I am writing to you on behalf of Lynsted with Kingsdown Parish Council. We urge you to vote against the Swale Borough Local Plan Review at the Council Meeting on 3 February 2021. The proposal contained therein for building a bypass and over 1,400 new houses in Teynham & Lynsted Ward is unsound for the reasons summarised below.
1. There has been a total lack of consultation with Parish Councils on the proposed Local Plan. This plan, if progressed, would irrevocably change the characteristics of both Teynham and Lynsted Parishes. We believe that democratic and representative debate has been stifled throughout this process.
2. For the Local Plan Panel Meeting of 19th January, the idea of a “Southern Link Road” was buried in a dense 688 page report. By the time of the meeting of 26th January, this tome had grown to 972 pages. Previous discussion of a bypass took place on 29th October 2020 under item 223 of the Local Plan Review Site Selection. To residents and Parish Councils, this is burying of bad news, not democratic engagement. There was ample opportunity ahead of 29th October 2020 and again ahead of 19th January 2021 for SBC officials to explore local issues with the Parish Councils. They failed to do so.
3. The plan contains and repeats fundamental errors that, if left uncorrected, will mislead Council Members, Planning Inspectors and the Secretary of State. For example, reference is made to “a southern link road… taking the main through traffic away from Teynham high street” which would "divert traffic away from the central village centre of Teynham along the A2”. This section of road has NEVER been Teynham’s high street, nor is it the central village centre. The entire South side is in the very rural Lynsted with Kingsdown Parish, and the road forms the border between the villages of Teynham and Lynsted. It is of grave concern that SBC’s uninformed grasp of local geography and conditions on the ground has influenced its thinking. We urge SBC to re-visit all of the proposals contained in the documentation to ensure it is factually correct for all Parishes and Wards.
4. The Local Plan proposes building 305 homes and a bypass in and towards the 14th century village of Lynsted, on the most valuable agricultural land in the Borough. The bypass threatens to carve up the Parish, dividing the community. The housebuilding plan directly contravenes the Lynsted Parish Design Statement, adopted as policy by SBC, which identified a 'sensitive edge' South of the A2 with development limited to ‘one building deep’.
5. As part of its review of the Local Plan, SBC called on Parish Councils to put forward nominations for local green spaces. Two of the four sites nominated by LKPC - ‘Coffin Pathway’ and ’The Gallops’ - are likely to be devastated by the proposed bypass and/or housebuilding. The minutes of the Local Plan Panel meeting on 29 October 2020 state: “It had not been possible to review all the suggested new sites, due to time constraints and resources which had to be focused on the Local Plan Review”. It would therefore appear that SBC was pre-occupied with plans for a bypass, but failed to notice that its likely route was through two green spaces nominated by the Parish Council. The minutes also confirm that the designation of green spaces was intended to afford “significant protection for green areas which were of particular importance to local communities”.
6. There is already a serious air pollution problem in this area. Building a bypass and 1,405 new houses will only exacerbate this problem. New roads attract more traffic, even without new homes in the equation (CPRE Study). Under the terms of the latest National Planning Policy Framework and Guidelines, SBC is the body responsible for taking measures in its planning decisions to manage traffic in AQMAs, specifically to avoid “cumulative impacts” arising from several planning approvals. While we are concerned that SBC has completely misread the situation in AQMA5, the fact is that the combined effect of measures already taken and proposed will severely damage the populations (residents and workers) around East Street AQMA and Ospringe AQMA. The three AQMAs are linked by decisions to expand development to the east of Sittingbourne and west of Ospringe village. These concerns have been raised at Local Plan Panel meetings but a satisfactory response has not been forthcoming.
7. Particulate Matter (especially PM2.5) presents the greatest pollution threat to residents and workers. SBC only measures one of the dangerous pollutants (NOx) identified by Government - ignoring PM2.5, PM10, Ammonia and Volatile Organic Compounds. Even the measurement of NOx by SBC is flawed. Unreliable single diffusion tubes positioned far above head height (and in some instances missing completely) were used to measure exceedances until January 2019 when the error was acknowledged by SBC officials. SBC is relying on suspect air quality data to support the case for building a bypass. That will not in any event relieve AQMA5 because road pollution disperses widely, north and south depending on weather conditions, to approx 1km beyond the roadside.
8. Harm from absorbed PM2.5 particulates contributes to widespread organ damage - eg. glaucoma and macular degeneration, and damage to hearts, lungs, brains and other vital organs. Children are more vulnerable to damage and they experience denser pollution because they are shorter, and babies in buggies are closer still to tailpipes. SBC is therefore putting at risk the health of residents if they proceed with the building of a bypass.
9. The Government abandoned its algorithms of housing numbers last December and informed all local authorities that house-building targets will be re-assessed. The indication is that distribution of housing will be moved away from the South-East and into areas of investment in the Midlands and North of England. There is also emerging evidence that original calculations of housing need will have changed because of more flexible working patterns, growth of online business, vacant office space and the loss of 1.3 million Europeans in the UK - all because of Covid and Brexit. SBC is not responding to these seismic shifts in our socio-economic demands. Instead it is pressing on regardless, with unseemly haste, to build a very large number of new houses across the Borough - which could result in the revised housebuilding targets being exceeded!
10. The bypass and housing proposals are framed as a fictional “Teynham Area of Opportunity”. There is no clarification of what this actually means and there has been no consultation with, nor input from, the local community. This spurious smokescreen masks a change of direction by SBC against Government priorities that make clear housebuilding should be focussed on towns and cities, and brownfield sites.
11. SBC is proceeding to a Regulation 19 consultation with no agreed transport strategy. Can this be a sound plan with no identified route for the bypass, and no agreement from either KCC Highways or landowners?
12. A six week public consultation after the plan has been rubber-stamped is inadequate engagement with residents. It comes far too late in the process and is too short a period for a plan as complex and important as this. Because of Covid, there can be no public meetings and no viewing of paper plans at the Council’s offices or libraries. Lockdown limitations and postal delays make the delivery of informational literature difficult. The pandemic is being exploited to deliberately undermine or avoid democratic procedure. It is wholesale disenfranchisement of voters over a matter of Borough-wide importance.
13. It is not clear what action SBC will take after the proposed public consultation ends. We are concerned that SBC will parcel up resident/consultee comments and forward to the Planning Inspector without proper scrutiny or further consultation with all those raising objections - yet these are the functions and responsibility of SBC as the executive body.
14. There are numerous examples of Local Plans being rejected or withdrawn in 2020 - notably in St Albans, Uttleford, Wealden, Eastleigh and Warrington. Grounds cited by the Planning Inspector included: lack of consultation; excessive building in garden communities; destruction of unique heritage and landscape; failure in legal duty to co-operate with other bodies; process by which the chosen site was selected; failure to take into account the economic recession, Covid-19, emergence of new brownfield sites and climate change. We believe that SBC is at serious risk of the Local Plan being overturned on these and other grounds. This would be at a very high cost to ratepayers, for which Councillors would be accountable. Councillors are put on notice that this letter will form part of an audit trail.
In summary, the entire Local Plan should be put on hold until residents can fully engage. In the event that the Council votes the motion through, we reserve the right to take further action including, but not limited to, referral to the local government ombudsman on the grounds of maladministration and a call for a vote of no-confidence in Swale Borough Council.