My MP, Sir Roger Gale's (Thanet North) response to the draft Thanet Local Plan. The deadline for comments was on Friday 6th.
A very good response from Sir Roger. All in all this is a piece of work where I think Roger has done a very good job as an elected member of parliament. Roger quite rightly points out the numbers don't add up. 12,000 new homes and only 5,000 jobs, anyone? As for Westwood Cross being rebranded Westwood and being the prime town centre, Roger quite rightly points out it isn't a town.
Take it away, Sir Roger:
5 March, 2015.
The Strategic Planning Manager
Thanet District Council
PO Box 9
Thanet District Council – Draft Local Plan
I have studied with care Thanet District Council`s Draft Local Plan, I have attended public meetings and I have received many communication by e-mail and by post from a large number of constituents and representative bodies. Most particularly I have received input from Manston Parish Council, St. Nicholas at Wade Parish Council, The Westgate on Sea Residents` Association, Birchington Parish Council, Acol Parish Council, Minster Parish Council, Garlinge, Cliffsend , Broadstairs and the Margate Civic Society. From that informed position I now submit my observations as follows:
National Planning Policy Framework
First, and as indicated in Thanet`s initial consultation document, the NPPF places “The emphasis upon local authorities to produce a local plan that objectively identifies and then meets the housing, business and other development needs of an area”. The NPPF is not inhibitive in its guidelines and very specifically allows local authorities to determine their own needs with regard to both development and the environment. The South East Local Plan, which set targets for growth including required housing targets was rescinded on 26th March 2013. Responsibility for the proposals contained within the Draft District Plan therefore lies directly with Thanet District Council. It is in this context that the proposals should be appraised.
Overwhelmingly public reaction has opposed aspects of the Draft Plan and most specifically has objected to the Council`s proposals to accommodate “12,000 additional homes over the 20 year period to 2031” as outlined in (North Thanet) Policies SP13, SP14 and SP15, with considerable disquiet also expressed about proposals for new housing in the Thanet villages. These proposals appear to conflict with Policy SP26 and “the Protection of Open Space”.
Concern has also been expressed in relation to the Council`s intention to widen the designation of Manston Airport to describe the site as an “opportunity area”, facilitating the possibility of the alternative use of a site that the majority of people of Thanet see as a national and local asset that should and must be preserved for aviation and related purposes only.
I have received no representations at all in support of the Draft Local Plan as a whole or in part. While there is clearly a recognition of the need for “local homes for local people”, for the creation of employment opportunities within the wider East Kent and for additional provision of infrastructure to meet existing needs, all of the observations that I have received, and those which have been made in considerable numbers to Thanet District Council, have been negative and reflect very real misgivings.
In describing Thanet the Draft Plan notes that
“The villages retain their separate physical identity, historic character and have vibrant communities and services” and adds that “The open countryside between the towns and villages remains essentially undeveloped, with a varied landscape, tranquility and distinctive views”.
while Strategic Priority 4 lays emphasis on the need to
“safeguard local distinctiveness and promote awareness, responsible enjoyment, protection and enhancement of Thanet`s environment…….”
This appears to be little more than lip-service in the light of what is actually being put forward for consideration.
The proposals contained within the Draft Plan threaten to destroy not only the “separate physical identity” of Westbrook, Garlinge, Westgate on Sea and Birchington which residents correctly regard as villages in their own right, but to overwhelm the “tranquility and distinctive views” of the smaller Thanet Villages that I represent while not meeting even the current requirements for enhanced local education, medical and other services.
The Draft Plan asserts that:
“It is recognised that any growth in Thanet must be supported by the necessary infrastructure, such as roads, schools and health facilities. The Plan aims to take a co-ordinated approach to delivering such facilities alongside new development and the Council has and will continue to work with other agencies, organisations and service providers to ensure that this is achieved”.
In fact, it emerges from the Draft Plan that little or no realistic provision has been made for the required services and that there is a bland assumption that “ the developer” will provide the “two form entry primary schools” that it is believed will meet the needs of the families occupying new homes and will presumably also create, for example, the “new link road to serve the development (in Birchington) and extending from Minnis Road and the A28” while offering no solution to any increased secondary school need. There is no indication that “other agencies,
organisations and service providers” will be either able or willing to step up to the mark and small faith can be placed, on the basis of current performance, in the claims contained within Policy SP32- Community Infrastructure and SP 33 – The expansion of Primary Schools. It is not enough to suggest that “Thanet will work with Kent County Council in identifying, allocating and safeguarding land as appropriate.” Adequate provision must be identified, resourced and made in advance, not as an afterthought.
In fact, the lack of thought given to or provision for supporting road, education, primary and secondary healthcare and other ( social and emergency) services forms the justified basis for very many of the critical observations that have been submitted by individual residents and, in great detail, by the genuinely representative bodies that have made submissions.
Turning specifically to housing, Policy SP 11 Housing Provision indicates that :
“Provision is made for a total of 12,000 additional homes in the period to 2031 with notional delivery across the period…..” “attributed evenly over four five-year periods.”
This figure, which represents a dramatic increase over the number of homes predicted as needed in the previous (2006) local plan, seems to be predicated upon “The Council`s aspirations for economic and employment growth” which in turn is based subliminally not upon the needs of local people but upon inward migration from the rest of the United kingdom.
Brutally, East Kent in general and Thanet in particular has suffered for too long from the “dumping”, by London Boroughs of problem children and problem families and there is a very real fear that much of the proposed additional housing may be used to accommodate not local people at all but those which the London Boroughs seek to re-locate out-of-area. Thanet has neither the facilities nor the finances to meet these demands and the provision of housing that is not supported by fully adequate infrastructure and employment is neither acceptable nor sustainable.
Under the heading “Protecting the Countryside” the Draft Plan indicates that:
(4.1) The National Planning Policy Framework (NPPF) states that local plans should take account of the roles and character of different areas, promoting the vitality of our main urban areas and recognising the intrinsic character and beauty of the countryside”.
The Draft Plan accepts that:
(4.1)“Thanet`s open countryside is particularly vulnerable to development because of its limited extent, the openness and flatness of the rural landscape and the proximity of the towns. Thanet`s countryside provides important landscapes that contribute to its sense of place, as well as making Thanet an attractive place that people want to come to. Much of the countryside is classified as `best and most versatile agricultural land`. The countryside also supports a variety of habitats and species, particularly a number of important species of farmland birds which have declined in numbers over the last few years”.
The authors of the report might have added the Thanet Brown Hare to their list of species but the assertion (4.3) that “there is a presumption against the development in the countryside as the sites allocated in this plan meet the development needs of the District” is disingenuous. It is very precisely the rural hinterland of Garlinge, Westgate on Sea and Birchington, that is being proposed as part of the solution to “the development needs of the District” while the impact of the proposals upon the smaller rural villages is also designed to intrude upon countryside and habitat.
Specifically, and in relation to Quex Park, we are told that:
(4.24)”The Park is unique within the Thanet context, comprising a formal and extensive wooded parkland and amenity landscape within an otherwise open intensively farmed landscape”
How can (SP 22/5)
“New development proposals respect the historic character of the (Quex Park) parkland and gardens”
succeed if a housing estate, complete (presumably) with all of the necessary supporting roads , street lighting, drainage, convenience stores and other infrastructure is to be permitted to be built upon the doorstep of this “unique” park on the hitherto “open and intensively-farmed landscape”?
Instead of asserting, as the Draft Plan does, that:
“A significant amount of greenfield housing land is required to meet the housing target”
the Council must first review its methodology and justify the amount of additional housing that will actually be required in the foreseeable future.
In tandem with this approach there must be a thorough appraisal of unoccupied and under-occupied property and an acceptance of the need, given the age profile of the population, to seek to create suitable accommodation (not merely the proposed `flats for single-person occupancy` - Table 4/Market Homes) designed to meet the requirements of those who wish to downsize and release larger homes for family occupation.
Next, there needs to be a thorough and imaginative examination of all of the available brownfield sites, irrespective of their current designation and excepting Manston Airport, in order to meet the current and foreseeable need.
Then and only then should consideration be given to greenfield sites to meet any genuine local shortfall.
Thanet is blessed with a very significant amount of Grade 1 agricultural land that, in the national interest, is and will be needed to maintain the sustainability of the United Kingdom as a food producer.
It is clear that insufficient value has been placed upon this land that, once built over, would not only be lost forever but would have significant additional implications in the form of damage to the already fragile water sources and demand for sewage treatment and disposal.
Economic development and employment
It is astonishing that, given that “Thanet`s business parks have been slow to develop and there is a considerable amount of land available” (Par. 1.9) consideration should be given at all to the prospect of still more land being designated (at Manston Airport) for industrial use.
Manston Park, Eurokent Business Park, Thanet Reach Business Park and the Hedgend Industrial Estate are already available and under-occupied and the former Pfizer site, not in but immediately adjacent to Thanet, has potential that is still very largely unrealised.
To quote the Draft Plan again:
(1.30) “Forecasts show that Thanet will need in the region of 15 hectares of employment land over the plan period…….”
(1.31) “The 15 hectares is significantly below the amount of land that was allocated in the 2006 Thanet local plan……..”
(1.32) “This brings into question the need to maintain an oversupply in Thanet`s employment land portfolio”.
Or, put another way, there is, surely, land earmarked already for industrial use that could and should be considered for release for housing.
Thanet most certainly needs not only housing but local jobs for, particularly young, local people. If we are to reverse the exodus of brains and skills from the Island then we should be concentrating our efforts not on moving existing jobs from elsewhere to the Discovery Park on the back of the attractions offered by an Enterprise Zone and claiming “job creation” but maximising our efforts to create genuinely new growth and fresh entrepreneurial endeavour on the sites that we already have available to us in abundance.
Westwood “Town Centre”
Westwood is described by the Council as a “town centre” when it is not, yet, a town at all. It is certainly true that the retail offer has helped to stem to flow of out-of-area shopping and may even have drawn in some customers from the wider East Kent but this has been achieved at a cost to the traditional Town centres of, particularly, Margate, Broadstairs and Ramsgate and with woefully inadequate advance thought given to, or planning for, transport infrastructure.
The Draft Plan states that
(2.21) “The area currently suffers from poor connectivity between sites, both vehicular and pedestrian”
That is an understatement. The ”connectivity” is approaching gridlock and if it is the intention to create a “Westwood New Town” with all of the housing, medical and community centres and schools that will be required to support what will, effectively, be a sizeable new village then serious investment will have to be made to resolve the current and future road network and public (road and rail) transport services.
Even now little thought seems to have been given to how and by whom that provision of infrastructure will be funded.
While much has already been achieved (SP08, SP09, SP10) with the regeneration of the Old Town Centres Westwood remains the `elephant in the room`. Everyone can see it but nobody appears to be prepared to take a strategic and comprehensive, rather than a piecemeal, responsibility for it.
Manston Airport is (local Plan 2006) designated as exactly that. An airport.
The Draft Local Plan states:
(Strategic Priority 1) Objectives:
“Support the sustainable development and regeneration of Manston Airport to enable it to function as a local regional airport, providing for significant employment opportunities, other supporting development and improved surface access subject to environmental safeguards”.
Unfortunately, after that promising start the Draft Plan now adds:
“….or as an opportunity site promoting mixed-use development that will deliver high quality employment and a quality environment”
which dilutes the airport designation and paves the way for a housing and industrial estate.
As highlighted earlier, Thanet has acres of under-occupied industrial land and there is no shortage of land to meet actual, rather than theoretical local housing demand either. By contrast, the United Kingdom is short of runway capacity in the South East, short of a major aircraft diversion facility, needs a Search and Rescue base from which to cover the Straits of Dover and needs to relieve airfreight capacity to release slots at larger passenger airports. Manston Airport can have a viable future dedicated to aviation and supporting industries . Such a project has a willing buyer and operator and huge and immediate skilled and semi-skilled local employment potential and the designation of Manston as an airport, exclusively, should be reflected in the Local Plan and maintained.
Much hard work has, indubitably, gone into the Draft Local Plan and the authors should be thanked for providing a base from which to now commence a serious and in-depth revision of the entire document.
I have deliberately eschewed the fine detail that is included in other submissions in order to avoid repetition but I would hope and expect, in the interests of those that I am elected to represent, that careful attention and scrutiny will be given to each and every one of the individual and collective submissions that have been made and that, under the guidance of a newly appointed fully-qualified Chief Executive and Officers, the plan will be re-written in its entirety and submitted to the newly-elected administration that will arise from the May District Council elections for approval and onward transmission to the Inspector for further scrutiny.
Sir Roger Gale, MP
North Thanet 4th March 2015.