STATEMENTS TO MAKE IN THE “YOUR COMMENTS” SECTION
SBC made an undertaking it would follow the early Regulation 18 (2018 ‘Looking Ahead’) consultation with a second, Regulation 18b (‘Issues and Options’) consultation. This second stage of community involvement would also be supported by documented analysis and ‘proportionate’ evidence. That promise was also indicated in SBC’s Statement of Community Involvement.
But, in 2020, everything changed. SBC decided it would be ‘legal’ to ignore community involvement and proceed straight to a Regulation 19 (final publication) consultation. The evidence base is incomplete and we are denied any influence over key decisions like the surprise announcement of the TAO. When KCC Highways and SBC Environmental Officers commented on a significantly smaller development of 86 homes off Lynsted Lane, they recommended against it on traffic congestion and air quality grounds.
The concept of an Area of Opportunity was never declared under the Regulation 18 consultation, thus singling out the parishes of Teynham & Lynsted for a treatment that has not been applied to other areas of the Borough. It’s an untested and undemocratic approach lacking the analysis or the rigour of strategic thinking required to bring forward such a proposal and to allow those now being consulted on it to fully understand and respond to its implications. No attempt was made by SBC to consult with the two affected Parish Councils, citing ‘lack of resources’ as an excuse. Introducing the TAO at this very late stage is clearly unfair, undermines the fundamental principles of engaging with the local community in the development of the Local Plan and is totally unreasonable given the effects the TAO would have on the locality.
We understand that KCC Highways have already stated that the additional housing at Teynham is “potentially the worst location in terms of traffic impact”.
We currently suffer from 14,000 vehicles daily along London Road. The combination of existing allocations in Bapchild (600), Teynham (430 + 26,840sqm commercial/light industrial) and Ospringe (300) plus the proposed TAO (1,100) makes for 2,430 more homes along a road that is already beyond its “service rate” (capacity). That means about 4,250 new cars/vans in this rural setting. A conservative estimate suggests new traffic movements along the A2 between Ospringe, Teynham and Sittingbourne of 8,500. Thereby increasing traffic through three AQMAs to 22,500 vehicles – that is 60% more than today.
Yet there has been no traffic modelling; no air quality modelling; no attempt to apply meaningful continuous tests of the four harmful pollutants at the heart of Government policy on the environment; no mention of the 25 years of brickearth extraction from Barrow Green Farm immediately east of Teynham; no assessment of the impact on the landscape or local bio-diversity.
This plan is not consistent with policies in the National Planning Policy Framework (NPPF). Firstly, the importance of building on Lower Grade land, not Best Most Versatile land that forms the Fruit Belt immediately south of the A2. Secondly, the NPPF requires plans to identify land for development to meet housing needs over the plan period. That has not been done.
The TAO is unsupportable in terms of its location; access to facilities and employment; destruction of BMV land; fracturing of sensitive rural communities; and legal constraints (NPPF) governing the cumulative impact of pollution on health in AQMAs.
A key element to a ‘sound’ plan is that it takes into account the reasonable alternatives, based on proportionate evidence. The Plan is not justified because there is no evidence demonstrating the TAO has been assessed against alternative schemes. It appears to have been pre-determined by SBC and then post-rationalised by the promise of some future ‘masterplan’.
The whole process has been hidden from sight behind a bureaucratic smoke screen. Democratic engagement has been abandoned. This smoke screen includes: initially hiding the policies in SBC’s impenetrable and dysfunctional website; lack of a robust communications strategy (until residents protested); incomplete evidence base; misdirection on addressing Reg19 responses (conflicting advice from officers on the ability to influence change); and misdirection on the sustainability of ‘Teynham’ as a Rural Local Service Centre.
At a residents meeting, the Cabinet Member for Planning threatened us with 600 new houses if the TAO were to fall – without supporting evidence of need, sustainability or suitability. This is bullying.
COMMENTS TO MAKE IN THE “CHANGES SOUGHT” SECTION
I request the complete removal from the Local Plan of the Teynham Area of Opportunity (TAO) and Policy AO1. It is uninformed by community/parish council involvement. It is severely damaging to the AQMAs in Ospringe, Teynham/Lynsted, Bapchild and East Street. It is a product of secretive behaviour and misdirection by SBC Councillors and Officials. There has been no sustainability appraisal that meets the relevant requirements. It is an inappropriate use of Supplementary Planning Guidance to make housing allocations subject to a lesser test than is applied to any other kind of allocation. It only offers a future ‘masterplan’ as a means of deciding how the development will be achieved as opposed to whether it should exist at all. This is an abuse of administrative process by SBC. The TAO and Policy AO1 render the whole Local Plan ‘unsound’. Rather than waste further public money and time by pushing forward to examination, the Plan should be withdrawn now and a fresh Reg18 consultation prepared once the requisite evidence has been produced.
Once you’ve submitted your views on Policy AO1 (Teynham Area of Opportunity)… If you now wish to comment on the individual paragraphs that explain how they’ve arrived at this policy, then please click on the link below