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The funny thing about planning…
There are a number of draft local plans flying around Kent at the moment, and coming directly after the Canterbury District consultation, we now have Swale Borough Councils stab at setting the agenda for the next 20 years!
This has led to an interesting situation in which our Senior Planner, Brian Lloyd, has been able to make quite direct comparisons to the plan making processes that councils have gone through. He was kind enough to point out one of the inconsistencies to me this morning…
In their draft Local Plan, Canterbury District Council set an incredibly aspirational housing target of 15,600 houses during the plan period, which they intend to deliver at a rate of 780 dwellings per annum. This is a rate which, even during the boom years of housing, was never sustained for more than the odd year at a time here and there. However, they are looking to commit themselves to delivering this number every single year over a continuous 20 year period. There are significant dangers with taking this stance, as we have recently seen in Dover with the Western Heights and Farthingloe development. 
On the other hand, Swale Borough Council has decided to do things very differently. Where Canterbury argued that they must have a high target to meet the ‘objectively assessed need’ in full, Swale take the view that they need to be realistic in meeting housing needs and what the market can deliver. Because they have never been able to deliver such a high level of housing over the last 20yrs they argue that they cannot commit themselves to fully meeting all of the needs at this time. They state that:
“A key consideration is the deliverability of development, both in terms of viability of development in Swale and the capacity of the housing and development markets to deliver sufficient growth at a sustained rate year on year over the whole plan period. However, previous records suggest that housing delivery at the upper end of the range of objectively assessed needs (almost 900 dwellings per annum) has only been achieved twice within the last 30 years and represents a substantial increase over previous supply rates. It is therefore entirely untested over a sustained period for Swale and would place significant risk upon a strategy expecting to delivering this scale of growth.”
This realistic ability to deliver is actually quite a crucial point in the preparation of a draft local plan, and it is fascinating to see two District Councils which have chosen to approach the same issue in such different styles. The big danger is that if Canterbury is allowed the undeliverably high target and then fails in its duty to meet the 5 year land supply as required by the NPPF, a myriad of damaging and unplanned developments may be allowed to emerge in the same way that the Western Heights and Farthingloe development proposal was allowed to. This strikes me as totally contrary to everything a local plan is supposed to do. A situation of unplanned planning like this could lead to destructive developments on greenfield or designated land.
So, the lesson that Canterbury City Council need to learn is that deliverability isn’t just a catchy buzzword; it is what plans genuinely need to be. Without Canterbury being able to deliver their land supply, the District could come in for significant planning challenges in the future.
- 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.
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