In order to fully appreciate the debate that is currently taking place it is necessary to understand a few key points which I will endeavour to explain here.
Firstly there is this document called the Local Plan which in theory sets out a framework for all development that will take place in Swale over a specified period of time, in this case a 17-year period which commenced in 2015 and ends in 2031.
This document which has yet to be formally adopted is nearing the final stages of its extremely protracted consultation period, which believe or not began in 2010. We are now technically mid-way through a public inquiry which began last November and has been suspended so that the Council can make adjustments which they hope will satisfy the Governments Independent Inspector when the inquiry is reconvened later this year.
As of Thursday evening, the Council has now formally agreed what those changes are, and is set to embark on the very final public consultation between 24th June and 5th August 2016. This is literally the last chance for members of the public to offer their opinions.
Probably the most hotly contested and controversial element of the Local Plan are its housing targets. Again in theory these should have been derived from the many public consultations which have already taken place, however true the governments localism agenda, if they don’t like the answer, the targets will be imposed on us.
That is precisely what has happened here and is part of the reason that the inquiry was suspended, whilst the Council considered a range of additional housing sites which could be brought forward in order to achieve the higher housing target imposed on us.
There are two further complications that make this even more controversial. Firstly, and most significantly, is the creation of two internal planning areas. This construct was entirely the creation of Swale Borough Council and may even be unique amongst local authorities.
An arbitrary line has been drawn across the borough with approximately half of the borough now designated with a form of special protection which allows only limited development. This split is known as the Thames Gateway and none Thames Gateway portions of the borough is a left over from the last Labour Government which was, at the time, used to facilitate investment. However, it has been resurrected, and the majority of development will now be focused in the Thames Gateway area which encompasses Sittingbourne and Sheppey.
Then secondly there is something called a 5 Year Land Supply which has to identify specific sites capable of delivering a set quota of housing within a five-year period. Now just to clarify, this may involve sites comprising of a significantly higher total number of houses than those that are expected to be constructed in that timeframe due to the duration of most larger sites which will extend well beyond a five-year period.
That admittedly is quite a lot to take on board, so breathe a sigh of relief if you have made it this far.
Historic Annual Housing Completions which average 542 houses per annum
I am now going to take you through some of the numbers. The overall housing target set by Government for the whole of Swale is now 13,192 made up of 17 years x 776.
However, one year in and we’re already in trouble as we only built 618 in the last year, which is of course 158 short of the 776 we now are required to achieve on average. I guess you might be thinking that it is a bit early to panic, there is another 16 years to go and surely there are going to be bad years and good years.
Sadly, the government doesn’t work like that and micro manages targets with a rolling 5-year housing land supply which means that we now need to build 825 houses per annum for the next four years because failure to do so would lead to a review of the plan.
On this point I do actually have a degree of sympathy with Swale Borough Council because failure to take the inspectors advice and increase the annual rate from 540 houses to the 776 houses per annum figure, would undoubtedly lead to the plan been found unsound. However, increasing the numbers to 776 is a huge leap of faith, because housing developers have not achieved anything like this number in the past and failure to achieve this also creates its own problems starting with a reviews of the Local Plan which is explained below.
Spatial Planning Manager, Gill Harris explained “A local plan review would require new and updated evidence on the objectively assessed need (OAN) for housing. It would depend on what that concluded. However, if the 5-year supply was not being met this would not necessarily lead to firstly a lower OAN for housing or a resultant lower housing target. “
“A Council would have to consider whether there was adequate evidence to lower the target relative to the OAN or explore whether there were alternative strategies needed to deliver the full OAN.”
“Unless there is any review of national planning policy in respect of what councils are expected to do in meeting OAN, during a Local Plan review, any Council would be subject to the same risks from unplanned development as currently.”
It would appear that, should housing developers fail to live up to their hyperbole on the delivery of housing due to limitations on available sites or the planning process in general, all of which have been handed to them on a plate, it won’t be their fault. No indeed, all they will need is a few more sites with planning permission.
Now I am sure that you are aware that a number of additional sites, around 16 I believe, have been approved by the Council ahead of the public consultation where members of the public are able voice their opinions.
The Council was required to find enough sites to accommodate around 3,000 extra houses and this is where the debate has become most heated due to the internal split of planning areas and the weighting applied to the Thames Gateway area. It is important to note that the Government sets targets for Swale as a whole, it does not set targets internally within a borough, that was done by the Council itself and therefore any distribution within is entirely in the hands of local councillors.
This planning construct is extremely divisive and has pitted towns against one another.
It doesn’t actually make sense from a planning perspective, because the most important and sensitive landscapes with the highest landscape value in the borough, more important than anywhere in Faversham are located inside the Thames Gateway planning area. This is one of the key arguments put forward by those seeking to uphold this deeply unfair arrangement and any developer worth his salt is more than capable of finding the same documentary evidence that I have found and potentially taking the Council to task with an appeal.
On Thursday evening I attended the Local Development Framework Panel meeting which was very well attended with residents, so much so that a number had to be accommodated in an adjoining room. The meeting didn’t start well with a lack of audio in the adjoining room which meant that residents couldn’t hear the discussion taking place.
Principal Planner, Alan Best informed the panel that Faversham had taken the second highest gain (in terms of the additional housing) and that the inspector had asked for a proportional boast.
Cllr Mike Baldock (Borden) made a case for reconsideration of the two planning zones in light of new funding arrangements coming forward via the Thames Growth Commission which could assist areas outside the current Thames Gateway region and in particular made the case that Faversham residents were being deliberately deprived of funding opportunities.
Chairman Cllr Gerry Lewin (Upchurch) was dismissive suggesting that such a move “puts the plan at serious risk, it’s not for now”
Also speaking in favour of the two planning areas, Cllr John Wright (Hartlip) said “We are trying to do the best for the borough”.
Cllr Nicholas Hampshire (Tunstall) put up a sterling defence against the inclusion of the site in Borden citing the much lower Community Infrastructure Levy (CIL) funds that can be generated from development compared to sites in Faversham.
He also expressed concerns about the selection criteria, given that the site in Borden had many of the same issues as similar sites in Faversham and didn’t understand why it was appropriate in one case and not in the other.
Cllr Mike Baldock and Cllr Roger Truelove (Sittingbourne) also expressed grave reservations about whether the site in Borden was viable.
Other larger sites in the Sittingbourne area went largely unchallenged.
It still surprises me that there are a large number of people who have criticised the reaction of Sittingbourne residents for daring to suggest that the none Thames Gateway area of the borough should take a more appropriate share. Indeed, there are those that consider that 15% is too high and that the Sittingbourne share should be increased.
There are going to be some very frustrated residents on both sides of the debate and ideally we wouldn’t be building anything above the original target.
This is going to create some interesting issues in the future. Already we are about to have villages such as Bapchild, which is considered for all intents and purposes a suburb of Sittingbourne, fall within Faversham in terms of County Council representation due to the lack of new development that has previously taken place in Faversham.
Watch this space.