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Faversham Society Statement on Swale Housing Options

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.

July 29, 2020

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