This page will be updated very shortly with an indepth approach to commenting on the consultation relating to the development of Stones Farm
Key items to consider in brief
1. Legality of safeguarding possible future routes of Northern Relief Road through the Open Space which is at odds with Policy C5 which seeks to retain minimum of 15 Hectares in perpetuity.
2. Question both the phasing of and need for the site as a result of the abolition of the South East Plan Housing Targets. Current 5 year housing land supply still largely based on targets defined by the South East Plan.
3. Consider timing of development in relation to the adoption of the Core Strategy (assumed to be mid 2013) and the concerns surrounding the progression of the Northern Relief Road route options.
How to respond
Comments can be emailed direct to planningpolicy@swale.gov.uk (for the attention of Julie Davies) or sent by post to the Planning Policy Manager, Swale Borough Council, Swale House, East Street, Sittingbourne, Kent, ME10 3HT.
The full list of consultation documents can be found here http://www.swale.gov.uk/stones-farm
In-depth items for consideration
(updated 29th September)
How can the Borough Council safeguard land for the construction of the Northern Relief Road on the Public Open Space?
Quite simply we do not believe that they can. It is clearly in breach of their own policies in the Local Plan (Policy C5) and could be construed as an unlawful act. The Local Plan states that a minimum of 15ha of land be allocated for public open space and its retention in perpetuity will be a condition of any planning permission.
The Local Plan Inspector said in his report that
“I consider that the main concerns regarding the allocation of this site relate to its location within an important local countryside gap.”
The supporting wording for Policy C5 states
“It is important that a permanent open gap is maintained between Sittingbourne and Bapchild/Tonge and that the open setting of the Tonge Conservation Area is protected. Consequently, it is proposed that at least 15ha of land to the east of the Stones Farm housing allocation is provided as public open space.”
When is the site scheduled to start?
We understand that construction could start in 2012/13 based on the current forecasts from the Borough Council.
I’ve heard that there are reasons why the start of the site should be delayed, what are they?
There is concern regarding the timing of this site in relation to the Borough Council adopting its Core Strategy which is assumed to be mid 2013. The Core Strategy which is part of the Local Development Framework (LDF) will hopefully provide a clearer picture on whether the Northern Relief Road is likely to go through the site and the Borough Council will have set out its own housing targets and therefore rationalised the requirement or not to progress Stones Farm.
We’re told Stones Farm is in the Local Plan so it must now go ahead, is this true?
Contrary to the views which have repeated been expressed by the Borough Council that the site is not a reserve site and therefore afforded no special status beyond that of any other site allocation in the Local Plan, the Inspector is his report reasons that
“If, as the Council anticipates, no shortfall in housing supply arises until the latter part of this Plan period, then it will clearly have the opportunity to reassess the need to develop the Stones Farm site when it prepares and subsequently reviews its LDF.”
One might therefore reasonably reach the conclusion that Stones Farm can indeed be de-allocated if the Borough Council were so inclined.
We’ve heard that the South East Plan and a number of Quango’s have been abolished, will this impact on Stones Farm?
Almost certainly and the full extent of the abolition of the South East Plan’s housing targets and government housing density targets is as yet unknown because the Borough Council has not provided any details at this point.
Steve Quartermain - The Chief Planning Officer for Local Planning Authorities in England has stated
"Where local planning authorities have not yet issued decisions on planning applications in the pipeline, they may wish to review those decisions in light of the new freedoms following the revocation of Regional Strategies."
"Local planning authorities will be responsible for establishing the right level of local housing provision in their area, and identifying a long term supply of housing land without the burden of regional housing targets."
Stones Farm was only included in the Local Plan to make up for a possible housing target shortfall, does this shortfall still exist?
That is correct; the site was included to address a possible shortfall of 230 dwellings. However looking at the last 5 year plan that was published only 110 dwellings from Stones Farm are included, which begs the question as to the need to develop the site.
We are informed that the timescales of the Northern Relief Road and the development of Stones Farm are so far apart that the consultation doesn’t need to consider the implications of the road?
Firstly, apart from the obvious conflict of safeguarding land for the road on the Public Open Space, it is difficult for most of us to comprehend how any sensible logically minded individual can address one without full consideration of the other.
However a Freedom of Information request has revealed contradictory evidence from the Borough Council as follows: -
“The view held at officer level is that the proposed alignment of the Bapchild link road could have a fundamental bearing on the development of Stones Farm site”
James Freeman Head of Development Services 19th January 2010
“I re-iterate the position that whilst the completion of the Sittingbourne Northern Relief Road prior to the development of this site may not be necessary, transport assessment as required in the Local Plan to assess the impact of the development on the A2 is clearly sensible and could indicate the need for phasing of the development in accordance with the progress on the road."
James Freeman – Head of Development Services 16th December 2009
If the site is to go ahead do we need now to build 600 houses?
The abolition of housing density targets could have a bearing on the number of dwellings that Stones Farm can accommodate. The Borough Council now has the flexibility to respect the sensitively of Stones Farm given its location in a Countryside Gap and possibly consider restricting all development to two storeys or reducing the number of dwellings if the site is progressed.
We’re told that a full traffic assessment is required and that this has not yet taken place?
That is correct and we believe that is was assumed that this would have been undertaken now in order to resolve the issue of capacity of development on this site. The Local Plan Inspector stated
“I am satisfied that the full transport assessments which will be required by this process will provide the necessary evidence to more clearly establish the development limit of the site, up to the maximum of about 600 dwellings set out in the new policy.”
“In my opinion this issue could and should be covered by the Development Brief/SPD.”
This is further support by Swale Borough Council whom has questioned the impacts on phasing the development in both respect of possible transport mitigation measure along the A2 and the progression of the Northern Relief Road.
Can the precise boundary between the Open Space / Countryside Gap and the development be defined at this point?
This is probably only possible if the Northern Relief Road does not go through the site. However if sufficient land is reserved in the developable area of the site and the development brief is altered to suit then it might be possible to fulfil this requirement.
The Council say that “none of the various alternative routes suggested for the Northern Relief Road affect the developable part of Stones Farm” how is that possible?
The Council are suggesting that they can develop the site in accordance with the Local Plan polices as they stand and retrospectively ignore the same policies when developing the road in the future. In planning for this now, we believe that Council are possibly acting unlawfully.
The Council also states that “It is certain that the Stones Farm development will not prejudice the Northern Relief Road” which is in our opinion is almost impossible if acting in accordance with Policy C5 which would rule out the possibility of the road ever running across the 15 Hectares of Countryside Gap which is all that remains once the site is developed as planned.
Road access via Peel Drive has been ruled out, but we've heard that there are plans for a Bus Route and for use as Emergency Access is this correct?
Yes this does indeed appear to be what has been suggested and the Parish Council has considerable concerns about this. Firstly we do not believe that the commercial opportunity for a Bus Route via Peel Drive exists and the route once leaving Peel Drive would certainly be difficult in a Bus. And secondly where such access routes exist on other sites, including East Hall Farm, they have proved difficult to police.
Help Kent Wildlife Trust to help us
Bapchild Parish Council is working with the Kent Wildlife Trust to establish a record of wildlife using Stones Farm. If you have witnessed any types of birds, reptiles or mammals on the site we would like you to email debbie.salmon@kentwildlife.org.uk and provide as much information as you can, photographs would be very welcome.
Why not help and let the local media what you think
Just send a quick email to any one of the following: -
EKG - stephen.waite@krnmedia.co.uk
KM - hrobinson@thekmgroup.co.uk
Kent On Sunday - editorial@kosmedia.co.uk
Your Swale - yourswale@kosmedia.co.uk
BBC South East - southeasttoday@bbc.co.uk
Meridian - meridiantonight@itv.com
KM Radio - sfountain@thekmgroup.co.uk