FAVERSHAM CREEK NEIGHBOURHOOD PLAN
Hats off to Mark Gardner [Gardner Digs, Dec 13] for flagging up concerns about flood risk in relation to the Faversham Creek Neighbourhood Plan.
As we write this letter, Town Green is under water, the creek is lapping the town jetty and there’s a deep flood in Church Road – and this is not even an exceptionally high tide. If building on the creekside causes even the slightest increase in flooding levels, the consequences could be disastrous.
We have repeatedly raised the question of flood risk and flood defences, but we’ve had no response whatsoever. The subject is barely mentioned in the many consultations and reports on the future of the creekside, even though most of the land is designated by the Environment Agency as a flood risk area. It’s high time this was taken seriously.
Neighbourhood Plans must conform to the EU Strategic Environment Assessment (SEA) Directive. Any potential environmental impact should be screened by the local authority at an early stage, to determine whether an SEA is required. Has this been done? Have the flood risk implications been fully evaluated?
The letters from Councillors Cosgrove and Kay raise further concerns about the Neighbourhood Plan process. It does appear that, apart from the initial launch/exhibition in May, the plan is being drawn up behind closed doors by a small group of people who consult only those they choose, that the rest of us are expected to wait patiently and be grateful for any concessions squeezed out of landowners, and that dissenting opinion is not welcomed.
Community engagement is a legal requirement in the development of Neighbourhood Plans, yet the vast majority of Faversham residents have no idea what is being done in their name and with their money. Even those who take an active interest find it difficult to get information or to have any influence on the planning process.
Six months in, the steering group has not yet developed its community engagement strategy. The guidelines on Neighbourhood Plan development state that ‘properly engaging people from the beginning … ensures that there is an opportunity to influence the detail of the plan, rather than just having the option to accept or reject the whole plan … If the outcomes have already been determined, then community engagement is tokenistic (marketing)’ – yet the steering group minutes and the councillors’ letters strongly suggest that this is what they have in mind: waiting until the plan has been drawn up, then ‘selling’ it to us and trying to convince us to vote for it, whether we like it or not, on the grounds that the alternative will be worse.
The guidelines say that: ‘Community engagement should be undertaken before work commences … and throughout the process of plan preparation … It is important to publicise the proposals as widely as possible using different media … Feedback should be provided throughout the process.’
Prominent in the ‘what not to do’ guidelines are ‘consulting too late, placing a thick document on a stand in a library or on a website and expecting people to read it, or talking at people at a public meeting. Asking consultants to produce options before consulting the community is also poor practice. Consultation should not be treated as a one-off tick-box exercise … analysis of responses is not about counting the numbers, but considering the depth and range of responses.’
If people are not actively informed and involved, it’s no wonder that tempers are raised at meetings and angry letters are written to the newspapers. Instead of peevishly disparaging their critics, complaining about how difficult their job is, and expecting unquestioning support for whatever they’re doing (but not telling us what it is), our elected representatives should be seeking to engage with objectors and address their concerns.
This plan is supposed to be local democracy in action: it needs to be opened up to public scrutiny. Publishing in full the results of the May consultation would be a good start.
Chris Berry & Hilary Whelan – Upper Brents, Faversham