The Bearsted & Thurnham Society

Transcription

1 The Bearsted & Thurnham Society The Residents Association for the Civil Parishes of Bearsted and Thurnham C/O The Secretary Bearsted & Thurnham Society 3 Thurnham Oast Aldington Lane Thurnham Kent ME14 3LL thesecretary@bearstedandthurnhamsociety.org Spatial Policy Maidstone Borough Council Maidstone House King Street Maidstone Kent ME15 6JQ 6 th May 2014 Dear Sir, Local Plan Consultation 1. The Society s views on the plan are set out in the following paragraphs. 2. The Society welcomes a number of aspects of the Plan specifically: The fact that Junction 8 and Woodcut Farm are not designated for development. This is an important acceptance of the arguments put forward by the Society, its members, the Bearsted Parish Council, the Joint Parishes Group and others. The land between Cross Keys and Sutton Street (often known as Lilk Meadow) is retained as open countryside and not designated for housing development. As a water meadow, regularly liable to flooding, it is unsuitable for development and forms an important green space in the village landscape, and critical to the setting of Sutton Street Bearsted s oldest street. The exclusion of land adjoining Edlin Road, off Ware Street, for residential development. This area was clearly vulnerable to development but would have imposed a heavy burden of additional vehicle use onto an already heavily trafficked road; as well as piling more pressure on other infrastructure, notably health services and school places, demand for which already exceeds supply. The statement in paragraph 5.68 that the land to the south of the AONB that forms the setting of this designation is a sensitive landscape that requires conservation and enhancement where this supports the purposes of the AONB. The Council s commitment to resist development of residential garden land where it cannot be absorbed within the existing character, pattern and layout of the built environment without detriment to visual amenity (paragraph 11.19). As the Plan says: the subdivision of existing residential curtilages can often appear cramped and damage the existing pattern of development There are key areas of Bearsted where the demolition of single houses and many more built in their place is gradually changing the appearance of the area. The Society believes that such new development or redevelopment should always be sympathetic to the density and nature of the housing surrounding such sites.

2 We welcome the statement in paragraph 5.57 of the Plan that The countryside has an intrinsic value that should be conserved and protected for its own sake. But we are concerned that the qualification that follows However there is also a need to ensure a level of flexibility for certain forms of development in the countryside in order to support communities when taken in conjunction with the changes in SP5 see paragraphs below - weakens the Council s commitment to protecting the countryside and the measures it has available to it to secure that end. 3. While these points are to be welcomed, there are other aspects of the plan that give cause for grave concern. Weaknesses in the planning system 4. One of the great weaknesses of the current planning system is the absence of any strategic over view of how development should take place in Kent and Maidstone s place within such a scheme. This is not MBC s fault. It results from the National Planning Policy Framework, introduced by the current government, which places the emphasis on local plans rather than broader, strategic assessments. 5. However, the National Planning Policy Framework places a duty on local authorities to consult on matters of joint interest. This is reflected in paragraph 31 in terms, inter alia, of developing strategies for the provision of viable infrastructure necessary to support sustainable development; and again in paragraph 160 in relation to business needs. 6. Paragraph 160 bears reproducing in full: Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across their area. To achieve this, they should: Work closely together with county and neighbouring authorities and with Local Enterprise partnerships to prepare and maintain a robust evidence base to understand both existing business needs and likely changes in the market; and Work closely with the business community to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability. 7. The urban area of Maidstone is set hard against the North West boundary of the borough. This boundary is of historic significance only and takes no account of the social, economic, employment, transport and other links that Maidstone has with areas of Tonbridge and Malling to the west; with Medway to the north and with the county in general. 8. These areas, especially Aylesford and its massive industrial sites, formerly occupied by the paper mills, are of critical importance to what the NPPF describes as the economic markets operating across the Maidstone area. For many years the former paper mills provided the largest source of employment for Maidstone residents and paper making was for generations one of the key industries of the Maidstone area. 9. As one travels west out of Maidstone one is within the urban area of Greater Maidstone until beyond Larkfield. Similarly, West Malling and the massive development at Kings Hill are much closer to Maidstone than they are to Tonbridge. Clearly they are part of the economic markets affecting development and employment opportunities in the Maidstone area. 2

3 10. In his Foreword to the plan, the Leader of the Council states: The local plan has been prepared by working closely with partner organisations, including Kent County Council, local communities and agencies, as well as our neighbouring local authorities. 11. That being the case, one might expect there would be many references to these discussions and the impact that developments outside of Maidstone s administrative area have on the district and vice versa. In fact there are next to no such references; even when we know from comments made by the Leader of Kent County Council, Paul Carter, that the county has severe reservations about some of the fundamental assumptions underlying the plan notably housing numbers and the ability to expand and fund the infrastructure needed to underpin such an increase. These reservations are now incorporated in the Kent County Council response to the Local Plan. 12. Regrettably there is little evidence that any meaningful attempts have been made at such cooperation. As a result the plan is based on projections that relate to MBC s area in isolation. 13. We believe that many of these assumptions are fundamentally flawed and undeliverable and that these shortcomings constitute a major failing of the current plan. Housing 14. This is particularly true of housing numbers where the Maidstone Strategic Housing Market Assessment commissioned by the borough council and undertaken by consultants G L Hearn (and made publicly available in January 2014), states that 19,600 dwellings should be built from 2011 to This represents an increase of 30% on the existing housing stock. It compares with projections produced by the Office of National Statistics which show: 12.6% increase for the UK over the same period 12.9% increase for England. 13.3% increase for the South East Region (excluding London) 17% increase for Kent (excluding Medway) 22% increase for Maidstone 15. As Alan Smith pointed out in his article in the Kent Messenger on 7 February, the Hearn figures are simply arithmetical extensions of recent population trends. They show that Maidstone s population has continued to grow faster in the last ten years than the regional averages. This leads to projections that Maidstone s population will continue to grow faster than the regional averages. Contrary to the government s guidance on the preparation of housing assessments, the report attempts no analysis or explanation of this past trend. 16. In fact this figure is largely influenced by a one-off spike resulting from development of brownfield sites which, by its very nature, is unlikely to be repeated. Within MBC s area 72% of houses are under occupied, while the 2011 census indicated there were 2,030 vacant properties in the area. Hardly, as Alan Smith points out, evidence of a housing supply crisis. 17. If one assumes that Maidstone s population would grow only at the same rate as the regional average the demand for new homes drops to between 11,000 and 12,000. This is more in line with the ability of the infrastructure to cope. 18. The Society finds it difficult to understand why the MBC has not used exactly these kinds of arguments to support a more limited growth in housing and employment that would place less pressure on the area s already overstretched infrastructure and, as we show in the following paragraphs, more in line with what is likely resources will allow to be provided, to say nothing of lessening the impact of the Plan on the environment. It is clear from Kent County Council s response to the Plan (Managing Growth in the Maidstone Borough) published on 29 th April, that they too support a lower figure. The County contends that an 3

4 appropriate housing target should be in the region of 14,500 houses, and that the current proposals are undeliverable and unsustainable and will diminish the quality of life for existing residents. As the County go on to point out, Maidstone has already provided its fair share of housing over the last decade and that it would be unfair to penalise the Borough by requiring it to deliver still more houses because of its previous record of housing delivery. 19. New development needs to provide for affordable social housing. Such affordable social housing on large scale commercial developments is not reserved for local people. The Society believes that consideration should be given to allocating a proportion of social housing in a given locality for the benefit of people in that locality. 19. Turning from the general to the specific, we welcome the fact that within Bearsted and Thurnham several sites for additional housing have been ruled out of the Plan. But the one remaining site at Barty Farm (Policy H1(17)) is, in our view, unacceptable. It is reached by a narrow, unmade up farm track giving access onto Roundwell where sight lines are impaired and which is already heavily trafficked. Furthermore, the 122 houses proposed will almost certainly mean 120 more children in due course competing for places in local schools that are already oversubscribed and which cannot be expanded. Retail and commercial development 21. We are also concerned about the spread of development at Junction 7 and the major plans by Land Securities for a massive expansion of shopping development on the site at Newnham Park. 22. We believe that the restrictions set out in paragraph 7.8 of the Plan are not sufficient to prevent development on a scale that will not damage the town centre. The fact that the Council has already granted planning permission for the development of a NEXT store at Eclipse Park weakens its hand in resisting other major retailers proposals (Debenhams and Waitrose are already being mentioned) for development at Newnham Park. 23. Far more conducive to realising the Council s stated objective of regenerating and revitalising Maidstone s town centre (paragraph 7.8) is the development being proposed by the owners of the The Mall (formerly the Chequers Centre). This would be genuinely transformative of the town centre and should be encouraged while further development at Junction 7 should not. 24. But one of the great problems facing the Council is that these and other developments (the Invicta Barracks site is now the subject of interest for retail development) are in competition with one another. If Land Securities are successful at Junction 7, then that will almost certainly lead to the abandonment of redevelopment of the The Mall and adjacent land. 25. It could also jeopardise the redevelopment of the Maidstone East/Sorting Office site which is the Council s priority location for new retail development (paragraph 7.1). There is much to be said for this site adjacent as it is to a key rail link and with the ability to up-lift the northern end of Week Street that is currently in need of regeneration. 26. But these and other sites have been the subject of discussion for many years and nothing has materialised. The area around Wrens Cross has been semi-derelict for decades. As the Plan acknowledges much of the office space in the town centre is of poor quality and needs up-grading or, as the Council suggest, converting to residential use. 27. The Society believes that a crucial reason for the failure of these projects over the years is that developers sense that the Borough Council will concede building on out of town sites, if they wait long enough for the fruit to fall from the tree. It will be extremely important that the Council keeps a tight grip on development on the periphery of Maidstone if plans for the regeneration of the centre are not to be jeopardised. History and the Council s recent record do not give cause for optimism here. 4

5 Providing the infrastructure to support growth 28. Paragraph 14.6 (page126) states that: In Maidstone Borough, some forms of infrastructure provision have historically not kept pace with development. This has been a contributory factor to some issues such as the congested road network, a shortage of affordable housing, deficiencies in open space provision and poor access to key community facilities in certain areas. There is concern that future growth will intensify this problem unless a co-ordinated effort is made to ensure that essential infrastructure accompanies new development at all times. 29. Few would disagree with that statement. Indeed, many would consider it a considerable understatement of the problems the Borough faces. Part of that co-ordinated effort was a modelling exercise carried out by the Council in 2012 which predicted that the normal growth in traffic, plus the extra congestion generated by the proposed expansion of housing and employment would result in the number of person trips rising by 42%. The Council acknowledged that such an increase would significantly impact the local economy, air quality and the general health and well being of the population. This in turn led to the preparation of an integrated transport strategy. 30. However, the strategy was subsequently trashed by the Joint Transportation Board comprising members of both the Borough Council and Kent County Council. It was described by local county council representative, Gary Cooke, as not a fit and proper document. And MBC Deputy Mayor, Clive English, described it as not integrated and not a strategy. 31. KCC has challenged the borough s plans on the grounds that they were based on traffic estimates prepared in 2012 when it was planning for 10,000 new homes in the town. Now it is planning for substantially more than that the measures planned to deal with the expansion are out of date. 32. Despite all this criticism, the Council continues to place the flawed strategy at the centre of its plans for dealing with the inevitable consequences of the massive housing expansion on which the Plan is based. Thus, Paragraph 3.9 (page 9) states that: Through the delivery of the Integrated Transport Strategy Maidstone will have a transport network that supports a prosperous economy and provides genuine transport choices to help people make more journeys by modes such as public transport, walking and cycling. The transport network will promote Maidstone town centre as a regionally important transport hub and will have sufficient people and goods moving capacity to support the growth projected by the local plan to The strength of these assertions is even more extraordinary given that the only measure directly under the Borough Council s control is car parking provision and charges! Most of the others fall to the county which has made it clear that development in edge of urban area locations will place further pressure on road infrastructure that lacks capacity now and which the KCC has no money to improve.34. Having asserted its intentions the Council then casts doubts on the financial viability of their own scheme. Paragraph (page.11) states that it would be extremely unlikely that finance from: existing resources, the new homes bonus, mainstream public funding and future site specific provision:..would be sufficient to fund the total amount of infrastructure provision that is being sought. The Community Infrastructure Levy is intended to fill the funding gap that exists once existing resources (to the extent that they are known) have been taken into account. If a funding shortfall remains once the CIL charging levy is determined there will be a need to prioritise key infrastructure projects considered necessary to support the local plan. 35. Back in December the Leader of the Borough Council was quoted in the Kent Messenger as agreeing that the town s traffic system would not cope with the extra vehicles generated by the town s 5

6 planned housing expansion of course, it can t cope. But, he added, that was not a reason to resist expansion. He suggested that the community infrastructure levy and section 106 payments could bring about the changes needed. 36. Four months later and despite all the qualifications expressed in the Plan about the ability to fund necessary infrastructure including now reservations that the CIL will come to the rescue Maidstone still intend to press ahead with major expansion. The result, as the Council acknowledges, will be difficult decisions over priorities. In other words key elements of the vital underpinning infrastructure will not keep pace with development with the results that can be all too readily predicted: greater congestion, insufficient school places and over stretched medical and social care facilities. 37. We know that the leader of Maidstone believes that congestion is a sign of prosperity. Perhaps when it takes residents hours to get to work and hours to travel home we can all comfort ourselves by knowing that we are living in one of the most prosperous areas in the country even though the quality of our lives will be much diminished. 38. The absence of clear explanation as to the means by which a transportation strategy can be delivered and funded to underpin the planned expansion leaves a huge hole in the credibility of the Plan. It is as if the borough council is simply ploughing on with its own policies irrespective of the impact they have on other partners especially KCC - and dependant on a source of funding (the infrastructure levy) that is unreliable. One hesitates to use the phrase pie in the sky for what has resulted, but in the absence of any clear evidence as to how the strategy is to be delivered it is difficult to see how else to describe it. 39. After the crash landing of the Transport Strategy we had hoped that the Plan would include detailed references to discussions between the borough council and KCC to develop a coherent revised strategy for what infrastructure can be delivered in the current economic climate. But despite the fact that both organisations have their headquarters in Maidstone and are controlled by the same political party, it appears the borough council has made no meaningful efforts to secure such an agreed strategy. 40. The current failure to match supporting infrastructure growth with the growth in housing and job creation can only result in more pressure on existing roads causing congestion, delay and more pollution. 41. The Society is particularly concerned about the impact on the narrow roads to the south of the A20, on the already heavily trafficked Willington Street and on the areas around Junction 7 where the Plan acknowledges (paragraph 7.9 page 54) that: Critical to the development of Newnham Park is the provision of appropriate transport infrastructure. The large housing development proposed for southeast Maidstone (Policy H1 nos. 6-10) is also likely to create traffic along Willington Street and other local roads to come out on the A20, yet there is no provision in the planning conditions for money to be spent on any improvements at those junctions. 42. Of course, infrastructure is not just about roads: schools, health, social and other vital services are also critically important. This is a key area for county councils and other agencies, and the future cuts in planned spending by county councils and their equivalents across the country is already resulting in horrendous predictions on the impact on services up to the end of the decade. 43. For example, projections made by the London Borough of Barnet show that rising demand and shrinking resources will result in the borough s finances being so squeezed by 2020 that it will be reduced to funding only children s services and adult social care. What has become known in local government circles as the Barnet Curve of Doom is a dire warning as to deliverability of the services on which key sections of the population depend. 6

7 44. The Society finds the gross mismatch in the Plan between aspirations for growth and the ability to deliver the infrastructure to underpin it extremely worrying. Against this background the Society asks that the Council publish, as part of the Plan, exactly how they expect infrastructure to be provided to keep step with housing, employment and retail expansion, and for a commitment that planning permission will not be granted for additional development in these areas unless it is clear the required infrastructure can be provided in step. Simply to rely on the expectation that the funding gap can be filled by levies on developers is a woefully inadequate response to this key question. Protection of the countryside 45. This issue has been of primary concern to the residents of Bearsted and Thurnham ever since a great swathe of our countryside was threatened by the KIG development. At that time the borough council took a very robust position over the need to protect this land. This included the retention of the local designation of Special Landscape Area and the saved policies which were frequently used by the Council as a basis for refusing applications for planning permission e.g. in the case of applications to build houses on the land between Cross Keys and Sutton Street, often referred to as Lilk Meadow. 46. Since then the Council has been progressively rowing back from this robust position. This began in the Core Strategy Strategic Sites Allocation in 2012 with the withdrawal of the SLA designation that only two years earlier had been an essential plank of the Council s argument for the protection of this and other sensitive areas. Instead the Council relied on a criteria-based policy to protect the countryside and the setting and separation of settlements generally. It contended that SLAs ran counter to the European Landscape Convention which makes clear the whole landscape is the most appropriate for effective landscape management and high quality of life. 47. In its submission on the Core Strategy two years ago the Society demonstrated how this approach was flawed. The Convention did not seek to restrict the scope of its measures and policies local authorities can apply to particular landscapes and therefore did not prevent the use of SLAs or similar measures to protect valued landscapes. 48. While the plan contains some warm words about the countryside and about the protection of the setting of the North Downs AONB it is short of concrete proposals about how this is to be achieved. 49. For example, Policy SP5 (see pages 43 & 44) includes the statement: The distinctive character of the North Downs Area of Outstanding Natural Beauty and its setting, and the extent and openness of the metropolitan green belt will be rigorously protected and maintained. 50. Crucially, this statement does not say how these areas are to be rigorously protected and maintained. Given that SLAs have been abandoned there is no mention of them in the Plan just how are the council s aims to be translated into action? 51. The Society believes that the above statement is woefully inadequate and that Policy SP5 needs to spell out exactly how the Council intends to protect these vital areas. We also believe that reference to the setting of the North Downs AONB is inadequate as it leaves open to debate the precise areas that are deemed to comprise the setting. These too need to be defined. We are also concerned about the absence of any reference to Public Rights of Way. On the face of it this would appear to be indicative of the lack of importance the council places on the countryside. 52. In the Society s view the setting of the AONB embraces the area as far south as the Greensand Ridge and we would wish to see this area clearly defined as part of the setting. 7

8 Saved policies 53. Appendix K of the Plan (page 346) lists the Maidstone Borough-wide 2000 Local Plan policies which were saved in It then goes on to state that these policies will be superseded by this local plan. 54. There are three policies that are of critical importance to the protection of the countryside. They are: ENV22 Urban Open Space ENV28 Development in the Countryside ENV34 Special Landscape Areas 55. Unhelpfully, Appendix K does not contain a list of the policies in the plan that supersede those listed above. Perhaps MBC think it is self-explanatory. In the absence of any clear statement one can only assume that Policy SP5 Countryside (pages 43 & 44) is intended to replace all three. 56. ENV28 states that: 57. Policy SP5 states that: In the countryside planning permission will not be given for development which harms the character and appearance of the area or the amenities of surrounding occupiers, and development will be confined to It then goes onto list 5 types of development that will be permissible. Provided proposals do not harm the character and appearance of an area, the following types of development will be permitted in the countryside. There then follows a lengthy list of developments that will be allowed which goes significantly further than under ENV28. So, ENV28 refers to confining development whereas SP5 refers to development that will be permitted. 58. The Society believes that this change of wording, combined with the deletion of SLAs, and the absence of any details as to how the MBC intend to defend these important areas, constitutes a substantial weakening of its policies to defend the countryside against development. 8

9 The importance of ENV28 and the SLA designation was well demonstrated in the decision reached by the borough council over planning application 11/1909 for development on Lilk Meadow. Amongst the arguments the Council advanced to the Planning Inspector in the subsequent appeal (for which a site visit took place in August 2012) were: The application site is located outside the urban area in a Special Landscape Area and by definition open countryside. New residential development is unacceptable in principle unless there are other determining factors or policies which can justify such development. ENV28 restricts new development within the countryside unless it falls within one of five categories. In this instance the proposed dwelling does not fall within one of those categories. The reason behind the policy is to protect countryside for its own sake in terms of character and encroachment from development. The character of the countryside in this location and the Special Landscape Area are important considerations in the acceptability of this scheme. It is abundantly clear that, if the current wording of SP5 were approved, it would not be possible to advance the same kind of arguments with the same kind of force to protect valued areas such as Lilk Meadow. This points to the shortcomings in the current wording of SP5 which need to be addressed. 59. The Society would wish to see SP5: Redrafted to include a statement that the countryside has an intrinsic value that should be conserved and protected for its own sake. Include a definition of development in terms of what it will be confined to rather than what is permissible. Set out the means by which the AONB and its setting and the countryside in general will be protected. 60. As noted above, SP5 contains no mention of Special Landscape Areas. It does state that Account should be taken of the Kent Downs AONB Management Plan and the Maidstone Borough Landscape Character Guidelines supplementary planning document. However, in the Society s view the use of words such as account should be taken and guidelines is no substitute for the policies it has abandoned. 61. The Society is not alone in calling for stronger protection of the countryside. KCC in their submission argue for: the establishment of clear policies to enforce a green belt style arrangement to protect the open countryside at the defined boundary of the Maidstone urban area and to provide appropriate buffer between the Maidstone urban area and nearby villages, preventing urban coalescene and adopting sound town and country planning principles. The Bearsted Parish Council and others have pressed for meaningful protection being extended to all the undeveloped land to the east of Maidstone stretching south to the Greensand Ridge. The Society strongly supports these arguments. Conclusion 62. While there are aspects of the Plan to be welcomed, overall we see the current proposals as a missed opportunity. After all the time that has elapsed since KIG was defeated and after a number of false starts, the current proposals still fail, in the Society s view, to produce a sustainable blueprint for the future of Maidstone. The housing target is excessive, based on the wrong assumptions and takes insufficient account of the impact of development in 9

10 surrounding districts or of the ability to provide the infrastructure needed to underpin it. In the Society s view more realistic targets are required, more closely related to the ability to fund the required infrastructure and which can secure the support of both borough and county councils. Without that there is little chance that the principal authorities will be able to come together, unite behind and implement an agreed blueprint for the future. Yours faithfully, Mary Richards (Mrs) Secretary 10