at the site to be determined through early review of the Plan.
The recommended main modifications all concern matters discussed at the examination hearings.
After the hearings, the council prepared a schedule of the proposed main modifications and where necessary carried out a sustainability appraisal of them. The main modifications were subject to public consultation from December 11 last year to January 27, 2020.
After considering the representations made on the proposed main modifications, the inspectors have recommended that these be included.

In summary they
are:

• Introduce new Policy SP01a, which supports the principle of development in the urban area and designated villages
• Introduce new Policy SP01b, which requires the council to complete a review of the Plan within six months of adoption
• Modify the stepped housing requirement in Policy SP11
• Clarify which sites are allocated for residential development in the urban Area (Policy HO1) and the rural settlements (Policy HO11)
• Modify the development principles for strategic housing sites and include land at Shottendane Road as a strategic housing allocation (Policy SP18A)
• Amend Policies SP19 and SP20 to provide clarity regarding the type and size of dwellings and the thresholds for the provision of affordable housing
• Include a requirement in Policy HO22 to identify and allocate sites for gypsy and travelling communities as part of an update to the Plan
• Introduce a new policy (Policy SP05) concerning development at Manston airport
• Modify Policies SP02, SP03 and E01 to support new economic development within settlement boundaries, clarify how much land is allocated for employment uses and provide criteria to assess proposals for the reuse of employment land and buildings
• Modify Policy SP21 to support economic growth in rural areas
• Delete unjustified and undeliverable transport routes from Policy SP47
• Modify Policies SP22, SP25 and SP26 to provide effective criteria for development in Green Wedges, and for proposals likely to lead to increased recreational pressure on the Thanet Coast and Sandwich Bay SPA and Ramsar Site
• Modify the town-centre policies (SP06-SP10 and E04-E06) for clarity and effectiveness
• Support the extension of the Queen Elizabeth The Queen Mother Hospital through Policy SP37
• Clarify how new medical facilities will be provided at Westwood and where new primary and secondary schools will be located through changes to Policies SP38 and SP40
• Provide effective criteria to consider proposals for foster homes and childcare facilities, and the retention of family homes in Policies HO24 and HO26
• Delete Policy CM04 relating to the expansion of Minster cemetery
• Update Appendix B to reflect the latest position concerning site delivery

Other main modifications are also recommended to ensure that the Plan is justified, effective and consistent with national planning policy.
A striking feature is the proposed housing trajectory. The inspectors’ modification MM27 Table to Policy SP11 provides for the following average annual housing numbers:
2011/2012 – 2015/2016: 311
2016/2017 – 2020/2021: 600
2021/2022 – 2025/2026: 1,200
2026/2027 – 2030/2031: 1,317

The figure for 2011/2012 – 2015/2016 is based on actual completions averaged over the five-year period.
The modification requires a doubling of completions for the next-five year period 2016/2027 – 2020/2021. This has not been achieved in the first three years. 
For the years 2016/2017 – 2018/2019 only 993 dwellings were built. That averages just 331 per annum. Little more than that was achieved in the first five-year period.
So to average 600 dwellings per annum over the five-year period in the next two years, 2,007 dwellings will need to be built.
That is an annual average of 1,004 and three times that which has been achieved in the previous three years. Given the Covid-19 lockdown and the predicted slowdown in the global economy, it is highly unlikely that these levels will be achieved this year or next year. 
This means that in the last two periods more homes will need to be completed than required by the trajectory, suggesting an increase in housebuilding not seen here before and only in recent years experienced in growth areas such as Dartford.

• Read the 63-page inspectors’ report here

• See the recommended main modifications (to make the Plan sound) here

Wednesday, April 15, 2020

• 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