18^th March 2022

Dear Paul Gregory

Land at Lady Dane Farm, Faversham – Holistic Overview.                            

Applications numbers - 18/501048/REM - 21/502927/FULL - 21/506465/HYBRID

This representation, submitted on behalf of the Faversham Society, scopes all applications for Lady Dane, both approved and pending approval. This is so that the delivered and proposed land use allocations can be compared to the MU6 policy allocations in the prevailing Swale Local Plan 2017.

Master planning.

We are concerned that a Lady Dane masterplan to coordinate the land use disposition and quantum across the multiple applications has not been submitted. This is bad planning practice. We are faced with a dual ‘estate’ identity with separate developer enclaves that deny a sense of place in the locality.  There is no vehicular connectivity between the adjoining schemes.

 The Fernham Homes (FH) planning statement details inconclusive discussions between the landowners and the planning department who were seeking to agree a coordinating masterplan for policy MU1 in the emerging local plan.

3. 2.2.13 Following the Council’s consultation of the Pre-Submission Local Plan Consultation Draft Version February 2021, Fernham Homes took part in several strategic workshops with all of the landowners that formed part of the proposed MU1 allocation. These workshops were organised by the Council and intended to review and agree the Emerging Local Plan Concept Masterplan (Figure 4) as part of the process. Two meetings took place but any progress towards agreeing the Masterplan stalled as:

1.       (1) The landowners could not collectively agree the principle of community infrastructure equalisation across the entirety of the allocation where land was required to be transferred for education infrastructure. Fernham Homes were agreeable to contributing on an equalised basis.

2.       (2) The location of community infrastructure could not be agreed.

This statement refers to the emerging new local plan and is irrelevant in the context of Policy MU6 in the Swale Local Plan 2017.  In the light of the Reg 18 deferred status of the emerging plan the adopted Swale Local Plan 2017 Bearing Fruits 2031, carries full weight in the determination of these applications.

 We understand that Lady Dane is in the ownership of a single entity, except for the Crest Nicholson (CN) Phase 1 scheme which nears completion.  In this context there can be no ‘failure of agreement between landowners’ to inhibit the provision of a masterplan to coordinate the applications.

 We would encourage officers to persuade the applicants and landowner to commission a masterplan to inform the land use disposition, quantum  and connectivity across the schemes.

Insufficient Information Provided.

The Faversham Society are concerned that insufficient information has been provided to fully scope compliance with the land use allocations prescribed in Policy MU6.  The current submissions, together with the consented Phase 1 site, propose the development of 438 units. This exceeds the local plan allocation of 260 by a significant factor of 69% (178 units).  CN and FH have not provided details of the unit plotting metrics, or the site areas of land use categories, to enable an informed assessment as to whether the land use policy allocations have been complied with. There is no database scoping this. 

Policy MU6 (2) allocates 13 hectares (nearly 50%) of the 27ha site as greenspace.                   

Use the rolling landscape to define the development envelope in a way that respects its topography and watershed and through an integrated landscape strategy:

1.       secure substantial strategic parkland to meet open space needs (including that for natural and semi-natural greenspace) and provide for improvements to existing sports pitch and formal play facilities;

2.       achieve a net gain in biodiversity.

3.       minimise adverse visual impacts, with particular regard to the siting of development at the eastern boundary; and

4.       provide a landscape framework that reflects and reinforces the area's landscape character.

In the absence of a coordinating masterplan, or any integrated landscape strategy, a visual comparison of the site layouts for the ‘green’ provision across the three-applications, set against the quantum marked on the policy allocation plan can be reviewed (Appendix 1). This clearly illustrates that there is a significant shortfall of greenspace proposed.

We have endeavoured to identify the area of green space in the applications from an analysis of the limited data available and this is scheduled in the table below.  The calculated allocation of housing land is derived from a simple division of the 7ha (17acre) allocation by the 260 units to arrive at a unit plotting density of 37.1/hectare(15/acre).

This analysis illustrates that an overprovision of housing has ‘captured’ 8.9 acres of employment land (72%) and 5 acres (15%) of greenspace for housing.  It is noted that the 15/acre development density appears high compared to the submitted application layouts. The plotted housing typologies are predominantly two storey with a limited range of apartments.  This suggests a lower density typically in the region of 13-14/acre which would increase the land take.  At 13.5/acre this would increase the greenspace loss to 8.2 acres (25%).  In the absence of a coordinating masterplan a land budget should be sought from the applicants (including a retrospective audit of CN Phase 1) so clarity can be introduced to these plotting scenarios.

Conclusions

The development proposals submitted represent over development and an inadequate allocation of greenspace is proposed. The housing numbers should be justified to demonstrate the efficient use of land and reduced to ensure that sufficient greenspace is provided.

The employment land loss, reducing the allocation by 72%, is premature.  The promotion and development ‘strategic land’ is a long-term business. The land at present is unserviced farmland without any planning consent for development.  A ‘snapshot’ market survey, commissioned during a period of reduced activity during the Covid pandemic, cannot justify the extinguishment of 72% of the allocation only 5 years into the 14 year term of the plan.  The outline application should be refused.

We would be obliged if this representation could be registered against both the Crest and Fernham Homes undetermined applications.

Yours sincerely

Harold Goodwin

Chair, Faversham Society