Word from our chairmen

In the Spring/Summer 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 new draft Local Plan will be examined by two inspectors between April and June and, with whatever amendments that result from their Examination in Public, is likely to become the adopted Local Plan before the end of 2018.
It will replace the old Local Plan approved in 2008, when Ashford was still designed as a Growth Area and had very high housing targets but with a compact strategy focusing development in and around the town of Ashford.
Since the NPPF came in in March 2012, the district has been under increasing pressure to accept less constrained development. Recently, when Ashford could not demonstrate a five-year housing land supply, many villages in the district were besieged with housing proposals not in the Plan and at an entirely unsympathetic urban scale.
The planning inquiries that follow are a huge diversion for the borough council and for CPRE, but at Brabourne and Charing CPRE has been there as a participant to fight alongside the council against this wrong development.
The engagement the committee has with the council and the clarity of CPRE’s campaigning owes a great deal to the work of Hilary Moorby so many years. We shall miss her very greatly.

Canterbury – Barrie Gore
Canterbury City Council has invited us to join its new District Heritage Forum, which has been tasked with producing a heritage strategy for public consultation.
Other amenity organisations (including our Historic Buildings Committee) have also been invited. The forum is chaired by Cllr Robert Thomas, who has been appointed Canterbury’s heritage champion.
We certainly need one, and the forum will hopefully alter planners’ perception of the pecking order for heritage.
In our view, that should be a prime, not secondary, consideration to economics. It is amazing to me that, since Canterbury’s senior conservation officer left the council, the issue of conservation has been so poorly served.
For example, the list of Locally Listed buildings has not been updated since 2012 and the council refuses our requests to list buildings on an ad hoc basis, as was the case. This means that local, undesignated, heritage assets have been at risk for six years.
Also, an independent volunteer Clean Air Action Group has been formed and, subject to formal approval by the council’s policy and resources committee, the director of transport has agreed to invite Professor Stephen Peckham from that group on to the council’s transport forum. Stephen has expertise and practical experience that is invaluable in connection with transport and air pollution.
We have commented on the proposed change of use of a lovely pub to residential, accompanied by three houses, a micro pub and some tourist “pods” all in the open countryside on unallocated land near the hamlet of Chartham Hatch (designated as such in the Local Plan).
There is an application for umpteen more houses, highways proposals and sundry development at Cockering Road, Canterbury. We are concerned that the cumulative effect of the Thanington changes is not being considered as the effect on already polluted Wincheap will be great. It seems Kent Highways still has concerns, but whether that will suffice to defer or improve the application remains to be seen.
We have been asking the council for many years to take account of the cumulative effects of the developments in and around Canterbury, without any response. However, recent news suggests such effects must form part of the planning process.
I must mention the quality of our committee, which puts in a great deal of hard work, with skill and expertise, and with valuable links with other amenity organisations, including the Canterbury Heritage Design Forum (independent to the council).
I am delighted Branch has contributed towards their funding as they operate on a shoestring.

Dartford and Gravesham – Alex Hills
Green Belt boundary review papers were due to go to the Gravesham Borough Council cabinet on February 26, with consultation due to start in April. Gravesham Rural Residents Group (of which CPRE is a member) have been gearing up for this campaign; the plan is to use social media extensively. We are confident we can reach at least 26,000 people directly.
GBC is looking to build 2,000 homes in the Green Belt, so it is going to be a big fight. All the area’s services are under massive strain, so sustainability should come up a lot in the consultation. We believe GBC should do much more to get the housing-number target reduced and increase housing density in the urban area.
Two test-case applications were due to go to the council’s regulatory board on March 7; one was for a two-bedroom house and the other for two two-bedroom bungalows.
Both are in an Istead Rise estate extension built in early 1970s; in soft landscape areas that are a community amenity asset; an integral design feature of the estate; and classed as part of the highway, which is something I had not come across before.
The cases are important as they should define what GBC means by “infill” development, how much weight GBC gives to the importance of soft landscape features and how much GBC values community amenity assets.
There are 18 such sites in Istead Rise alone, although most are not big enough to be built on. There were more than 170 objections after a campaign including social media, targeted leafleting and two meetings. A big thank-you to local residents Frank Booker, Terry Annable and Rachael Westlake, who worked so hard on the campaign.
Consultation on the Bean interchange started on February 26.
Consultation is under way on a new cycle route between the Cyclopark and Gravesend train station. Overall I support the scheme, but there are a few areas where I will be suggesting improvements: it is unnecessarily long for a commuter route and it crosses a busy road twice in a very short distance.
As CPRE Kent representative on the Gravesend and Dartford Cycling Forum, and its chairman, I have meetings coming up with the Bluewater community body and consultants working for EDC on developing new cycling routes. EDC is working on routes within the garden city and leisure routes out of it.
The forum has been pressing both EDC and Bluewater to look at where people want to travel to and make sure cycle routes are joined up.

Dover – Derek Wanstall
With the Supreme Court ruling on Farthingloe and Western Heights going in CPRE Kent’s favour just before Christmas, the year ended on a high. Many thanks to our legal team and those at CPRE Kent who worked so hard… well done!
There is the ongoing issue of the Lydden Hill race circuit and its proposed expansion, which can only bring more noise and traffic problems to the village, plus the site is in an AONB.
Residents’ tranquility and quality of life can only deteriorate if the expansion is approved.
What an excellent idea to have a war memorial on the Western Heights! It should encourage tourism. Across Europe there are several such memorials, one in particular looked after by village children to a very high standard.
Developers at Connaught Barracks and the Eastry hospital site are still dragging their heels with regard to any progress.
The massive development at Whitfield is taking shape and some infrastructure has been agreed.
The St James shopping area in Dover is nearing opening. This will improve the area; however, much work is needed in raising the environmental standard at Tower Hamlets and Buckland.
With developers putting in planning applications around the villages, parish councils are frequently endeavouring to retain their open spaces and village status.
Our MP has constantly made irresponsible comments in the local media regarding Farthingloe, claiming young people are being stopped from getting on the housing ladder.
CPRE Kent supports housing – but in the right places. At Farthingloe, very few, if any, of our younger generation could have afforded the proposed homes.
Perhaps our MP should place in the local paper the letter he wrote to the Secretary of State requesting that the Farthingloe development not be called in. If it had been, the people of Dover might have avoided the hefty costs of the subsequent court cases.
CPRE Dover committee meetings take place every two or three months from 10.30am to midday. If any parish councils would like to send representatives who are CPRE members, they would be welcome. I can be contacted on 01304 363610.

Maidstone – Gary Thomas
We are extremely disappointed at the dismissal of our attempt to get a judicial review of the inclusion in the Local Plan of industrial and commercial development at junction 8 of the M20, otherwise known as Woodcut Farm.
The review was not allowed to go forward on the basis that there were no significant procedural errors made by the examiner in approving the Local Plan. The planning issues were not seen as relevant in this context. This was despite the information given to the Examiner often being less than satisfactory. The key point was that he felt able to accept the borough’s statements and included this site in the Local Plan.
We regret that a planning application for a 13-house estate in the Conservation Area of Linton, which was not identified for development in the Local Plan, was approved. The site comprises a field that is half in the Conservation Area and the other half in the process of being included.
The case officer made a strong case against the development, but the planning committee took a different view based on grounds we find difficult to support. These were:
1. It would not harm the Conservation Area, although it was clearly contrary to the 1990 (Listed Buildings and Conservation Areas) Act
2. It would assist in getting a pedestrian crossing in the northern part of the village – already ruled out by the county council
3. It would be a windfall site. In our opinion this argument doesn’t make any sense: all land not identified in the Local Plan for develop
A very large house in the AONB on the site of a modest Edwardian dwelling (to be demolished) was approved in 2015 in Lenham. The design is for a massive house with very large windows that make use of solar gain. During daylight this area of glass sometimes reflects light like a mirror and at night allows much light to illuminate the otherwise dark escarpment. This application was approved and nothing can be done about it, but the applicant has now submitted an outside lighting scheme that includes 87 lamp positions, either on the house or its immediate surrounds. We have submitted objections.
A huge warehouse and packing shed in the countryside, not in the Local Plan but allowed anyway, is under construction in Linton and as damaging as we feared. The promised studies of traffic movements have not been carried out and the road improvements, including Linton crossroads, appear not to have been progressed.
A landowner has applied to build eight large barns in the AONB in Lenham, to which we have objected. A response has been submitted on our behalf.
Maidstone Borough Council is looking to introduce charges for the park-and-ride (currently free), while greatly increasing charges for parking in town. We object to these changes as they will deter people from outside the urban area visiting town and affect the elderly disproportionally.
Maidstone CPRE is looking to involve more people in monitoring planning applications and in preparing for the review of the Local Plan, on which the borough council is already working.

Medway – Hilary Newport
Medway Council’s cabinet met on March 6 to agree the publication of the draft Medway Local Plan Development Strategy, which is open for consultation until 11 May this year. This document sets out the options for the most sustainable strategy for managing Medway’s growth up to 2035.
These options include consideration of the government’s proposed new housing trajectory for Medway, which would see the already challenging housing targets escalate considerably. It also includes consideration of a new ‘rural town’ at Hoo or a return to the plans for development at Lodge Hill – despite its designation as a Site of Special Scientific Interest and an internationally important breeding site for nightingales. Difficult decisions will have to be made.
Plans for Lodge Hill continue to evolve. Earlier development proposals from Land Securities and, more recently, the Ministry of Defence, were withdrawn, with the site has been passed to Homes England, a government agency charged with delivering the country’s housing needs.

Sevenoaks – Nigel Britten
These are tense days for all who care about the Sevenoaks countryside.
A technical exercise has indicated the district needs 12,400 new dwellings over the next 20 years – almost four times the target of the previous period – and the question is where they can be built without covering our beautiful landscape with bricks and concrete. Last summer the district council consulted on the ‘issues and options’ for the next Local Plan, showing possible approaches to meeting housing demand. Brownfield land in the urban areas is always the first choice. Then one ‘option’ is to use previously developed Green Belt land. Another, and very contentious, would be using Green Belt land for large-scale housing development in “exceptional circumstances”. Examples would be 600 houses under the Which Way Westerham plan, 600 on the Tarmac site north of Sevenoaks, an 800-house ‘garden village’ on the former Broke Hill golf course at Halstead and several smaller sites around Edenbridge.
The draft Plan will be published in June and it will be keeping the Sevenoaks committee busy.

Shepway – Val Loseby
Shepway District Council has published A Charter for Otterpool Park Garden Town. It builds on the Development Principles for Otterpool Park published in the Expression of Interest submitted by SDC to the government in June 2016. The charter was published in draft in September and now incorporates revisions after public consultation and consideration by the council’s cabinet.
The Framework Masterplan for Otterpool Park is being worked on by council officers with consultants. We understand that plans have stalled due to some land being withheld by the landowner. We await the next stage of public consultation.
A councillor, residents and other interested parties, including CPRE Kent, have met Affinity Water officials to discuss their plans for providing water in an already water-stressed area. Aside from supply to the 12,500 dwellings planned for Otterpool Park, there are other major developments in the area. The meeting was informative and there are plans for another one this year.
Princes Parade, Hythe, is a planned development of 150 dwellings, a leisure centre and swimming pool next to the Royal Military Canal, which is a Scheduled Monument. Historic England has come out strongly against this development, citing the harm it will cause the RMC, which dates back to Napoleonic times.
The Shepway district committee has also objected to the development, which would mean the loss of an open space much used by the local community and wildlife. Vicky Ellis of CPRE Kent submitted an excellent critique of the environmental report submitted to SDC by its consultants, pointing out that the methodology was flawed and the data unreliable.
SDC has published the submission draft of the Places and Policies Local Plan, which will be submitted to a planning inspector at an Examination in Public. The district committee submitted comments on several sites, including Princes Parade, which is still in the Local Plan despite strong local opposition. The planning application for this site was not expected to be determined by the local authority until after the consultation.
The Kent Minerals & Waste LP 2013-2030 consultation concluded at the end of March. The district committee commented, particularly the already extensive Lydd quarry at Dengemarsh and Allen Banks, which is proposed to extend even further into the surrounding SSSI. We are objecting due to the loss of agricultural land as well as harm to the SSSI and have suggested there are alternatives for extracting gravel without leaving deep-water ponds that turn saline over time.

Swale – Peter Blandon
There was relief when Swale Borough Council adopted its Local Plan.  The feeling was that it would be possible to combat more easily speculative planning applications.
However, it seems such relief was misplaced. An EIA Screening Opinion has appeared for a development of 11,250 dwellings with new junctions on to the M2 and A2 to the south and east of Sittingbourne. The junctions are near Kent Science Park and the development would effectively engulf Bapchild and Rodmersham.
This ‘ticks all the boxes’ for SBC as it is keen on a southern relief road and development of the science park. Cynics might argue the houses are needed to pay for the roads that are needed to mitigate the effects of the housing… and so on.
The Inspector had only qualified support for the adopted Local Plan and required an early review. So Swale CPRE produced a study for consideration by SBC as part of its preparations for the next planning review.
It states: “This study is needed because the Inspector had concerns that the current adopted Plan might not be able to support sufficient homes over the Plan period. Emerging numbers suggest that Swale needs to provide more housing permissions – equivalent to around 35% more every year, on top of the number already in the plan.
“In our view the prudent approach would see Swale preparing to plan for around another 7,500 homes over the new Plan period to 2037/38 in addition to the number already identified through the current Plan.”
The report proposes a number of scenarios:

• Incremental growth on the periphery of existing settlemen
• Two new villages or one new town – a total of 10,000 houses –around Kent Science Park.
• An extension of Faversham with new villages or a town to the south, containing 5,000 to 10,000 dwellings.
• Building around Upchurch and/or Newington

The emphasis seems to be on ‘garden villages/towns’ as it states early in the report that “pressing sequential development into and up against existing communities drives high densities and low quality”.
At the meeting of the Local Development Panel in Swale it was decided “the scope of options identified in the report are appropriate for initial stakeholder engagement workshops be agreed”.

Thanet – David Morrish
Thanet has a CPRE district committee again, with the first meeting held on November 27.
As a relative newcomer to Thanet, I have been bemused by the complex planning situation here, where the district council was one of 15 local authorities without an up-to-date Local Plan. In January many councillors revolted against officers’ proposals for 17,000 houses unaccompanied by new employment; the proposals were thrown out by the full council.
Sajid Javid, Secretary of State for Communities and Local Government, subsequently stepped in to speed up production of the Plan, with chief planner Steve Quartermain and team being sent to the isle to decide whether it will be taken of Thanet council control. Mr Quartermain will report back to Mr Javid, who will make a final decision on formal intervention. The council has seen a change of leader and change in administration.
Plans for a Development Consent Order for a ‘freight-only’ airport on the Manston Airport site went to public consultation. After thumbing through the 3,000 pages of documentation, the CPRE Thanet committee concluded the proposals were generally aligned with Thanet’s 2006 Local Plan. We await central government’s response to the GDO proposal and the supply of further information as part of the next stage of consultation.
One peculiarity of the Local Plan policy was that TDC officers appeared to have prepared their own £80 million transport plan for a circular updated country-lane system not supported by Kent Highways, which is itself awaiting a final result from the Local Plan process before committing scarce resources.
Anxious eyes look fearfully to the reopening of ‘Operation Super Stack’ if and when Transport Minister Chris Grayling has to deal with the local consequences of us leaving Europe without a plan!
Our working committee started work in earnest in January and February, considering the potential work ahead on an ill-prepared  Draft Local Plan.
We have resolved to press the incoming TDC administration to adopt the principle of the Community Infrastructure Level as a way to secure speedier delivery and sounder infrastructure provision and payment.
I would like to thank my 11 new colleagues for stepping forward to help secure a better approach to planning in Thanet. Also, thanks to my new colleagues on the CPRE Kent chairmen’s group and to the trustees for welcoming me aboard.

Tonbridge and Malling – Mike Taylor
Tonbridge and Malling Borough Council has deferred publication of its Draft Local Plan for the third time, still assembling the evidence base. Our next district meeting will discuss the issues detailed below. Because the district has large tracts of Green Belt that have been ‘temporarily’ released for mineral extraction, we have constant battles to stop the local planning authority treating this land as ‘brownfield’. We will engage in the Local Plan process, not just on specific site issues but also to ensure it contains unequivocal rules and not the vague suggestions contained in the Local Development Framework. Some of this engagement shift towards the end of the final consultation, if not completely deferred until it can be put directly to the inspector.
While TMBC keeps a register of employment sites, it pays as much notice to this as it does to air quality and Green Belt protection. It is too simple for developers to advertise in such a way as to make sites unviable for employment use and getting them released for housing.
Contaminated land: on sites with known contamination there must be a clear and unequivocal distinction between remediation and construction, with a conditioned requirement for validation that the site is clean and safe before permission for construction is given. Many of the problems we have experienced are caused by builders treading on the heels of the remediation team, or, worse, a site where the two processes are mixed. The simple process of earth-moving can mix high levels of contamination with clean soil, creating the statistical illusion that the site is now clean.
On sites of known contamination, the developer must provide a comprehensive contamination survey prior to application, and any permission conditioned to ensure the developer cannot later claim lack of viability due to ‘new-found’ contamination, particularly if that loss of viability results in any loss of affordable housing or other benefit.
While validation of the remediation is principally the responsibility of the developer, that does not let the planning authority off the hook entirely. There must be a clear oversight of the process, incorporating occasional independent assessment of developers’ sampling, random sampling of the site by officers and rigorous checking of the developer’s processes to ensure they are complying with the remediation plan, and random site visits to ensure the paper complies with what is allegedly happening on the ground.
We must have assurance that the sites approved are safe for residents.
Landfill sites: TMBC has allowed two housing developments on general waste landfill sites (176 and 43 houses), but in recent weeks Joco Pit, where 48 houses were built in the 1970s, has produced an alarming increase in landfill gas, including methane. TMBC largely dismisses concerns that the same will happen at the new sites, claiming houses have gas-proof membranes and that methane coming up in gardens will simply disperse in the air.
This stance neglects two important facts:
1. Methane is a greenhouse gas of an order of magnitude worse than CO2
2. Methane is generated when oxygen ingress allows buried organic matter to rot. That putrescence will leave a void, leading to subsidence.
The fact that these sites are deep-piled and use vertical band drains to manage drainage and release methane also provides new pathways for oxygen to reach buried organic matter.

Tunbridge Wells – Liz Akenhead
Tunbridge Wells Borough Council is continuing to work on producing a new Local Plan. We had expected to see the first draft of this published by now, but the latest information we have is that the Preferred Local Plan will be consulted on this summer, with pre-submission consultation from November 2018 to January 2019 and Examination in Public from April to June 2019, leading to adoption in October 2019.
The two Calls for Sites conducted by the council have resulted in a range of submissions, including some for ‘garden villages’ of about 6,000 houses. Many of these are in the Green Belt and/or the Area of Outstanding Natural Beauty. The council tells us it is engaged in analysing sites and options for the development strategy; we feel this is a better way forward than choosing a strategy without first analysing available sites.
The borough’s Brownfield Register shows room on Previously Developed Land for some 900 homes (a little more than one year’s worth of the housing requirement for the new Local Plan period), which appears to leave a very large housing requirement to be filled via greenfield sites.
If as little as possible of our precious countryside is to be lost, it is essential that where new housing goes on greenfield sites, its density should be increased from the relatively low densities currently being achieved.
High-density housing does not have to be poor or unattractive: Cranbrook’s historic centre, for example, is widely recognised as a beautiful and desirable place to live yet has a density of 70 or more dwellings per hectare (DPH).
The recently approved site at Mascalls Farm, Paddock Wood, will have a density of less than 12 DPH and the major site at Hawkenbury Farm on the outskirts of Tunbridge Wells less than 21 DPH.
The borough’s first Neighbourhood Development Plan (NDP), for Hawkhurst, passed its referendum on February 8 and will soon be adopted by the borough council. Other parishes are at early stages of producing NDPs.
We need more committee members. If you want to help protect our environment and can spare a few hours a month to help monitor planning matters in your parish, please contact me, Elizabeth Akenhead, on 01892 723920 or at liz@akenhead.plus.com

Environment – Graham Warren
A winter of below-average rainfall and higher-than-average temperatures has left Kent with water table levels in the North Downs (our major public supply resource) still relatively low, and a warm dry spring could see groundwater levels falling back into the ‘red’.
The water companies have produced their public consultation documents for the next 5- to 25-year Water Resource Management Plans, this time with an emphasis on more flexible strategies to meet the increasingly fragile balance of supply and demand, and the challenges of climate change, population growth and pressures on the environment. And who knows what, post-Brexit?
2018 looks like being the year that produces the first UK land-based shale gas/oil operation, most probably in northern England but Surrey and Sussex are also looking to us to support their opposition to the granting of licences for fracking operations. Expert opinion is that the UK already has twice the hydrocarbon reserves it will ever need, assuming we stay within the 1° global temperature increment adopted under the Paris Agreement.
It is a good time, we think, to make clear our support for local community initiatives for small-scale solar and windpower generation schemes, so long, of course, that due regard is also given to the equally important challenge to conserve reserves of productive agricultural land.

Historic Buildings – John Wotton
The Kent Historic Buildings Committee has supported the Tunbridge Wells committee in relation to the continuing deterioration in the condition of the partially demolished, listed Blue Boys Inn near Matfield.
We have advised residents in Nonington about a possible residential development that would involve the demolition of a 19th-century cottage of historic interest.
We have been approached by residents in the Ightham Court area who have made an application for judicial review of a decision by Historic England in 2015 to de-list part of a historic park and garden.
We have endorsed a donation of £250 by the branch to Canterbury Heritage Forum.
We have objected to a major proposed development in the setting of the Royal Military Canal at Hythe, as has Historic England.
We have recently been consulted about plans for redeveloping the Hextable Heritage Centre and the proposed demolition of a toll-gate cottage at Brenchley.
We will again sponsor the Gravett Award for Architectural Drawing in 2018 in partnership with the Kent School of Architecture. We next meet on Friday, April 20, and continue to seek additional members to cover Maidstone and Ashford districts.

Wednesday, April 25

• 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