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Councillor Gerry Lewin. |
I object to this application.
PREAMBLE
This application is an outline application for permission to build a main access to the development with ALL other matters to be dealt with in a future application.
Whilst this application does not include details of that access one asks what then is the point of this application?
This application is an outline application for permission to build a main access to the development with ALL other matters to be dealt with in a future application.
Whilst this application does not include details of that access one asks what then is the point of this application?
• Clearly it is the applicant’s intention to test the Local Planning Authorities approach to housing of this quantum at this location and therefore we must respond as if it were a ‘FULL’ application.
• It is interesting that no details of the access being applied for are provided with the application on the website [I accept that an access has been pictorially represented by the applicant but surely this would not be acceptable as a document to support the application?].
The application on the planning portal is very thin in information and relies heavily on the contents of the consultation leaflet sent to parts of the village.
POLICY
The site has NOT been allocated for housing in either a] the Swale Local Plan adopted in 2008 or b] the Swale Local Plan Proposed Main Modifications June 2016. Developers can however submit applications beyond the Local Plan that are in accordance with the National Planning Policy Framework [NPPF] where a Local Planning Authority [LPA] does not an ongoing five year housing supply or where the LPA does not have a compliant [with the NPPF] Local Plan. In either of these situations the applicant, nevertheless, will only be granted permission if they can show conformity with the principle of sustainable development as given in the NPPF at para 7 – which refers to the economic role, the social role and the environmental role. Whilst Swale does not have a current five year supply I believe it can be shown that this application [albeit outline] can be shown to fail the sustainability criteria of the NPPF.
The position of Upchurch, in relation to its ability to accept further development is stated in policy SH1 para5 of the Swale adopted Plan and restated in policy ST3 page 58 of the Swale Proposed Mods June 2016 document. These are both worth reading but broadly state that development of this size would not be acceptable in this village – I recommend quotations from these policies be used in consultation responses.
Councillor Gerry Lewin
The application on the planning portal is very thin in information and relies heavily on the contents of the consultation leaflet sent to parts of the village.
POLICY
The site has NOT been allocated for housing in either a] the Swale Local Plan adopted in 2008 or b] the Swale Local Plan Proposed Main Modifications June 2016. Developers can however submit applications beyond the Local Plan that are in accordance with the National Planning Policy Framework [NPPF] where a Local Planning Authority [LPA] does not an ongoing five year housing supply or where the LPA does not have a compliant [with the NPPF] Local Plan. In either of these situations the applicant, nevertheless, will only be granted permission if they can show conformity with the principle of sustainable development as given in the NPPF at para 7 – which refers to the economic role, the social role and the environmental role. Whilst Swale does not have a current five year supply I believe it can be shown that this application [albeit outline] can be shown to fail the sustainability criteria of the NPPF.
The position of Upchurch, in relation to its ability to accept further development is stated in policy SH1 para5 of the Swale adopted Plan and restated in policy ST3 page 58 of the Swale Proposed Mods June 2016 document. These are both worth reading but broadly state that development of this size would not be acceptable in this village – I recommend quotations from these policies be used in consultation responses.
ISSUES
Infrastructure – clearly a development of this nature will put pressure on the local highway system in the centre of the village both for pedestrians and vehicles. New vehicle movements from this site will in the majority travel westwards to leave the village by Oak Lane or Horsham Lane with few movements via Holywell or Halstow Lanes. The centre of the village at the church is constrained physically by the church wall and road width exacerbated by increasing on-street parking in this area by residents, shoppers and delivery vehicles. The position for pedestrians approaching this area is one where if there are no pavements to walk on then there are inevitable roads to be crossed. It is difficult to see how developer contributions could mitigate these issues.
Services – Currently the primary school is at capacity with some capacity at local primary schools in Swale. However the demographic profile for Swale means that KCC is requesting money from developer contributions from rural areas be directed to urban schools. Others will comment on the ability of Holywell to expand its pupil input but any increase in its numbers will again cause vehicle movements that go through the centre of the village [see above]. I am neutral about commenting on access to health services as these are problems not of a local nature but can be found wherever you go.
Suitability – the site assessment of this location can be found in the Swale Proposed Mods June2016 appendix entitled ‘Ranked Assessment of Reasonable Non-Allocated Site Options to inform Modifications to Swale Borough Local Plan’. It is referred to as SW/718 and is ranked 94th of 116 sites not allocated. This ranking indicates that, of the sites offered by landowners currently, this is unlikely to be approved for allocation for housing except in extreme circumstances which are difficult to imagine.
Agricultural Land – loss of our best and most versatile high quality agricultural land means a continuing impact on our ability to feed ourselves also any loss has an impact on our local economy. It is a consideration in planning and referred to in the NPPF also in Swale Proposed Mods June 2016 in policy DM31. I am unware of the grade that applies to this location but it can be easily found and cited.
BENEFITS
It must be recognised that developer contributions can be used to mitigate some of the harm caused by development – hence the S106 legislation. I list some examples applicable to this application.
Affordable Homes – the scheme provides the opportunity to deliver some of this housing type. I am aware of the need expressed by some residents, of the lack of such provision in the village. There are however alternative ways of delivering such schemes not requiring this level of development to deliver them.
Local Economy – it could be argued that there may be some local uplift during the construction phase, however this scheme does not deliver lasting employment opportunity. I accept that some local retail and leisure businesses would welcome an increase in their trade.
School Parking – could be seen by some to be helpful in relieving the current congestion but I do not understand how the number provided has been calculated or to what degree it would relieve congestion.
Public Transport – it is suggested that some contribution will be made towards improving the buses. This would of course be welcome but is not quantified.
Benefits Overall – whilst developer contributions can be used to mitigate some of the harmful effects of development it is my view that in this case the harm significantly outweighs the benefits and that this application fails to meet the sustainability criteria required by the NNPF, The Adopted Feb 2008 Local Plan and the Swale Local Plan Proposed Main Modifications June 2016.
Infrastructure – clearly a development of this nature will put pressure on the local highway system in the centre of the village both for pedestrians and vehicles. New vehicle movements from this site will in the majority travel westwards to leave the village by Oak Lane or Horsham Lane with few movements via Holywell or Halstow Lanes. The centre of the village at the church is constrained physically by the church wall and road width exacerbated by increasing on-street parking in this area by residents, shoppers and delivery vehicles. The position for pedestrians approaching this area is one where if there are no pavements to walk on then there are inevitable roads to be crossed. It is difficult to see how developer contributions could mitigate these issues.
Services – Currently the primary school is at capacity with some capacity at local primary schools in Swale. However the demographic profile for Swale means that KCC is requesting money from developer contributions from rural areas be directed to urban schools. Others will comment on the ability of Holywell to expand its pupil input but any increase in its numbers will again cause vehicle movements that go through the centre of the village [see above]. I am neutral about commenting on access to health services as these are problems not of a local nature but can be found wherever you go.
Suitability – the site assessment of this location can be found in the Swale Proposed Mods June2016 appendix entitled ‘Ranked Assessment of Reasonable Non-Allocated Site Options to inform Modifications to Swale Borough Local Plan’. It is referred to as SW/718 and is ranked 94th of 116 sites not allocated. This ranking indicates that, of the sites offered by landowners currently, this is unlikely to be approved for allocation for housing except in extreme circumstances which are difficult to imagine.
Agricultural Land – loss of our best and most versatile high quality agricultural land means a continuing impact on our ability to feed ourselves also any loss has an impact on our local economy. It is a consideration in planning and referred to in the NPPF also in Swale Proposed Mods June 2016 in policy DM31. I am unware of the grade that applies to this location but it can be easily found and cited.
BENEFITS
It must be recognised that developer contributions can be used to mitigate some of the harm caused by development – hence the S106 legislation. I list some examples applicable to this application.
Affordable Homes – the scheme provides the opportunity to deliver some of this housing type. I am aware of the need expressed by some residents, of the lack of such provision in the village. There are however alternative ways of delivering such schemes not requiring this level of development to deliver them.
Local Economy – it could be argued that there may be some local uplift during the construction phase, however this scheme does not deliver lasting employment opportunity. I accept that some local retail and leisure businesses would welcome an increase in their trade.
School Parking – could be seen by some to be helpful in relieving the current congestion but I do not understand how the number provided has been calculated or to what degree it would relieve congestion.
Public Transport – it is suggested that some contribution will be made towards improving the buses. This would of course be welcome but is not quantified.
Benefits Overall – whilst developer contributions can be used to mitigate some of the harmful effects of development it is my view that in this case the harm significantly outweighs the benefits and that this application fails to meet the sustainability criteria required by the NNPF, The Adopted Feb 2008 Local Plan and the Swale Local Plan Proposed Main Modifications June 2016.
All the documents I have referred to can be found on the Swale Borough Council website. Link: www.swale.gov.uk/planning
Councillor Gerry Lewin
135 Oak Lane, Upchurch, Sittingbourne, Kent ME9 7AY
Email: lewing135@btinternet.com
Telephone: 01634 366113 / 07946 996789
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