Question 25

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IF YOU DO NOTHING ELSE, ANSWER THIS QUESTION

This is where the Teynham/Lynsted area is, once again, mentioned as a potential ‘Area of Opportunity’.  It offers the alternative of allocating specific sites for housing now – or identifying a wider area to be developed via a masterplan, resulting in long-term uncertainty as the plans are developed.

If you responded to Reg 19, you could simply copy and paste your previous comments.  Your intro could say: I objected to the proposal for significant new housing in Lynsted/Teynham in response to the earlier Reg 19 exercise – my views have not changed so I repeat my objections here”. 

Remember to remove any mention of ‘TAO’, ‘Policy AO1’ etc as these are not included in the latest document.  

Alternatively, click on the subject headings below:

General comments

Teynham is singled out at paragraph 5.1.97.  Development continues to be proposed in what is inaccurately described as a ‘rural service centre’.  The ‘Teynham Area of Opportunity’ (TAO) first raised in Reg 19 remains in SBC’s thinking despite overwhelming opposition.  The only ‘concession’ appears to be an option to allocate specific sites rather than identify an ‘Area of Opportunity’ via a ‘Masterplan’.  We are sceptical of the promise of ‘significant input from and engagement with local communities’ given SBC’s lack of genuine engagement in the Local Plan process thus far.

SBC’s summary of Reg 19 feedback does not adequately reflect the strength of feeling against the draft Local Plan in general, and the Teynham Area of Opportunity (TAO) in particular.  In total 226 people commented on TAO, making 734 individual comments.  This means over 30% of ALL the comments across the entire Borough related to plans for Teynham and Lynsted.  Of these, 93% were clearly opposed to TAO.  Yet there is no mention of this in the Reg 19 feedback.

We already face out-of-scale developments approved for Teynham and Bapchild (as well as other rural villages).  Adding potentially over 1,000 more houses is completely unacceptable.  The proposed use of a Masterplan-led strategy continues to be completely ill-suited and damaging to the area.  The focus should be on preserving the identity of rural villages and their rich formal Heritage value.

The presence of AQMAs along this section of the A2 further argues against any form of additional housing in this area.

“Important Local Countryside Gaps” (ILCGs) have been identified between Teynham and Bapchild to the west and Teynham and Lynsted to the south due to the role these areas play in providing a sense of separation between the villages, to safeguard the open and undeveloped character of the land and to prevent coalescence.  Housing allocations in this area would result in precisely the sort of coalescence that ILCGs were intended to prevent.

Air Quality

The A2 between Lynsted and Teynham falls within an Air Quality Management Area (AQMA5).  It sits between AQMA3 and AQMA6 along the same road.  It’s the main link between Faversham and Sittingbourne, the two nearest and biggest commuter, service and shopping centres.  Given the apparent location of housing in options 1-4 (including the preferred option 3) the residents of any substantial new housing development would also depend heavily on cars, particularly in view of inadequate local rail and bus services. 

Commuting via the A2 onto the M2 and into London and other employment centres will greatly increase our congestion and already harmful levels of pollution.  Every new development that is trapped between Faversham and Sittingbourne adds to the harms we experience every day.

CPRE, KCC and Mid Kent Environmental Health frequently raise concerns about air quality within the local area in response to local planning applications, so the Council is aware of the cumulative impact that even smaller scale developments would have on local air quality.  The Council has no reliable evidence by way of air quality studies to suggest additional housing in Teynham/Lynsted can be tolerated. 

More housing between Faversham and Sittingbourne inevitably increases harms from higher levels of NO2 and Particulate Matter (PM2.5) on our doorsteps and in our bodies.  Worsening pollution has already led to another AQMA being declared at Keycol Hill last year.  SBC refuses to monitor and protect populations from accumulation of friction particles (PM2.5).  PMs will increase even as combustion engines are removed from our roads.

Poor air quality is inextricably linked to traffic issues.  Government Regulation (NPPF) makes clear that SBC must take account of the ‘cumulative impact’ of each development that adds vehicles to AQMAs.  The resulting harms to our health are being ignored by SBC.

Traffic

Any substantial housebuilding in Teynham/Lynsted adjacent to the A2 London Road would require a bypass through Lynsted.  We understand that Kent County Council’s submission in response to this proposal at Reg 19 raised major concerns regarding a link road to the South of Teynham.  There are no economic arguments to support such a bypass.

The Department for Transport’s most recent traffic counts for Teynham (2019) average around 14,000 vehicles per day along the A2.  Based on “Bearing Fruits” approvals already in the system, traffic is estimated to grow to 19,000 or more.  The appeal of using private motor vehicles to commute via the A2 has not been sufficiently considered by SBC. 

Traffic can quickly and suddenly become congested with the existing infrastructure within the area.  The narrow lanes are easily blocked by parked cars, deliveries, bus stops, HGVs, cyclists (often using pavements as a result) and agricultural vehicles.  New housing estates served by junctions, traffic lights and pedestrian crossings make the existing situation worse.  Further, the A2 frequently carries M2 traffic of all sizes in response to accidents and maintenance works.  These episodes cause serious congestion, noise and air pollution at any time of day or night.  Seasonal agricultural vehicles (harvesters, tractors and trailers) also reduce traffic flow.

Slow-moving traffic burns more fuel over a given distance and with less efficiency.  Friction particles from tyres, brakes and tarmac are released through repeated braking and acceleration.  The most harmful components are PM2.5 friction particles that are readily re-circulated and captured in narrowly built ‘canyons’ along the A2.  These are the size of particle that penetrate deeply into our organs, where they stay and cause damage.

Destruction of natural environment

Care needs to be taken to preserve, and enhance, the attraction and character of the open countryside within the Borough and particularly within the Teynham and Lynsted area.  Additional housing and the associated bypass would play havoc with the existing network of footpaths and the openness of views that are tourist attractions as well as being vital to local residents and the settings for our heritage assets.

The loss of Best Most Versatile (BMV) land must be properly considered and assessed.  The NPPF states that planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity and soils.  They should also recognise the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.

The dominant grading of agricultural land where both housing and/or a ‘movement corridor/bypass’ would be built in Teynham and Lynsted is Grade 1 (excellent).  The Fruit Belt, Best and Most Versatile (BMV) agricultural land is being threatened and cannot be restored or ‘mitigated’.  

Brownfield Sites

We cannot see any initiatives to build on brownfield sites.  SBC recently failed to bid for a share of the £58 million Government grant to develop brownfield land into housing, to protect countryside and green spaces.  Apparently, SBC does not have any brownfield site proposals sufficiently far advanced to put forward for funding.  Given the massive objections from residents to building on greenfield, this is astonishing. SBC simply didn’t try. 

Brownfield sites are available in the Borough, for example in Sheerness, the old Sittingbourne car parks, behind SBC’s offices, off Bell Road, in Queenborough etc.  As a Council that states it does not want to build on green spaces, why does SBC not have ‘shovel-ready’ brownfield sites and why are none indicated in the Reg 18 document?

There are just three mentions of brownfield in the entire document!

Water supply, quality and sewage

There are no concrete plans in place to address water supply and sewage.  Housing development worsens the incidence of effluent outflow at both Sittingbourne and Faversham.

Locating additional development in new, ill-prepared locations such as Teynham means they too will exceed their waste-water ‘tipping point’ leading to discharges into the Frognal Drain.  SBC has voiced concern over Southern Water’s mismanagement of water, on whom record fines were imposed in July 2021 following illegal discharges.  However, effluent dumping continues.  The significant number of new homes proposed will expand the built environment, creating the double negative of loss of natural landscapes (vital for mitigating against storm flooding) and the generation of yet more effluent. 

Water supply in Kent is subject to significant levels of stress and will continue to be in the future.  Climate change will bring greater weather extremes: flash flooding but also prolonged drought.  Swale experiences some of the lowest levels of precipitation nationally – this part of the South-East is drier than South Sudan.  Transfer of water from the Stour and Medway river catchments is already required to meet demand in Swale.  Will neighbouring catchments wish to, or even be able to, meet supply beyond their catchment in 25 years?  Water must be recognised as a constraint in the setting of a housing target and the creation of Local Plans.  There is a total absence of analysis of where the additional water supply would come from to support the Local Plan’s housing targets. 

Stop TAO

For further help or guidance on submitting your responses, please email: nigel@aqma5.co.uk

This website is published by the following local residents in Lynsted and Teynham: • Terry Hewett • Bruce Bell • Charlotte White • Paul Townson • Nigel Heriz-Smith • Dylan Winder

November 2021

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