20/500015/OUT | Outline application for the development of up to 180 dwellings with associated infrastructure including internal access roads, footpaths, cycleways, parking, open space and landscaping, drainage, utilities and service infrastructure works (All matters reserved except Access). | Land At Abbeyfields Faversham Kent ME13 8HS
If you agree with us please OBJECT on Swale's Planning Portal
The listed buildings of the Abbey Barns site is adjacent to the open fields and creek; the main abbey port lay to the east at Thorn Creek. ZF29 is a public footpath much-used by local residents and by visitors offering an appreciation of the Abbey Fields.
Faversham is now all but totally encircled by modern housing estates. Abbey Fields is the last place where our historic town, designated as a Heritage Asset as a Conservation Area, abuts the open countryside and marsh which explains so much of Faversham’s character. The proposed development severs the link between the Conservation Area and the open historic landscape.
In the Faversham Society’s view this amounts to substantial harm to Faversham’s Heritage Assets. As is made clear in the July 2021 NPPF (201) “Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss”
The applicant has not made a case strong enough to outweigh the harm.
That Historic England has not commented does not indicate approval, HE has been stripped of resources and lacks the resources necessary to respond.
JBPA conclude "Overall, the creation of much more carefully planned transition from the eastern fringe of the town to the open land beyond."
In the view of the Faversham Society JBPA here defines the substantial harm that the development would to do Faversham's sense of place and its most important green lung, the importance of which has been very evident in the context of Covid and lockdown.
JBPA seem to be suggesting that less than substantial harm to the heritage assets would be caused by the development and to imply that refusal would be vexatious. We think that on the contrary substantial harm would be done.
As Montagu Evans point out in their evidence substantial harm can be caused “though development in its setting.” This development would damage the setting of the Conservation Area which it abuts and would do substantial harm, meeting the high test.
Montagu Evans define the test thus: “if the development is completed, will it reduce someone’s ability to appreciate what is special about the asset?” YES IT WILL. The proposed development divides the Conservation Area and other Heritage Assets from the natural landscape between the Abbey, Abbey Barns and Thorn Creek which was the Abbey’s port, the division diminishes the Heritage QAssets causing substatial harm.
JBPA make several claims of public benefit. The Society disagrees
The emerging Local Plan does not identify this as a suitable site for further housing development and the 180 houses are not required.
A "policy compliant amount of affordable" housing will not contribute to meeting housing needs which is for two-bedroom genuinely affordable starter homes, homes suitable for the elderly and those with disabilities and one bedroom studios. Claims made by developers at Outline Planning Permission often fail to materialise when detailed plans are submitted.
There are claims made about the provision of jobs, but no guarantee that these jobs will be filled locally.
AECOM in their site assessments for the emerging Neighbourhood Plan point out that
1. Access to the site is off Abbeyfields, a relatively narrow road, part privately owned with parking on both sides and
2. It is relatively poorly located for local services so that most residents would access the town by road.
3. The site sits within an area identified as having medium to high sensitivity to new development in Landscape Sensitivity Assessment and lacks defensible boundaries along the eastern edge, and a larger site was put forward for the SHLAA, the precedent is unwelcome
4. In the Local and Neighbourhood Plan the site was not selected for development, and Swale’s targets are met without any development on Abbey Fields
Similarly, the other cited "public benefits" are little more than a wish list and are not guaranteed. They are also in many cases, undesirable.
JBPA has disregarded our previous comments so they are repeated and amplified here.
"The facts that a) the proposed development at Abbey Fields is not necessary in order for Faversham (or Swale) to reach their respective housing quotas, b) would aggravate already serious traffic flow problems on the Whitstable Road, c) would infringe on a Local Wildlife Site which also has important amenity functions for local residents, d) has already been rejected for housing development in the emerging Local Plan, and e) would damage irreparably the characteristic view from the northeast of Faversham as a historic port town, mean that this application must be rejected."
The residents survey of 2020 saw a significant number of respondents wishing to see the preservation of the town with as many as 65% of respondents wanting to preserve as much as possible. The industrial heritage of the town and its proximity to the marshes and the countryside were referred to as providing the character and "lungs" of the town, respectively. This development site is adjacent to the Conservation Area and listed buildings at the Abbey Barns and, if built out, would damage views of the town from an historical landscape perspective.
The site lies north of the existing built-up area of the town and as a field with casual path across it, public footpath along it, hedges and pond forms part of the 'accessible countryside' for this part of Faversham. It is used as a habitat by a variety of wildlife including bats and warblers because of the hedges and pond. As well as this, it is actively used for agriculture and is within the scale of Best and
Most Versatile Land with part grade 2 and part grade 3a. The development of this land would result in the permanent loss of agricultural land as well an area of accessible countryside valued by local people.
An extra 180 houses in this location does not "enhance the intrinsic value, tranquillity and beauty of the countryside" around Faversham. (Section 5 of Policy ST3 of the adopted Local Plan) Both CPRE and the Faversham Society believe the area to have high landscape sensitivity in contradiction to the assessment of the site having "moderate-high sensitivity to future change from residential and employment development," believing it to be important to Faversham's identity as an historic market town at the heart of a high-value agricultural area.
The spring at Clapgate is one of a series along this stretch of the coast that emerge where the chalk of the North Downs meets the impermeable clay formations of the Thames Estuary. The stream that flows from Clapgate down through Thorn Creek and into Faversham Creek is therefore considered a chalk stream, which is one of the most endangered habitats in the world. Any possible run-off from the new development, even under storm conditions, must therefore be avoided because it would cause unnecessary damage to the chalk stream ecosystem. See the attached letter from the Environment Minister, Rebecca Pow, about the Westbrook and the priority accorded by the government to chalk stream conservation, which may have some quotable phrases re: EA regulations, etc.
The “at least 10% biodiversity net gain” proposed by the developers should be increased to “at least 20%” in line with the draft Local Plan. The site is currently used for arable agriculture so they’re starting from a very low baseline in terms of species biodiversity. The hedgerows along the margins of the site are almost certainly the most important wildlife habitat and should be retained at all costs. The site is a hunting ground for barn owls.
The eastern end of the site, adjacent to the spring and pool at Clapgate, is part of a Local Wildlife Site that is particular valued for its amenity value by ramblers, dog walkers, birdwatchers, etc., heading out into the countryside east of Faversham. The pool is a breeding site for waterbirds and important habitat for water voles and Critically Endangered European eels. The adjacent reed beds harbour grasshopper warblers (endangered in Kent according to the Red Data Book).
We reiterate our previous submission, which remains valid.
"The proposed development is on a prominent site north of the town visible from long distances. Although set above a steep bank, it forms part of a continuous open area to the north of the town from Abbey Farm westwards. The raised terrain enables long views from the edge of the town to extensive wider countryside including to the Blean Ridge. The site as an open area also provides part of a wider landscape setting to the listed building complex at Abbey Farm which includes the former site of Faversham Abbey and its pond and a rare concentration of listed buildings at grade I, grade II* and grade II. The site also provides an open setting to the edge of the Faversham Conservation Area which abuts it immediately to the west. Views into the conservation area can be obtained from many parts of the site including to Faversham Parish Church with its crown spire. The views across and through the site would be reduced and constrained by the proposed housing."
The site was rejected in the SHLAA process for the Local Plan currently being prepared. Again we emphasise our previous submission, which remains valid. Our objection "is partly because of its poor access which remains a major issue because the road is narrow, poorly maintained and a privately owned. The applicant also owns land close by, also agricultural land of similar agricultural land classification and with only the same access. The development of the present area of land could set a precedent for development of other nearby land which would be of at least as great harm to the setting of the Faversham conservation area."
"Abbey Fields abuts the east boundary of the Faversham Conservation Area. The character of the
landscape immediately within the Conservation Area here is one of historically and visually
significant open space (itself a rare feature within the Conservation Area as a whole). Among other
things this space provides part of the historic setting of the nationally important group of Grade II*
and Grade I listed house and barns, built for the monastic community of Faversham Abbey. The
Conservation Area landscape here remains essentially medieval in origin - all of it, including the
Cooksditch Stream, related to the workings of the former Abbey. This gives the area a unique
Prior to the mid c19 with the arrival of the railway branch to the Creek, this agricultural land around
the former Abbey site extended eastwards as further fields - Abbey Fields, once the 'Great Field' -
to the horizon. Notwithstanding the narrow incursion of the railway line (now a road), this remains
so today - the open agricultural land of Abbey Fields forms the east side setting of this part of the
CA. Nowhere else, apart perhaps from in a small way at Standard Quay, does the historic town
retain its pre-industrial, pre-C20, relationship with what was its millennial agricultural surroundings.
Everywhere else in the town the link with the countryside has been severed by later developments
of varying quality.
That Abbey Fields was exploited for brick earth and that scrub has grown up along the line of the
old railway makes no difference to the fact that this is literally the last major place in Faversham
where the historic and aesthetic relationship between the ancient town and its countryside
survives, can be seen, can be experienced and understood. The urbanisation arising from the
residential development of Abbey Fields will destroy the Conservation Area's last major, historic,
link between town and country. It will thus severely damage the setting of the Abbey Farm
buildings and of the Conservation Area and greatly reduce the potential for 'understanding' in what