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Faversham Society response to the Local Plan at REG19

Although there is much talk of localism, all planning decisions must be compliant with the National Planning Policy Framework (NPPF) and national planning legislation. The Swale Local Plan, and the Faversham Neighbourhood Plan, will be tested by the Planning Inspectorate against the NPPF. Both Swale & Faversham plans fail if they are found not to be compliant with central government policy. The Inspectorate’s role is to enforce national government policy.

It is important to distinguish between the Swale Local Plan and the Faversham Neighbourhood Plan. Members of the Society are engaged with the Town Council in its endeavours to achieve the best possible Neighbourhood Plan for the development of our town within the significant limits to what is possible because of national government policy.

The Society has engaged with the development of the new Swale Local Plan, most particularly in addressing the site selection. The processes through which local and neighbourhood plans are developed and the consultation procedures used are regulated by central government. The extensive Swale process can be examined here. District and parish councils are required to comply with these nationally determined procedures. In Swale, there was a Regulation 18 consultation followed by the development of a draft plan by planning officers overseen by the Local Plan Panel of elected councillors and the full Council through the normal processes of representative government. The Faversham Society was able to follow and engage in these processes, as could the parish councils and the electorate.

The Faversham Society has had sufficient time to undertake a detailed assessment of all the sites proposed for housing development and to consult our members. The results of those site assessments can be found here. We were able to engage in the debate about where the houses should be allocated by Swale and lobbied our elected Borough and Town representatives.

We are now at the Regulation 19 stage, where the nationally determined process permits us only to comment on the detail in the plan. Swale has a Duty to Cooperate and ensure that its plan is Legally Compliant. The other test is Soundness. The criteria for soundness are in para. 35 of the NPPF; it needs to be positively prepared, justified, effective and consistent with the NPPF. These limits on the consultation are imposed by central government through the NPPF.  They are not Swale’s responsibility. The national planning system has over the last decade or two been tilted towards making building easier and local authorities have very limited powers, for example to require green building. While the Faversham Society believes that solar panels should be incorporated into the design of all new houses rather than installed on land that was otherwise intended for reversion to saltmarsh, it recognises that neither the Local Plan nor the Neighbourhood Plan has the authority to require that.

Housing

Housing allocation in the Swale Local Plan

Numbers: Central government uses an algorithm to impose housing targets that districts are obliged to achieve. Failure to achieve these targets renders the Borough vulnerable to speculative applications from developers.

The government of the day determines how many houses Swale must build, setting both numbers and dates by which the targets must be met. Swale has to have both a five-year housing land supply and achieve the targets on the schedule set by national government.  District Councils do not build houses; they can only grant permission for developers to build. Developers will only deliver when they can realise what they regard as a reasonable price for the dwellings they build. If the government’s housebuilding targets are not met, Swale is vulnerable to unwanted developments for example, at North Street, Abbeyfields or west of Faversham. Unfortunately, developers can realise good prices for houses built around Faversham, and they constantly look for opportunities to build around us.

National government requires that districts permit developers to build a defined number of housing units by dates determined by central government. Local planning authorities then have to allocate sites and make this as palatable as possible to local residents. In doing this, they have to allocate land which developers can profitably develop.

Local Housing Need
The nationally determined housing numbers do not reflect local needs. It defines only numbers of houses, not types of housing. The Faversham Community Land Trust commissioned a Housing Needs Survey from specialist research organisation, Arc4. They found that households would need a minimum income of £30,590 per annum to afford the lowest cost affordable homeownership option. An income of £56,186 per annum would be required to afford the entry-level market house price. Households seeking rented accommodation would need a combined income of £33,264 to afford rented accommodation.

Entry-level market housing in Faversham is not affordable to many households. Arc4’s research found that 1,881 genuinely affordable units need to be built for purchase and rent over the next five years to house Faversham people. That is 376 per year. Faversham needs a mix of genuinely affordable housing. The research found 211 people couch surfing in Faversham, and we know of families where a son or daughter is living in a shed in the back garden. Faversham is not alone in experiencing the housing crisis. To address Faversham’s housing problems, we need to build a different kind of housing to that favoured by developers.

The survey found that we need:

  • Small family homes (2 or 3-bedrooms), small homes for singles and couples and small homes to enable older people to downsize;
  • Houses for first time buyers, social rented housing for low-income households and housing suited to frail elderly or disabled people.

The Swale Local Plan Housing Allocation

In July, 2020 we expressed our preference for Option A of the three that were identified by Swale, stating that: “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 be taking a large part of the additional 3,000 homes.”

We share Swale’s regret that central government’s housing targets for the Borough cannot be met “on brownfield sites in sustainable locations/within settlement confines and on land at low risk of flooding within existing settlements and on land with the least environmental or amenity value.”

Swale councillors decided on Option C in July 2020. That decision was debated and discussed nine months ago, and the Society expressed its strong opposition then to what amounts to a disproportionately large and unfair allocation of additional  housing to Faversham. Neither MP wants to see further housing in their constituency, and they are both campaigning for the housing to be in the other’s constituency

The Society’s site assessments played a part in ensuring that there was no further large-scale housing development west of the town, where the impacts of additional housing would be most damaging in particular because of the increased traffic and resulting pressure on the road network.

The avoidance of large-scale housing development to the west of the town has also reduced the possibility of a road being built from the Western Link roundabout to the M2 at some point in the future. This is important to prevent the risk of a major highway being put through the Syndale Valley.

Although the Society remains strongly opposed to the development of extensive housing to the east, we have concluded that – if additional housing is imposed upon us, we cannot walk away - rather we must work to mitigate its worst effects. We are determined that the mistakes of the past should not be repeated.

Risk of Unwanted Planning Applications from Developers

If there is not a five-year housing land supply in the Swale, then we are vulnerable to unwanted speculative planning applications for large-scale housing developments. The land around Faversham is particularly vulnerable because of the sale prices, which are achieved around our town. Unfortunately, Faversham has strong viability, defined by central government as 15-20% of the gross development value, this in addition to the landowner premium.

We learnt a bitter lesson in Faversham about the dangers of speculative development when there is not a five-year land supply for housing[1]. The Borough is vulnerable to developer-led development whenever there is not a five-year housing land supply. If Swale fails to meet the government’s Housing Delivery Test the national Planning Inspectorate is highly likely to approve developers’ appeals. The Perry Court planning application was finally accepted after a heated debate because rejection would have resulted in punitive costs being imposed by the Planning Inspectorate when the applicant appealed. This development breached the A2 and paved the way for Faversham’s expansion.

There is currently a planning application resubmitted for up to 180 dwellings on Abbey Fields [20/500015/OUT]. This site is not scheduled for development under either Bearing Fruits or the current draft plan. The applicant in their covering letter, points out that “the Council is not able to demonstrate a five year supply of housing with the latest published position 4.6 years supply.” In these circumstances, the national government’s National Planning Policy Framework (NPPF) requires that “permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the NPPF as a whole.” The applicant is able to appeal to the Inspectorate if Swale rejects their application. The role of the Inspectorate is to ensure that planning law is enforced and to apportion costs.

Infrastructure

Roads: the Society is very concerned about the increased traffic congestion and pollution likely to result from the additional housing. Regrettably, this is not sufficient grounds to reject development.  We support plans to turn the A2 into the Watling Street functioning as a town street.  It can no longer function as a “bypass” to the south of our town. It now runs through Faversham.

Mobility: the Society will continue to support 20’s Plenty, active mobility through walking and cycling and the creation of additional paths and cycleways to link new developments to the town and to the surrounding countryside.

Schools: two new primary schools and a new secondary school are planned.

Primary Health Care: both GP Practices have applications in for expansion; decision making about the provision of primary care for the town rests with those practices and the NHS Integrated Care System for Kent and Medway.

Dentists: the new dental surgery has significantly increased the availability of dentistry. There are still plans for another dental surgery in the former Iceland.

Air Quality

The Society shares the concerns of many Faversham residents about pollution from exhausts and road dust. The NPPF makes passing references to the desirability of avoiding development which reduces air quality. In paragraph 181 there is a reference to the “cumulative impacts from individual sites in local areas”. The NPPF advises that:

“Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications.”

We are as dissatisfied with the provisions in the Draft Local Plan on Air Quality as many residents but have not been able to determine where or how Swale could go further, given central government policy and the NPPF.

Enforcement

We are concerned about the extent to which planners at Swale Borough Council will be able to enforce the plan. We are worried that there are no clear tests, clear definitions of what constitutes compliance or non-compliance for some of the planning objectives.

Despite our reservations on housing proposals, there are other proposals to commend in the Draft Local Plan. The Society:

  • is pleased to see the prominence given to addressing the climate and biodiversity crises.
  • strongly supports the emphasis on improving skill and linking learning and employment opportunities. Low pay in Faversham is a challenge that results in families needing to leave the town to find affordable housing.
  • is pleased to see the references to heritage, reduced congestion and air quality issues in the vision for Faversham.

[1] https://www.kentonline.co.uk/faversham/news/perry-court-approved-93571/

April 19, 2021

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The Faversham Society - Registered Address: 10-13 Preston Street, Faversham, Kent ME13 8NS
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