English Heritage’s Modifications to Creek Plan

FAVERSHAM TOWN COUNCIL TO DISCUSS
REVISED NEIGHBOURHOOD PLAN
TUESDAY 7 APRIL 2015 AT 7 PM IN THE GUILDHALL

The Faversham Creek Neighbourhood Plan has been revised by Swale Borough Council, to take into account concerns raised by English Heritage. Although these are being reported as ‘minor’ modifications, the revisions are contained in a 12 page document, and they affect 33 pages of the Plan. They can be read here http://tinyurl.com/pnml6xl , and they make very interesting reading. Some of the main points are summarised at the end of this email.

The agenda for Faversham Town Council’s meeting on Tuesday, 7 April (7 pm in the Guildhall) – you can find it here http://tinyurl.com/nehuwt5 – includes item number 9, “To receive and approve the recommendations of the Town Clerk’s Report (copy enclosed).

Item Number 8 of the Town Clerk’s Report (page 11 of the above document) reads as follows:

“FAVERSHAM CREEK NEIGHBOURHOOD PLAN: ENGLISH HERITAGE

Following discussions with English Heritage, the attached paper indicates minor amendments that can be accepted to the draft Neighbourhood Plan. The purpose of the attached is to reassure the Independent Examiner that English Heritage’s views, although submitted after the general consultation closed, have been considered and, where appropriate, taken into account. The Town Council, Swale Borough Council and the independent planning consultant, Richard Eastham have been in discussion with English Heritage and believe that the Plan, with those amendments, meets the basic conditions as required by independent examination as well as meeting English Heritage’s concerns. Are Members content for this to be presented as the Town Council’s final amendments to the Plan following the consultation as led by Swale Borough Council?”

We think it is very important for the people of Faversham to be involved in such  crucial decisions. If you are interested to hear what the Council are discussing, please come to this meeting on Tuesday evening. It is your last opportunity to question your Councillors before the Neighbourhood Plan goes to the Independent Examiner. Please arrive early – the doors may be closed to late comers.

WHY ARE WE NOT BEING TOLD?

Many people would expect something as important to the residents of Faversham as the Neighbourhood Plan to be shown as a specific item on the agenda for a meeting, and to have a proper discussion held about the amendments. Many would agree that the proposed amendments are not minor.

English Heritage has no record of having been consulted at the proper time (Regulation 14 stage, which took place in May and June 2014), which is why they submitted their document during the Regulation 16 stage (November and December 2014). The introduction to the document, or ‘Statement of Common Ground and Schedule of Minor Modifications 28.03.15’ recognises this fact (paragraphs 3 and 4).

WHAT DOES THE DOCUMENT SAY?

Evidence Base

On page 3 of this document, in the first major paragraph, it is stated that:

‘All sites allocated for development have been assessed initially through the Strategic Housing Land Availability Assessment 2011 conducted by Swale Borough Council, and in the Strategic Environmental Assessment (date) prepared for the plan by Swale Borough Council.’

FCT responded to the SHLAA 2011-12, requesting that all sites within the Faversham Creek Neighbourhood Plan area should be excluded from the SHLAA pending the Plan. The response that was given to every site was:

“The purpose of the SHLAA is to assess potential housing sites. It forms part of the evidence base which will be taken into account when preparing the Neighbourhood Plan (which will balance all interests and cumulative impacts)”

In the SHLAA 2012-13, in the site specific sections, the Neighbourhood Plan is referred to as ‘advocating employment-led regeneration.’

It is questionable whether the Neighbourhood Plan did balance all interests and cumulative impacts. It is questionable whether the Neighbourhood Plan does ‘advocate employment-led regeneration’.

A search of Swale’s website for the Strategic Environmental Assessment yields nothing. The fact that no date is given for it in this ‘Schedule of Minor Modifications’ may be indicative of its existence.

Members of the Steering Group and other interested parties have repeatedly requested this document, which should have been prepared at an early stage of the planning process, but it had not been written. They still have not received a copy. It could not have been used to assess the sites allocated for development, as at that time it did not exist, and at this time it is not in the public domain. This document should, legally, have been written at a much earlier stage, and should have been available to the Steering Group and the public before the Plan was written.

Summary of Changes

The amendments do make a very considerable difference to the Plan, especially to Ordnance Wharf and Swan Quay, and to matters concerning the conservation area, the archaeology and historical aspects of the sites, the views and design standards. Specific sites which are affected directly (although all are covered by the ‘Background Text and Scene Setting’ and the ‘Creek-Wide Policies’) are Site 2 Ordnance Wharf, Site 3 BMM Weston, Sites 4 and 5 Swan Quay / Frank and Whittome, Site 8 Standard Quay and Site 9 Standard House.

Notes on Policy Changes

The policies for Ordnance Wharf would make it considerably more difficult to build residential units on it, but still would not preclude them.

The policies for Swan Quay would make it more difficult for the proposed large blocks of flats to be built by the Quayside, but would allow some housing. They offer much more protection to the existing industrial buildings, the industrial nature of the site, and to the environment of the historic and listed buildings on and close to the site, but it may not be enough.

The policies for Standard Quay remove the use of Building No. 1 as a restaurant.

The policies for Standard House offer greater protection to its setting as a significant landmark on the Creek.

In summary, then, these changes do offer some, but not all, of what Faversham Creek Trust and others have been asking for all these years. However, they should be properly debated by a full Council Meeting in public, as a specific agenda item – they are too important to be subsumed into a vote on the Town Clerk’s words:

“Are Members content for this to be presented as the Town Council’s final amendments to the Plan following the consultation as led by Swale Borough Council?”

If you wish to show your interest and concern about these items, please come to this meeting next Tuesday, 7 April, at 7 pm in the Guildhall, if you possibly can.

 

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