USE THE STATEMENTS ON THIS PAGE IF YOU WANT TO COMMENT ON INDIVIDUAL PARAGRAPHS IN ADDITION TO POLICY AO1 ITSELF.
Again, just copy and paste – or use the statements as a starting point for your own comments.
Without any supporting evidence or analysis, SBC claims that Teynham not only supports existing needs locally – but could also support a massively out-of-scale development based on its asserted status as a ‘Rural Local Service Centre’. Teynham has declining retail facilities and inadequate education/healthcare provision. Public transport is infrequent and the nearby towns too distant for realistic modal shift to ‘active transport’ (ie. cycling).
This identifies an ‘Important Local Countryside Gap’ between Teynham and Lynsted. The bypass and houses south of the A2 would be built on this gap, resulting in the merging of settlements – not the preservation and retention of their individual characteristics.
The justification for an ‘area of opportunity’ is inadequately researched. The alleged ‘existing facilities’ in Teynham are insufficient for current need. ‘Rail connections’ run once an hour. The line is at capacity in terms of signalling and rolling stock, and there are just six parking spaces at Teynham station. More frequent, faster services are available at Sittingbourne and Faversham. So the vast majority of local residents drive to these towns for rail connections or access to shops and services – adding to traffic congestion and air pollution. The ‘evidence base’ should have been provided now, not at a later stage through a ‘masterplan’. There has been no ‘consultation’ to date with residents and businesses in Teynham – nor is it stated as being planned at all with households in Lynsted where 300+ homes and the bypass would be built.
The “masterplan” appears as a democratic instrument but with clearly defined ambitions already embedded for a radical and unjustified series of developments – housing, commercial space, bypass, conversion of cul-de-sacs into through-roads, some 5,000 more vehicle movements, and much increased pollution. The inclusion of this prejudicial and cynical device defines additional housing allocations without any supporting evidence of need or opportunity.
Air quality and transport modelling should have been included at this Reg19 stage. A2 junction improvements are undeliverable, constrained by listed buildings, absence of footpaths and narrowness of roads. Bus prioritisation is undeliverable, given their infrequency and unreliability. This Local Plan has come to Reg19 without a coherent Transport Strategy. It is stated as ‘currently in development’ but we understand with limited input from KCC Highways!
The TAO does not have the analytical and evidential base that should be in place before inclusion in this Local Plan. It commits SBC to a course of action that fails to meet the same tests of ‘soundness’ applied to the Local Plan as a whole. We understand that land availability has not been established, therefore the plan is not ‘deliverable’ in the timeframe. SBC refers to ‘meaningful community consultation’ as part of the Masterplan process. Their lack of consultation to date has eroded trust.
The TAO housing allocations depend on the delivery of a ‘southern link route’ which is an incorrect use of Supplementary Planning Guidance. The unspecified route would have no alternative but to drive across BMV agricultural land, close to listed buildings in a conservation area, and into the sensitive Lyn Valley nailbourne to rejoin the A2. No assessments of the impact of the bypass on landscape, local amenity and wildlife have been included. SBC argues the bypass will relieve the A2. This assumes all traffic will turn away from a direct route along the A2 to Sittingbourne, Faversham or the M2. Everyone would have to take the longer ‘scenic route’ through Lynsted parish on a daily basis. This is highly unlikely. A rural bypass simply attracts up to 40% more traffic [CPRE Study], before any new houses are built, which will spread a deeper and more widely spread cloud of harmful pollution along the corridor of the A2.
As the TAO and Policy AO1 are described as Supplementary Planning Guidance, the whole concept should have been explored outside the Local Plan, or addressed by the same tests as the Local Plan. Planning Inspector Guidance and the Planning Advisory Service state the document put out to consultation should be legal, consistent and accompanied by complete evidential support. The TAO is being consulted on with key policy documents and evidence missing or incomplete. SBC has demonstrated failure of process. The whole Plan has to be declared ‘unsound’ because SBC has tried to embed an untested, undeliverable bypass proposal tied to out-of-scale development allocations – with total disregard for the damage caused to local communities and a total lack of consultation.
For further help or guidance on submitting your responses, please email: firstname.lastname@example.org