Question 6

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This is an important one to answer

The latest data from the Office for National Statistics (ONS) show the population for Swale in 2021 as 153,596.  The estimate for 2038 is 172,878 – an increase of 19,282 people.

The ‘housing requirement’ to 2038 in the Reg 18 document is 16,768 new dwellings.  That would suggest an occupancy level per dwelling of only 1.15 people.

According to the ONS, the average household size in Swale in 2038 is forecast to be 2.28 people – almost exactly double the figure relied on by SBC. 

A population growth of 19,282 would require 8,457 new dwellings.  SBC’s declared housing requirement between now and 2038 of 16,768 new dwellings is therefore DOUBLE the number of dwellings needed to accommodate local population growth.  SBC must challenge these numbers with Central Government as a matter of priority.

Furthermore, the 2018-based ONS data does not even consider the effect of Brexit, which has resulted in over a million fewer EU nationals living in the UK – a significant proportion of whom previously resided in the South-East. 

Urgent clarification should be sought following the Prime Minister’s speech at the Conservative Party Conference and subsequent statements by Michael Gove saying that future homes should not be built on ‘green fields’.  The Government’s Standard Method as applied in Swale’s housing need figure is incompatible with this stated aim and almost certainly out of date even before the ink dries.  It would be possible to build 300,000 houses on brownfield sites in the North and Midlands, but not in the South-East.  Potentially, this means that the target for new homes in Swale will be adjusted. 

SBC should assess housing numbers against genuine local need and deliverability, and then make the case for lower numbers.  There is real concern that houses are being built either for occupancy by people living outside the Borough or as investment opportunities for property speculators based as far afield as China.

SBC consistently states its resistance to over-development, blaming Government-imposed targets.  This would seem to be the perfect opportunity to challenge those targets.  SBC should seek an assurance that if the Local Plan is amended to release no greenfield sites, it will be legal and compliant under the indicated new planning proposals.

SBC must challenge these excessive allocations and the damage they will do.  Michael Gove has reiterated that local authorities can push back against central targets.

At least six local authorities including Welwyn Hatfield Borough Council, West Berkshire Council and Arun District Council have suspended progress on their Local Plan because of these imminent changes. 

Any reduction in required housing numbers for Kent would alter the spatial strategy for Swale.  What plans are in place to respond to such major changes without demanding another Reg 18 process at ratepayers’ expense?

The worst outcome would be for a disastrous Local Plan to be adopted in a hurry, only for non-retrospective legislation to be introduced banning construction on green spaces.  In other words, too late for Swale! 

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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