5 March, 2015.
The Strategic
Planning Manager
Thanet District
Council
PO Box 9
MARGATE
CT9 1XZ
Sir,
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rescinded on 26th March 2013.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.
General reaction
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.
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Public response
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.
Assessment
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,
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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.
Housing
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”.
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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.
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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…….”
While
(1.31) “The 15 hectares is significantly below the amount of land
that was allocated in the 2006 Thanet local plan……..”
And
(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.
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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
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.
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Conclusions
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.
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