Here are some extracted paragraphs….…….
As there is much in this Plan that was not included in the previous consultation version, we wish to make comments beyond the limitations specified for this stage of the consultation, and outside the strictures of the consultation portal.
The section of the plan which we are most concerned about is 6.8.8 and following, The Faversham Creek Neighbourhood Plan (FCNP). In its earlier consultation version in 2012, Bearing Fruits contained only a short reference to the then unwritten FCNP, and therefore this is the first opportunity to comment on this part of Bearing Fruits 2031.
We would like to remind you of the display box in Section 2, Taking a Journey Through Swale, entitled What’s in a Crest? Most of the nine points are relevant to Faversham, but two have a specific relevance to the importance of Faversham Creek:
Waves to signify ports, boat building and ancillary trades and, of course, The Swale.
Red lion/blue ship shows Faversham’s link to the Cinque Ports.
The FCNP seriously fails to address the importance of these specific points to the future of Faversham.
Statement 7 – Faversham Creek Neighbourhood Plan Vision
The Plan as it stands cannot deliver this vision, as it does nothing for the regeneration of the town; it focuses almost entirely on housing, with very little said about developing business, maritime or tourism uses.
6.8.10 – This paragraph relates to flood risk. Paragraph 4.3.100 also comments on the “challenge of climate change, flooding and coastal change … Around the developed areas of Faversham Creek, a flexible response to the issue of flood risk will be necessary to enable regeneration to take place.”
Firstly, the Faversham Creek Trust is horrified by the phrase “flexible response to the issue of flood risk”………….
The FCNP does not comply with Policy NP1 in the following ways.
It does not comply with the first sentence “priority will be given to the regeneration of Faversham Creek by retaining maritime activities (including the retention and improvement of wharves and moorings, including for large craft)”. We fully support this policy, and would like to see much greater focus given to it within FCNP.
It does not specify the “complementary redevelopment opportunities for workshops/ business uses”. Although some mention is made of these, there is nothing specific in it which enables the FCNP to comply with this sentence.
Policy 2 – it does not “provide for the restoration of and enhancement of the settings of listed and other important historic buildings”. In fact, it recommends the removal of at least one important historic building on Swan Quay, and the proposed density and size of development on this small site would do nothing to enhance the settings of the listed and important buildings on Swan Quay and Town Quay.
Policy 3 – It does little to protect open space and nature conservation interests…………..
The letter from English Heritage in response to the recent consultation on the FCNP makes clear the wide gulf between what could be done for the Creek area, and what the FCNP proposes should be done. This letter should alert SBC to the fact that very few statutory consultees responded to the earlier consultation stage of the FCNP, in May – June 2014. The reason given by English Heritage for their late response was that they had no record of receiving an invitation to respond to the previous consultation. It is quite possible that other statutory consultees also have no record of their invitation, perhaps because it was not sent to the appropriate person within the organisation. We believe that SBC should re-consult those organisations who have not responded, taking care to discover the correct person to approach.
In view of the responses which have been forthcoming for each stage of the consultation of the FCNP, and in particular the one from English Heritage, we feel there is a considerable risk that the FCNP will not be approved as it stands by the Independent Examiner. Even if it is passed to go to referendum, there is doubt whether it would pass a referendum.
In the event that the FCNP is not approved, what contingency plan does SBC have? Will Policy NP1 be used to determine planning applications, and what power will it provide SBC Planners to “retain maritime activities (including the retention and improvement of wharves and moorings, including for larger craft)”? Will the policy AAP2, which we understand is a “saved” policy, be relevant still? Will the policies outlined elsewhere in this plan be extended to cover the Creek area? There are many discrepancies between Policy NP1 and the FCNP as it now stands.
The Faversham Creek Trust would like to re-state that it supports Bearing Fruits 2031 in general, with the caveat that we endorse all the comments made by the Brents Community Association in their submission. However, we have grave concerns about the section of the Plan relating to the Faversham Creek Neighbourhood Plan, which we regard as a seriously flawed document, which does not represent the wishes and views of a significant number of people in Faversham. Many of them took the time to attend our Exhibition “Making the Creek Work for Faversham”, which we ran concurrently with the Faversham Town Council statutory consultation in May and June 2014. Over 840 people attended and over 460 completed our questionnaire.
We believe that this part of the Bearing Fruits 2031 is, in many ways, an improvement on the FCNP as it appears to place greater importance on maritime activities, but it may be ineffective in implementation terms without the FCNP, and SBC Planners may find it difficult to deal with planning applications if the FCNP is not ratified.