01795 534542
Central government in Whitehall sets the housing targets and requires that the local planning authority delivers then within the National Planning Policy Framework. The Ministry of Housing, Communities and Local Government polices the targets through the Planning Inspectorate. Swale is currently developing a Local Plan within the constraints and demands of central government policy and Whitehall's idea of how many houses are needed. Swale has to demonstrate that it has both an adequate supply of land for housing development and that the houses, for which it has given planning consent, are being built. It has to meet volume and delivery targets. Developers secure planning consent on sites, but they will only build when they can sell at prices which enable them to achieve the return they seek. Meeting delivery targets is an additional challenge.
If Swale is judged to be failing to meet either its land supply or completions targets, the developers can appeal and are in a strong position to win. The Planning Inspectors are not neutral arbiters; they are the enforcers of central government policy. Faversham's experience at Perry Court was a result of not having an adequate supply of land in the local plan. Swale had minimal influence over the Perry Court development because of the high risk of losing at appeal with substantial costs awarded against it.
The next local plan now being developed by Swale is required by central government to deliver 9,880 houses over 15 years in addition to 13,981 allocated in Bearing Fruits (the previous plan) and a 5% buffer. In the Local Plan Panel on 30th July Swale councillors will determine the proportion of housing to be allocated to the four parts of Swale. In and around Faversham sites for 6,000 houses have been put forward for development
We have some concerns about the lack of planning detail in the Vision and Development Growth Options paper going to the Local Plan Panel on July 30th. The decisions made by the Local Plan Panel and subsequently by the Cabinet and Council will profoundly affect everyone who lives and works in Swale.
Viability. What is the viability test being applied? What evidence is there that viability is greater in the east? How does viability around Faversham compare with viability south and east of Sittingbourne?
Infrastructure. Given the substantial investment in a new town centre for Sittingbourne is additional housing not needed to ensure that Sittingbourne thrives? Would not additional housing in the west enhance the vitality and viability of Sittingbourne town centre? We expected to see more detailed treatment of infrastructure in the discussion of the options.
Employment. TheVision and Development Growth Options paper appears only to be addressing housing allocations.
Inconsistency. The paper recognises Option B "would result in the dilution of the separation of settlements and undermine the individual identity of local communities, particularly surrounding Faversham." This is not mentioned in Options C or D where the impact would be still greater.
The assessment of Option D’s cites further development as a con “significant impacts on the character and setting of Faversham town.” The commentary on Option C cites development as assisting “in enhancing the vitality and viability of Faversham town centre.”
Whilst Local Plan Panel members have reviewed a whole series of papers over previous months, there has been very limited public engagement. With only one week between publication and decision about the distribution of additional housing, there has been inadequate time for members to consult or for the electorate to engage.
Windfall sites are sites not specifically identified in the development plan. Developers are keen to build in and around Faversham as the market supports higher prices in this part of Swale. Faversham is very likely to receive more than 30% of the applications for windfall houses over the plan period, given the buoyant market demand for housing. The provision of such a high windfall figure, it was 8.6% in Bearing Fruits, significantly increases the vulnerability of Faversham to housing developers. If delivery falls behind schedule, developers will take the opportunity to put in more windfall sites for development.
The Five Options going to the Local Plan Panel on July 30th
Option A is our preferred option. Swale and Faversham are unable just to say no to further housing if we do the developers will win on appeal, and it is likely that central government would remove what remains of local control over development.
Option B As is highlighted in the paper going to the Local Plan Panel Option B “would result in the dilution of the separation of settlements and undermine the individual identity of local communities, particularly surrounding Faversham. Option C would even further damage Faversham.
Option C would mean Faversham accepting a further 3,500 houses upt to 3,000 more as windfall. That would be 6,500 houses in addition to the 2,200 allocated under Bearing Fruits. A total over the two plan periods of 8,700. That is roughly equal to the number of houses in Faversham now. Faversham would double in size over the next 15 years.
Option D would require Faversham to take a further 1,000 homes taking the total to 9,700 more than doubling the size of the town over the next 15 years.
Option E would require significant greenfield rural development including the North Street development and is clearly unacceptable, the impact of that development on Faversham and traffic on A251 would be very damaging to the town.
Truly affordable housing
The paper going to the Local Plan Panel presents a set of broad principles, the first of which is "to provide for homes and jobs that are best suited to meet identified local needs." The Faversham Community Land Trust secured funding to have a Faversham Housing Needs Assessment undertaken by a specialist consultancy. The survey will enable the "identified local needs" to be taken into account in both the Swale Local Plan and the Faversham Neighbourhood Plan. The results will be available in mid-August. We know that the response rate, 14%, is high by comparison with experience elsewhere.
In early July Kent County Council published a 100-page dossier detailing the "acute" shortage of "genuinely" affordable housing in the county. KCC wants central government to give local authorities more control to develop truly affordable housing and KCC is seeking to change the government's "arbitrary" definition of affordable housing to reflect affordability based on income rather than local market priorities. The Faversham Society wants to see more truly affordable housing in Faversham to enable the children of Faversham residents to continue to live and bring up their children in the town. Extended families able to trace their history in Faversham back several generations make a significant contribution to the cultural heritage of our town, and the Faversham Society does not want to see this lost.
The Society has had a working group working on the assessment of the individual sites proposed for development in and around Faversham. In early August these will be published on our website and we shall be inviting members to contribute additional information and comments on the sites which have been put forward for development.
Later in the year having received feedback from our members on each of the sites put forward by developers, we shall consider our recommendations for which sites should be permitted for development through the Faversham Neighbourhood Plan and the Swale Local Plan.
Our preference is Option A. Central government requires that we take some more housing. Option A presents the most equitable distribution across Swale, with 30% windfall across the district we would still almost certainly taking a large part of the additional 3,000 homes.
Ordnance Wharf Flood Lane Faversham Kent ME13 7DY
Ref. No: 20/502408/FULL | Received: Thu 04 Jun 2020 | Validated: Tue 30 Jun 2020 | Status: Awaiting decision
Erection of a part three storey, part two storey building comprising of 5no. dwellings and an office and training workshop facility, and a three storey building comprising of a sailing clubroom, bar and cafe and 2no. dwellings, including 14 No. parking/sailing dinghy storage spaces and creation of a public access to the southeast end of the Wharf.
The application can be downloaded here
To comment:
Planning guidelines for developers:
Facing up to the transport issues
Over the last two years, members of the Faversham Society have observed with increasing concern the proposals for road layout and traffic management submitted by developers in their planning applications for residential developments in the area, and their likely impact on the level of road traffic congestion, noise and pollution. Many of these have been approved by the County Council as the highway authority responsible for roads in the affected area. At its meeting on 20 November, the Society’s Board endorsed the following recommendations drafted by a team drawn from the Faversham Future Forum for consideration by the County Council.
| 1 | Vehicular traffic generated by a new development should not erode the environment, threaten people’s safety, or worsen congestion. Since small traffic increases can have a disproportionate effect on a congested network, the impact should be assessed not in isolation but in conjunction with other schemes approved or under consideration.
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Relevant to 'The value of good design', Section 1.6 Movements and Connections, and ‘Creating the Design’, Section 2.1.2: Movement Appraisal. |
| 2 | To prevent 'enclaves' of isolated housing, the layout should incorporate road and footway connections to neighbouring developments, and allow for connections to future developments around the perimeter.
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‘Creating the Design’, Section 2. 2: Generating the layout |
| 3 | By means of a comprehensive, joined-up network incorporating routes for buses, pedestrians and cyclists, the development should allow and indeed encourage residents to use modes of travel other than the car. The network should provide safe crossings not only within the perimeter but across potential barriers around the periphery such as busy traffic routes and rail lines.
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‘Creating the Design’, Section 2.3: Designing for movement |
| 4 | Residential roads should be configured with a design speed of 20 mph. Compliance should be encouraged with imaginative design rather than mandatory signs and road markings.
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‘Creating the Design’, Section 2. 2: Generating the layout |
| 5 | Developers should assess the impact of the traffic generated by the proposed development on the levels of exhaust pollution and other particulate emissions over the wider network, and adopt measures for mitigating any negative effects. No development should be permitted to add to pollution on the wider network in places where existing levels are at or above the safe limits recognised by the World Health Organisation and the European Union. | ‘Making It Happen’, Section on Sustainable Solutions |
Faversham Society Board of Trustees, 28 November 2018
The government has published a new National Planning Policy Framework.
The Campaign for the Preservation of Rural England (CPRE) has published research on affordable housing:
60,000 houses being planned for land that will be released from the Green Belt, while the percentage of ‘affordable’ homes built continues to fall
The Green Belt remains under severe pressure, despite government commitments to its protection, according to a new report from the Campaign to Protect Rural England (CPRE).
CPRE’s annual State of the Green Belt report [1] highlights that there are currently 460,000 homes being planned to be built on land that will soon be released from the Green Belt [2]. Moving Green Belt boundaries when reviewing local plans makes it easier for local authorities to release land for housing, but is only supposed to take place under ‘exceptional circumstances’. This strategic shrinking of the Green Belt, as a way of getting around its protected status, is as harmful as building on the Green Belt itself.
The report also demonstrates that building on the Green Belt is not solving the affordable housing crisis, and will not do so. Last year 72% of homes built on greenfield land within the Green Belt were unaffordable by the government’s definition [3].
Of the 460,000 homes that are planned to be built on land that will be released from the Green Belt, the percentage of unaffordable homes will increase to 78%.
CPRE warns that this release of land looks set to continue, as one-third of local authorities with Green Belt land will find themselves with an increase in housing targets, due to a new method for calculating housing demand. The London (Metropolitan) Green Belt will be the biggest casualty [4].
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Swale Borough Council has published an early consultation document intended to inform the next Local Plan. Called "Looking Ahead", the document asks some key questions about the issues facing Swale to the year 2038. Please read more details below as to how to take part in this using our online portal.
We have also published a quick questionnaire in order to help us establish future priorities. This is also available to complete on the online portal. You do not need to register to take part in this.
If responding to our consultations, you will be asked to provide personal information at various points. Data Protection Legislation governs the way we collect and use the personal information you provide to us. You have specific legal rights in relation to that information and the Council has specific legal responsibilities. Please read carefully the notice that will be provided when you respond to the "Looking Ahead" consultation online. If you choose not to respond online, it can either be downloaded via the link below or as a ‘hard’ copy collected at Council offices or libraries. Where we have requested permission in the notice, please indicate by putting an ‘X’ in the relevant box. We will not be able to process your comments without the completed notice.
For most of our Local Plan consultations we use an online Consultation Portal, which has the following advantages:
You can read documents and consultation comments without the need to register. To provide any comments on a current consultation, you need to register before using our consultation portal.
You can also view our consultation documents at the Swale Borough Council Offices and libraries during these locations’ normal opening times:
Written representations on documents should be made either:
Paper versions of the form can be completed electronically (on screen) or completed by hand and returned:
If you have any questions please call us on 01795 417118.
All comments must be received by the date specified on the event detailed above.
Swale Borough Council engaged Peter Brett Associates to provide a starting point for developing a longer-term vision for how Swale might deal with choices about the type and location of housing growth.
None of the current represents an agreed political position or
policy in Swale. The views presented are those of the consultant
team only.
This study was commissioned for two reasons
Choices for housing growth suggests scenarios which could accommodate 15,000 new houses in Swale. Faversham emerges as one of the likely options for very substantial house building.
It provides the context for the Future Faversham meeting on March 8th
Application No:16/508602/OUT
Revised Details Land at Preston Fields, Salters Lane, Faversham, Kent, ME13 8YD
The Faversham Society has some serious generic concerns about the impacts of development south of the A2 on connectivity, safety and congestion. We request that Swale Planners pay particular attention to the road, pedestrian and cycle linkages between developments south of the A2 and the town.
We are particularly concerned that the drawings include a roundabout at the A251/A2 junction an idea about which the Society has serious concerns.
The A2 is rapidly evolving into a residential street in the middle of a town, not a road along the outside of it. This needs to be recognised in individual site plans and in the next SBC development plan. Planning for the new developments south of the A2 needs to recognise the long-term plans for a 20 mph zone across the town
There is a danger that the Preston Fields development will establish precedents which others will follow. In our view that would be very undesirable.
We need to see pedestrian and cycle infrastructure as well as vehicle infrastructure. We want to see light-controlled pedestrian crossings particularly around the periods when school children are going to and from school
There needs to be a footpath along the south side of the A2 and a two-way cycle path on the north side of the A2
The Society wants KCC to develop a plan for the London Road and Canterbury Road that anticipates the full transport needs of Faversham - pedestrian and cycling transport - not just the needs of vehicles.
The Faversham Society broadly welcomes the report on the Faversham Creek Neighbourhood Plan by the independent examiner, Mr Timothy Jones. The report recognises the value of the heritage and archaeology of the Creek, both for its own sake and as an asset for the town, and strengthens the protection and conservation of some of the most sensitive heritage sites. We particularly welcome the examiner’s comments on Swan Quay and the Purifier Building, and although we are disappointed that residential development has not been ruled out for Ordnance Wharf, we welcome the added protection to its heritage assets and setting.
While he has found it appropriate for the plan to allow some development, not all of which the Society would fully endorse, the examiner was impressed by the level of local interest in and commitment to the area’s built heritage, and found this reassuring for the future of those sites that most merit preservation.
The Board wishes to thank Dr Pat Reid, who represented the Society at the examination hearings in October 2015, and whose contribution is clearly reflected in the report, with its many references to archaeology and the addition of a new policy. We would also like to thank Ray Harrison, whose character appraisal highlighted the importance of Swan Quay as a particularly sensitive heritage site, and whose architectural and conservation expertise is noted with respect by the examiner.
The Faversham Society accepts all of the proposed amendments, with thanks to Mr Jones for his sensitive and thoughtful approach.
The report can be seen here.
The Faversham Society welcomes the final report on the Inspector’s interim findings on the Swale Local Plan. We are pleased to see that, although housing targets have been increased from 540 to 776 per year, the much higher numbers demanded by some developers have not been accepted.
We are also pleased that the Inspector acknowledges the distinctive character of Faversham, and has confirmed the soundness of the plan’s two-area settlement strategy, with higher levels of development in the former Thames Gateway area and more modest development in Faversham and rural areas.
We are however concerned about the effect of any new developments on traffic in and around the town, and have written to Kent County Council to call for a road traffic plan for Faversham. We note that the impact of the higher housing target has yet to be tested against highway infrastructure models.
The Inspector says that Swale Borough Council has undertaken to prepare a heritage strategy, which she considers necessary to ensure that heritage policies are soundly based and consistent with the National Planning Policy Framework. I have written to Swale Borough Council to ask that the Society should be closely involved in the development of the heritage strategy.