To: Secretary of State for Housing, Communities and Local Government of the United Kingdom
Rt. Hon. Michael Gove MP
Secretary of State for Levelling-up, Housing and Communities
Ministry of Housing, Communities and Local Government
2 Marsham St
Dear Secretary of State,
I am writing on behalf of the Faversham Society founded in 1962. Today, the Society's mission is to ensure that Faversham's outstanding heritage features are safeguarded for future generations and its unique sense of place maintained. The town's relationship with its surrounding landscape is especially important since its history is entwined inextricably with its coastal location, the fertility of the Fruit Belt, its place on the fringe of the North Downs, and the archaeological heritage embedded in that landscape. Those and other values are reflected faithfully in Swale's Landscape Sensitivity Assessment of 2019. Inevitably, large-scale development around the town will detract from that relationship and those attributes. As a result, the Society, on behalf of its 700+ members and in line with its charitable purpose, seeks to ensure that what development does take place addresses local needs as its top priority, in ways that are as sympathetic as possible to the town's natural, historical, architectural and cultural heritage.
There is some confusion amongst our members and in the town about the government's policy on building on greenfield land, and I write to request clarification.
At the Conservative Party Conference, our Prime Minister said that his government sought "to build the homes that young families need in this country not on green fields, not just jammed in the south-east but beautiful homes on brownfield sites in places where homes make sense." Many in Faversham applaud this aspiration for food security, environmental and aesthetic reasons. We note that the government is committed to protect 30% of UK land for nature by 2030 and that UK self-sufficiency has been declining for the past 30 years.
We applaud the government's adoption of the levelling up agenda and hope that it might lead to the development of a regional policy that would reduce pressure on Kent and the south-east by encouraging development in the north.
Your department's standard method results in Swale having to grant planning permission for 1,048 houses per year. There is now a tiny amount of brownfield land left in Swale, with an AONB and large amounts of designated protected land and flood-prone marsh. In consequence, in the emerging local plan, Faversham is expected to accept 3,500 houses on approximately 175 ha of greenfield land in the fruit belt.
Given that Swale also has to ensure delivery of the housing targets, it is in a very weak position when it seeks to require developers to build smaller units at higher density if the developers prefer to build predominantly three, four and five-bedroom houses. This is a particular issue in Faversham where the Housing Needs Surveys reveals a severe undersupply of one and two-bedroom housing units for starter homes, those downsizing and those needing bungalows.
We mention this because more houses could be built on less land if the NPPF gave more authority to LPAs.
Some in Faversham are arguing that Swale should simply reject the numbers delivered by the standard method in order to protect greenfield land from development.
Your Housing Minister in the House of Commons on 23rd November spelt out the danger:
"We might say that, in the land of no plan, the local housing need number is king. If there is no set number in an up-to-date local plan, it is quite possible for developers to submit speculative development applications to local authorities. The local authorities may choose to turn them down, but if they have no number in their plan, the local housing need number is the default that the Planning Inspectorate will look at. It is entirely possible that the Planning Inspectorate will overturn refusals sent down by local authorities that do not have up-to-date plans or targets, and will instead look at the local housing need target. It is incumbent on local authorities that wish to protect their communities and avoid speculative development to get up-to-date plans in place."
I understand that Christopher Pincher, your Housing Minister, said recently replying to a question from Gordon Henderson, MP that
“the housing need numbers, as calculated, are a starting point, not an endpoint. It is for local authorities to determine their building target for each year over the lifecycle of their plan, to be agreed with the planning inspectorate. Local authorities are able to identify constraints—such as green belts or areas of outstanding natural beauty—that allow them to land at a different number from that expressed in the local housing need calculations. It is very much for local authorities to determine the right number of homes that should be built in their community. As I say, we want more people to become involved in the formulation of those local plans.”
Clarity on the opportunities for LPAs to challenge the standard method is important. The risk of unwanted speculative development would have serious consequences for our town, its heritage and its relationship to the creek and the marsh.
Please could you advise
Chair, the Faversham Society