The chair of the Society’s planning committee has worked hard to produce a common response from the Society to the Draft Local Plan, this needs to be submitted very soon so any further comments need to be received as soon as possible.
Relevant extracts from the CCC 2013 Draft Local Plan shown below in BOLD with the proposed Whitstable Society comments in normal text underneath. Only sections that we propose to comment on have been included and any policies relating to Whitstable not listed are not objected to.
The full CCC 2013 Draft Local Plan is a very large document which is available on the CCC website or in the library should you wish to view it in its entirety.
This copy contains a summarised version of our comments, but should you wish to see the planned WS responses in full, please contact us and we can arrange for a full copy to be given to you. Several responses will refer to a general comment on the sufficiency of infrastructure in the town. Some non-contentious responses may be added (eg nominations of additional Local Green Spaces).
Please note, we have to submit our response no later than 30th August 2013. Your comments and thoughts are therefore requested by the 28th August. Please contact us by phone or email prior to the 28th .
1.6 To help to realise the strategic vision, the draft Local Plan needs to make available appropriate land for necessary development and create the right conditions in terms of:Conditions for business – to start up, attract and retain new businesses;Conditions for visitors – to encourage them to visit, to stay and to spend;Conditions for residents – to improve quality of life whilst retaining our heritage and natural assets.
1.6 OBJECTING -Gives emphasis to tourism which has no logic in planning/economics. By comparison, education generates far more jobs and is non-seasonal; and yet it is not given special mention and actually is structurally complimentary in terms of roofs over head to the hospitality sector. These three do not match the Corporate Plan. Changes sought. Have a sensible split and if one is critical to only one part of the District, then say so even in the summary.
1.41 Both the City Council and County Council will work together through the planning process to facilitate the use of sustainable transport by: looking to locate development near existing transport hubs requiring facilities for walking, cycling andpublic transport and ensuring mixed-use developments where housing and employment are located in close proximity toencourage shorter commuting journeys.Environment Strategy
1.41 SUPPORT – Add fourth point. Locating housing land allocations near to where the jobs and growth are.
1.50 Within the context set by the NPPF, the Council considers that the following are key elements in a local definition ofsustainable development: -supporting the growth and diversification of the local economy;
1.50 OBJECTING -‘supporting the growth and diversification of the local economy. This is not a definition of sustainable development, local or otherwise. Indeed it can and often will be the contrary when resources/infrastructure are at their limit. In 1.49 it is correctly stated. Changes sought: Remove. Detail aspects of growth that need to be targeted to make it sustainable, for growth of itself is by definition not automatically sustainable or conducive to sustainability.
2.1 The Corporate Plan sets out the following pledge to meet the housing requirement up to 2031.Pledge 8 – we will plan for theright type and number of homes in the right place to create sustainable communities in the future
2.1 This is not an objection but rather pointing out a major omission re residential use of ‘mobile’ homes. These can effectively be used as permanent residential accommodation where there is permission for year round use. The same even applies to caravans. Existing mobile homes should be counted as part of the housing stock, but not allowed by their expansion to be part of it in the future given that they do not satisfy the requirements of the plan for housing. If they are in effect being used as resident accommodation this should be noted and their expansion resisted for then housing standards are being ignored.
Policy EMP11Developments within the Whitstable Harbour area as shown on the proposals maps will be granted planning permission if theyconform to the Whitstable Harbour strategic plan, to sustain a working harbour with an appropriate balance of operational uses,and non-operational uses that are compatible with the maintenance of the operational capability of the harbour, subject toappropriate design and access considerations. Proposals that would undermine this broad strategy will not normally be permitted.
EMP11 OBJECTING We support this, but there are such deficiencies in the para that we must oppose as it is. The authors of the plan seek to make the Harbour’s Strategic Plan a full planning document; as opposed to a restriction on Harbour Board decision making. There are various problems: 1) The summary of the Strategic Plan is so truncated as to be unclear. 2) The Strategic Plan is a non-planning document and has been produced by a Council Committee. A future Council may pack the Board and change the Strategic Plan to still be within the cursory summary and yet change various fundamental aspects of it without the due
process that changes to the Local Plan would require (eg consultations). Notwithstanding the summary, the reference to the Strategic Plan, as if it is a planning supplemental document, will mean that any new Strategic Plan would override the summary as the latter is so imprecise. Changes sought… The Local Plan policy should state each the objectives (set out below) of the Strategic Plan to get round the issues described above. [ we list all the objectives stated in the Strategic Plan for the harbour.].
4.55 An attractive and accessible public realm benefits visitor perceptions, assists the safe movement of pedestrians andimproves town centre vitality. A strategy will be developed for appropriate schemes that builds on the Council’s document titled:“Streets as Destinations: Canterbury City of Imagination Public Realm Strategy”.Options that may be explored include: Whitstable Harbour.
4.55 OBJECTING -This is a City policy with after thoughts not thought through. The harbour quays are not streets. Operational requirements impinge and have priority in most places. The edge of the basin is very dangerous and so for example, demand discouragement of night time activities. Changes sought:……Remove the harbour as such and in isolation from this section. Add Harbour Street as this is the main route from the Gorrell Tank car parking to the town.
Policy TCL11 Planning permission will normally be granted for proposals for new leisure and cultural activities and replacementand enhancement of existing facilities on allocated sites, in areas where there is an identified shortfall, or where facilities areprovided as part of joint-use community proposals. Major commercial leisure and cultural facilities serving the City or the coastaltowns should be located within or close to the town centre, or if this is not achievable, at other locations within the urban area that are highly accessible by all modes of transport, particularly public transport. Planning permission for change of useinvolving the loss of existing indoor sport, leisure and cultural facilities will only be granted where the applicant clearlydemonstrates that there is no longer a need for that facility and that there are sufficient similar facilities in the local area.
TCL11 OBJECTING- This policy is not written with regards to the infrastructural needs of Whitstable as set out in the attachment. Changes sought…. Ideally the policy should distinguish between development for local people and those for visitor or those from the suburbs in Whitstable. Tourist developments should be resisted until all the infrastructural issues affecting the town are certain of resolution. Public transport cannot be relied on for the centre as buses are delayed by the jams as visitors come in cars at certain times, this is made worse by trains from London having ten minutes added to their timetable due to HS 1 and the long walk from the station with no bus service or taxi rank, whilst Canterbury benefits from much shorter train times which discourage car use and a short walk to the centre. Until these infrastructural issues are resolved in Whitstable, development should be focussed on areas outside the centre on bus routes. Development that must be in the centre for use of local people must have sufficient parking spaces for users, as Whitstable suffers serious congestion and parking problems at certain times of the year.
5.7 Whitstable is a successful and thriving artistic coastal town which attracts many visitors.
5.7 OBJECTING. It is not an ‘artistic town’ such as St Ives. The number of artist in relation to the population is negligible. The main leisure activities for locals and visitors are varied and include activities typical of those associated with coastal towns including major water sports/recreation activities ( eg three yacht clubs). It will probably be easy to establish that the vast majority of visitors from outside and inside the district do not come because the town is “artistic” but rather the quaint centre of town and the unique (in SE England) beaches with no road to disturb their general tranquillity. Additionally the town is home to far more retirees than there were. Changes sought…… The misleading fallacy of artistic town as it stated in 5.7 must be removed from the plan or anywhere where it is stated. It is PR and not planning professional terminology and analysis. There is a clear danger that the local plan through such an official description, becomes part of the massive PR output related to this minority group. The draws that pull in such huge numbers of visitors can be easily listed. They include the quaint town, the beach and water craft activities, the restaurants and pubs and the general tranquil atmosphere
generated by the unique ( in Kent /Sussex) absence of a beach side road. Please also see comments on 5.8 which refer to 5.7 and 5.8
5.8 In contrast to Whitstable, Herne Bay does not suffer from high levels of congestion. Here the challenge is to revitalise thetown centre and reduce the need for residents to leave the town for services, leisure or retail opportunities by making the centrea pleasant and attractive environment for shoppers and visitors.
5.8 OBJECTING The plan needs to take cognisance of the fact that new commercial estates ( eg on the Old Thanet Way) can provide retail units in practice, with free parking, to further threaten the high streets. This refers to those units that do not require car use ( eg carpet warehouse) which can be on the high streets in either coastal town. For example, the tile warehouse could be replaced with a carpet warehouse to everyone’s benefit rather than just another seasonal tourist related development.
Changes sought…The plan should prevent developers of commercial centres, especially with frontage to the Thanet Way from permitting retail activity that does not need cars for the pick-up of goods. If possible this should affect existing sites not yet used for this purpose. To illustrate the point, the commercial unit proposed for the Paddock would have had frontage on the Thanet Way and may well be used now or later in our view as retail units further leading to the Thanet Way becoming a rival High St for the existing shopping centre of Herne Bay and Whitstable.
5.11 By 2016 more people will choose to travel sustainably, (for example by public transport) congestion will remain at 2011 levels and air quality will not have worsened. In order to meet this aim, we would expect to see progress on the following measures during the next five years: ……increasing the number of people using park and ride….. reviewing our parking strategy to increase car parking spaces at our park and ride sites…. reduce City centre parking spaces and set parkingcharges to influence travel choice….. ensuring new building development occurs in the right places to support broader traveloptions …….encouraging sustainable travel by supporting improvements to public transport, increasing cycling and walking routes.
OBJECTING
1) ‘ ensuring new building development occurs in the right places to support broader travel options’. This is not specific enough. For ex-ample the proposed houses in Whitstable from Devine Homes or any large development in Whitstable will not be supported by local jobs growth and will lead to increased car commuting to other towns.
2) The references to park and ride are misleading in the extreme. There is no northern park and ride provision in Canterbury despite promises for Whitstable, even though the extant local plan put so many facilities in Canterbury as well as reducing services in Whit-stable. We have to travel to get them and bus fares are too expensive for some families (financially non-sustainable). The decision has been taken not to build a park and ride for those in the N / NW but this fact is hidden here. There is a possibility that the same decision may have been taken for the Park and Ride in Whitstable. See infrastructure note which is an appendix.
3) This policy is improperly very City centric. Incredibly it states that City centre car parking space will be reduced with no reference to
Whitstable where we need more in the centre of Whitstable especially if there is no park and ride.
Changes sought…… Make this policy truly District wide or have separate sections, for example, for Whitstable. This plan should hon-estly address that there should be a park and ride for the people of Whitstable to alleviate the jams and help the triangle buses to run to time (as well as other purposes mentioned elsewhere) or state that there will not be one. it is in the hands of the Councillors whether there is one. Add ‘locating houses where the jobs are’ instead of what the 2003 plan did in locating houses away from the jobs so traffic commuting increased vastly as a result.
5.37 The improved high speed rail service to/from Canterbury is a big driver for change and prosperity and a modern, efficient,safe, punctual and reliable rail service is central to the transport objectives of the City Council. Most of the future plannedimprovements will be progressed by Network Rail and the rail operator under the new Integrated Kent Franchise but this LocalPlan will support further improvements at the District’s stations such as the implementation of Travel Plans and physicalenhancements.
5.37 OBJECTING Not so much objecting as making this section honest. The Plan needs, first and foremost, to put the train needs of the majority of citizens (i.e. those who live in the coastal towns) instead of just those in the City of Canterbury. Canterbury shop owners and rentiers benefit enormously from HS trains on a different line. The Council had plenty of time to discourage the HS services that added ten minutes to North Kent trains, but chose not to despite the 2003 plan encouraging sustainable travel. Changes sought. Please add: The deterioration of London services to and from the coastal towns caused by the HS service is a big driver for change to increase traffic jams in Whitstable, less cycle friendly roads and prosperity for some as commuting to high paid London jobs is discouraged’. Commitment is needed for the authorities to do everything possible to change the new HS trains to Faversham so the services to the north Kent coast can be restored (i.e. cut the ten minutes that was added) so the train can help make travel more sustainable.
Parking Strategy 5.38 There is little point promoting alternative forms of transport unless the demand for car parking is carefullymanaged and controlled. This Local Plan looks to balance the need for parking with the need to manage the useof the private car. This will be achieved through increasing car parking spaces at our park and ride sites, reducing the number of city centre parking spaces and setting parking charges to influence travel choice.
5.38 OBJECTING. As elsewhere, please be clear. Is this for the City or the District? If it is for the District, it is the wrong policy as it will encourage people to drive to the out of centre shops and other facilities with their free parking and no traffic queues. Despite being headlines as general parking strategy, it appears to be for the City only and it needs to be labelled as such. The reference to ‘This will be achieved through increasing car parking spaces at our park and ride sites’ makes it even worse if plans for park and ride for our side of Canterbury have been abandoned and it appears that there is hostility to a park and ride for Whitstable itself. Changes sought….Label as for the City only or add specific policy for Whitstable.
11.15 The National Planning Policy Framework states that ‘Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well being of communities’It also states that existing open spaces, sports and recreational buildings and land, including playing fields, should not be builton unless: an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus torequirements; or the loss resulting from the proposed development would be replaced by equivalent or better provision in termsof quantity and quality in a suitable location; or the development is for alternative sports and recreational provision, the needsfor which clearly outweigh the loss.
11.15 OBJECTING This is not a workable or appropriate policy in planning terms. The policy needs to be fleshed out in the plan and a clear ranking shown. For example a sports field can genuinely be replaced by another field. But a Local Green Space providing the ‘lung’ for an area of housing simply cannot be replaced by a site elsewhere. Changes sought…Flesh out to show ranking of green spaces which exist in practice especially with NPPF designations.
11.43 The only other significant amenity open spaces are Tankerton Slopes and Duncan Down which include a mix of semi natural areas and amenity open space In Whitstable there are three significant areas of recreational space,Cornwallis Circle, Columbia Avenue, and Westmeads Recreation Ground. However, the beach is also recognised as important amenity open space.
11.43 OBJECTING There are protected open spaces left out of this list which are of similar size and importance. Changes sought…Please put in Prospect Field and Westcliff Meadow.
11.61 In exceptional circumstances where development on protected existing open space cannot be avoided the developer willbe expected to provide compensatory accessible open space of comparable quality, size and character in the vicinity.
11.61 OBJECTING This should not apply to Local Green Spaces since there is no alternative suitable site by definition. Why are Local Green Spaces not differentiated in these detailed clauses and indeed not mentioned in this draft plan? They are clear in the NPPF -’76. Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them. By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances’. Changes sought…As mentioned elsewhere, OS8 and OS9 need to be combined due to overlap and confusion. The hurdles for development must not be linked with Local Green Space as they are not so linked in the NPPF. Alternatively and perhaps better, OS8 could be for open space other than Local Green Spaces and OS9 be for Local Green Space or vice versa.
11.66 Public Open Space Held in Trust Protection has been sought and granted under this scheme for the following sites:….. Tankerton slopes, Whitstable.
Tankerton slopes, Whitstable’ is incorrect: Changes sought It should be ‘Tankerton Slopes, excluding beach hut sites.
Tranquillity 10.16 Tranquillity is recognized as a powerful contributor to the sense of well-being of many people and is normallyassociated with natural areas, and with the absence of man-made disturbance. Seeking an escape from noise and stress in urbanareas is one of the main reasons for visits to the countryside.
10.16 SUPPORTING We appreciate this being recognised and in LB4 (The visual impact of built development or uses and any associated noise and light pollution can have a significant impact on the enjoyment of the tranquillity of our countryside, as well as its character. Policy LB4 includes tranquillity as one of the aspects of the landscapes in the District that should be protected and enhanced). HOWEVER, the tranquillity of Whitstable’s landscape (specifically use of its beaches/coast) has been damaged by a failure to correct an oversight in water craft control. The Whitstable and Herne Bay Safety Committee approved a proposal by the Whitstable Society to apply the inshore speed limit to all launch corridors for all craft not towing skiers. This will improve tranquillity, or rather reduce the damage to it, for Whitstable is unique in not having road noise and this is severely damaged by jet skis travelling /cavorting at maximum speed in areas next to the beach which have no speed limit due to the skier concession. The proposal has been blocked by Council staff and prevented from being discussed in the Council these last ten years. Changes sought….To maximise tranquillity, please action in the plan the proposal approved by the Whitstable and Herne Bay Safety Committee to apply the inshore speed limit to all areas next to the beach for all craft not actually towing skiers by stating this in the local plan; if necessary for Whitstable only which has a character completely different to Herne Bay; despite this being inadequately set out in this plan.
Policy TV2 Planning permission will be granted in or on the edge of town centres for proposals to provide new tourism development including hotels, guesthouses, bed and breakfast, self catering accommodation and new visitor attractions after consideration of the following criteria: The anticipated traffic generation and whether the location is readily accessible by a range of means of transport including walking and cycling and by public transport. The environmental and landscape considerations; The impact on neighbourhood amenities; The standard of design; The relationship to existing tourism development and whether the proposal is for the upgrading of those facilities; Whether the proposal will contribute to the diversification of tourist attractions in the District.
TV2 OBJECTING Not necessarily a fundamental objection but we find a little confusion/ambiguity. Where are boundaries drawn? Please define in more detail what tourism development is to be separated from other employment land use. Why is new tourist development (incl accommodation) separated from visitor accommodation? Is this a new policy for all visitor accommodation or just those with attractions? The logic of the list does not match that for other commercial development. There is no control of too many restaurants being built in a town centre yet the diversification hurdle below appears to be about protecting the commercial interests of existing operators. Changes sought. Define exactly what is covered and make consistent with polices for the town centres.
Touring and Static Caravan Tourist Sites
6.39 The Council will seek to protect existing touring and static caravan tourist sitesthat make a recognised contribution to attracting and retaining visitors to the District. An emphasis will be placed on encouraging sites to upgrade, renew and extend their offer to retain and grow their offer
6.39 OBJECTING ‘grow their offer’ is inappropriate terminology for a local plan document. It is not proper English and is vague. It could mean almost anything. How can we comment on something that cannot be understood? What is meant by static caravan parks? Does this include mobile homes for they are not dealt with elsewhere even when they have explicit permission to be used as residential accommodation? If so they must be dealt with separately as they are not for visitors. Changes sought….The policy needs to be segmented: touring caravans from static; the latter must be clearly differentiated from mobile homes and detail provided on how static caravans are prevented from becoming residential accommodation for the council elsewhere implies they will grant permission for caravan parks where homes would not be permitted and yet such vehicles can be used as homes. Unless there is a cast iron way of preventing residential use, all new caravan parks or extensions, including touring (if they can be converted to static sites with ease), should like mobile home sites be subject to the full requirements applied for new residential accommodation in the District. The easiest solution is to have a policy for touring caravan parks and one for the rest instead of being mixed up together.
Devine Homes 400 houses – SP3G
OBJECTING. Of the theoretically possible sites for new building in scale, we agree that the Devine Homes site is suitable in absolute planning terms and has the very significant advantage of giving the community, a large tract of private land to be made community space with village green status. However it is clear that the proposal suffers from two major disadvantages, not mentioned in the draft .
1) Introduction of significant extra traffic on the Millstrood Road / Grimshill / Belmont route which is the shortest route to the centre of the town from the new estate and cannot take more traffic.
2) Most of the land being given suffers from serious noise pollution from the Old Thanet Way which substantially devalues its trade-off value. Our support for focussing any new residential construction allocated to Whitstable on the Devine site is therefore subject to a few absolute conditions for development which can be satisfied in practice and be solved using justification from other elements of the Local Plan related to transport planning and the quality of open space. We therefore commend them (see below) to the inspector as local plan conditions for this named development and not just solutions that the community could only hope might otherwise be included in a development brief.
Changes sought….
1.A northern entry/access point is constructed and paid for by the developer. The infrastructure of the area is not fit to cope with the new traffic flows; especially given that the proposal is now for 400 rather than the 300 homes in the developer’s public consultation. The Millstrood Road / Grimshill Road/ Belmont Road route is the shortest access route to the town for the new estate but is at maximum capacity with the present parking arrangements; having had no improvement from the extant Local Plan despite the latter requiring/permitting massive expansion of housing as well as retail capacity to the immediate south. The route’s further jamming will cause serious harm to the viability of traffic management in the town. Therefore there must be an entry/exist point to the north of the new estate via St Luke’s Close (at its western end), in addition to that proposed via a roundabout on the Old Thanet Way. For much of the estate, traffic levels may be the same or even fall as diverted commuter journeys from the Grimshill estate offset extra journeys from the new estate to the town. We expect general support given that residents of the estate will have rapid access to the road system to the south of the town; with the benefit proportional to their distance to the new entry/exist point given the geography of the situation and offsetting the net increase in traffic to be expected closest to the new entry/exit point. Therefore, this critical new entry/exit should be conditional on there being no majority opposition to such a northern access from those on the most direct route through the Grimshill estate who are closest to it and also on the installation of residents-supported traffic calming / pedestrian protection measures, paid for by the developer.
2.That an earthen or similarly effective bund is constructed, before development starts, on the southern edge of the site, just behind the row of trees and bushes, so the land given to the public by the developer is of the high value implicit in the scheme; as described and promoted. At the present time the level of noise pollution from the road will render it far less than valuable for a wide variety of activities and potentially far less used. The example of the same problem at the Wraik Hill country park illustrates the issues. We are confident that if Devine Homes had built an estate on the land to be donated, such acoustic protection measures would have been put in place.
2.20 The total housing land supply is made up of a number of elements:
2.20 OBJECTING The stock and new supply of mobile homes is completely be ignored. They are as much part of the data to be considered as any conventional house as they are used permanently, require services / infrastructure / schools etc and have to go through the usual planning application process for residential development. Changes sought. Add in the number of mobile homes as well as static caravans effectively used for residential accommodation.
2.23 In order to meet this requirement the City Council has made a number of strategic allocations which are set out below.Whitstable Sites North of Thanet Way, Whitstable
2.23 OBJECTING The extant plan allocated huge numbers and a large proportion of new units to Whitstable. There has not been an increase in employment opportunities and the Council has not shown that there has been or will. It is clear that commuting to jobs from, but not to Whitstable have increased hugely in the last ten years as jobs growth is elsewhere. Allocations should be close to job growth. Extra houses do not generate jobs when road links are good as any economist can advise. No strategic residential allocations in Whitstable as there is no job growth. By contrast, locating tertiary campus with accommodation or community facilities such as a school might make sense given the unsustainable travel of children to grammar schools on the other side of Canterbury or Faversham. The local plan appears to have ignored those retiring. If there is a strategic development in Whitstable it should be for the huge demand for retirement accommodation which, on top of the demand for places near the sea from very well heeled Londoners, is driving house prices up faster than anywhere in the District. Any strategic development should be restricted to bungalows as any estate agent in Whitstable will tell the council that is where demand is away from the sea front vicinity. But it seems CCC have not looked at this in research.
Policy T5 Land identified on the Proposals Map at Faulkner’s Lane, Harbledown is safeguarded for additional/alternative capacityfor a Park & Ride site.
T5 OBJECTING Not honest; especially given the words of 1.39 which identified park and ride places needed but ignores traffic from the North of the District as if it suddenly does not exist and despite being provisioned for in the extant local plan: in fact it has risen. The park and ride for people from the North including Whitstable was promised in the extant local plan. This paragraph should state clearly that for the foreseeable plan it has been dropped; notwithstanding the remaining need for it. There is a clear planning inconsistency between planning for expansion of the other park and rides and the effective abandoning of this one. It is effective discrimination against people from this part of the District given how many services and functions the Council place in the City for those in the North to use. Park and ride policy is neither honest or consistent. Changes requested Be honest that the park and ride for people from the North has been abandoned for all practical purposes. Use some of the resources saved for a park and ride in Whitstable to help alleviate traffic and parking problems there.
Policy T9 The Council will require any future proposals for a park and ride at Whitstable to meet the criteria as set out below :Minimise the visual impact in respect of the location, layout and design of the development;Ensure that the development will not have a significant adverse effect on the amenity of local residents;Development which would materially harm scientific or nature conversation interests, either directly, indirectly or cumulatively ismitigated and any impacts can be adequately compensated; Any proposals will be expected to meet the aims of design policiesDBE3 & DBE13
T9 OBJECTING It is extraordinary that specific planning hurdles to jump are introduced. Development of a park and ride has to jump the usual hurdles of the planning process and local plan. Being a park and ride does not exempt it. Yet these specific provisions are brought in and amplified as the entirety of the policy; as if they are excuses for doing nothing. Indeed they are written as if it is a private commercial initiative like the marina instead of 100% council action as it would be. We interpret the whole policy as written to stop the excellent site recently put forward gaining traction or/and as an excuse to halt the park and ride budget spend for one in Whitstable or for Whitstable traffic at Harbledown so the other park and rides can be expanded; despite it having been policy to provide a park and ride. We believe excuses are being looked for to avoid spend. The only issue that can be noted is newts, and they can be successfully moved next door to
the massive and protected area of Duncan Down. No mention is made of the huge additional benefits of the site proposed; especially now that the Council is to sell off and close Tankerton car park. The park and ride can act as a coach park, for the town has trouble accommodating these and they are being directed to Herne Bay after dropping off and causing congestion in the High St. The site can host blood bank, the off season open air events like boot fairs and also act as an emergency assembly point. It can also act as additional parking for the hugely expanded Duncan Down public open space adjacent. The infrastructural issues are expanded upon in the attached note. Unnecessarily promoted conditions as the entirety of the park and ride policy for Whitstable in sharp contrast to that for Canterbury. Changes sought…. Remove discrimination against the site already identified and proposed in detail; making result no different to Canterbury park and rides which have no special list of requirements .
Policy T10 The City Council will apply Kent County Council’s residential parking standard IGN3 or any subsequent guidance. Forall other developments the City Council will apply SPG4 or subsequent guidance. Cycle parking, where provided, will beconvenient, secure, covered and where possible complemented by showering and changing facilities for cyclists.
T 10 OBJECTING The only specific re residential is to ‘IGN3’ which is not able to be found on the web sites of Canterbury and Kent Councils. the desultory reference we have picked up on the net seem to show a moving target with constant lobbying by large scale developers: for example asking for garages to be counted when they are too small for modern cars and can be turned into rooms with no planning issue http://meetings.eastkenthousing.org.uk/mgconvert2pdf.aspx?id=14109 . There is no document to show the extant IGN3 they are adopting!! How can the populace comment on this consultation? Why is there to be no variation even considered for special cases like Whitstable; the centre of which has suffered badly from so many infill and blocks of flats with insufficient parking provision or none, and contribute to the parking crisis in the town. SPG4 cannot be found either. But in searching for that we found http://www.shepway.gov.uk/moderngov/documents/s11756/rcoun20130731%20Appendix%208%20-TA%20parking%20table.pdf which indicates both guidance are for maximum standards with one parking unit for a three bedroom residence. With central guidance for maximum provision abolished, the council appear to be using out of date standard instead of creating one which meets the special needs for a town like Whitstable with poor public transport: unlike the City of Canterbury which is heavily provisioned and can stand a developer friendly parking standard for the centre. We charge that there is no policy in practice and that a specific one is needed critically for Whitstable due to its unique problems as set out in the attachment. The matter is urgent. Further spaces were lost at 5 High St due to the absence of a clear policy; which should have been devised when central guidance ceased. Changes sought…A parking policy for Whitstable that requires full parking provision for users/resident/visitors for all classes of development and re-development.
Policy OS8 Development which would involve the loss of open spaces and play areas within residential areas which contribute tothe visual or recreational amenity of the area will be refused.
OS 8 Objecting The policies of OS8 and 9 need to be combined and there needs to be a separate policy for Local Green Space (which is not included in this Local Plan). There is no logic to their separation of OS 8 and 9 . There is no sense also in giving long coverage to Fields in Trust when they have no more protection than protected open space under the NPPF and less in practice as the trustee is the council and it influences the Development Control officers that they employ. OS 8 is clear re protection of protected open spaces and uses the development hurdles of the NPPF which is correct, yet OS 9 uses wording from the old C24 that the Council via officer opinion have used to completely side step protection on council owned land that they wish to sell off at a profit (e.g. extending line of huts on Tankerton Slopes) or from a favored developer. Changes sought …Combine OS8 and OS9 or allocate one to protected open space and one for Local Green Spaces and make it clear that the hurdles do not apply in their standard form; in particular about substituting alternative open space. The NPPF requires development on Local Green Space only ‘in exceptional circumstance’s. Remove the special focus on Field in Trust whose protection if any over and above other protected open space comes via the trust deed. Feature NPPF hurdles for development as stated in OS8 and the best of any elements the hurdles C24 where they enhance protection.
Policy OS9 Proposals which would result in the loss of protected existing open space as shown on the Proposals Map (allInsets), will only be permitted if: There would be no material harm to the contribution the protected open space makes to thevisual or recreational amenity of the area; Where there would be material harm, this would be balanced against demonstrableneed for the development; There is no alternative site available to accommodate the proposed development, and any harm thatmight result from the development could be offset by the provision of other open space of comparable quality, size, characterand usability in the locality; The open space has been assessed by the Council as making no positive contribution to its overall strategy on open space.
OS 9 OBJECTING. See also all points made re OS8 please. This is the old wording for hurdles which in its fourth point ( The open space has been assessed by the Council as making no positive contribution to its overall strategy on open space) allows council officers to make weak subjective statements under the influences of the officers’ employer which often OWNS the LAND not backed up by any facts which any of the first three reasons would require. The development hurdles must not however, refer to Local Green Space, which a current ambiguity in OS8/9 might allow. LGS needs its own policy. For example, a developer cannot produce new space to replace local green space by definition, for then it is no longer local. The NPPF requires development on Local Green Space only in exceptional circumstances, echoing village greens which the government hope it will replace VG protection for new areas. The draft is remiss in not mentioning and detailing policy for Local Green Spaces which after all have special hurdles to be jumped for designation and hence should have higher protection, as stated by the NPPF. Because LGSs have not been mentioned in the draft specifically and applications invited for candidates (as can only be made easily at the time of draft plans, we request the inspector to allow LGS’ application to be made in the second public consultation and request CCC to check this out so the public know for the second consultation. The council should not rely on the public reading the NPPF to find out that LGS exist and applications have to be made in the local plan consultation. The council should ensure that LGS applications can be made in the second public consultation or any time before and make ways to do so (i.e. rather than having to ‘object’ to OS8 or 9 just to apply for an LGS).
11.50 The following Green Gaps are shown on the Proposals Map (see also Insets 1,3 and 5)Between the urban areas Canterbury& Tyler Hill, between Herne Bay & Whitstable, Canterbury & Sturry, Sturry & Hersden, Sturry& Broad Oak, Blean & Rough Common, Canterbury & Bridge
11.5 OBJECTING The Bogshole Valley is the Green Gap between Whitstable to half way down Clapham Hill and Blean and its northward leading ribbon development on the Canterbury to Whitstable road. The Bogshole Valley did not need to be declared a green gap in the last plan because it had specific landscape designation due to its visual amenity. The inspector acted to protect it re the proposal in the 2003 plan to extend a commercial estate into it and extend ribbon development on the flank of Clapham Hill. The area is the only significant green section left along the entire Canterbury Whitstable Rd due to ribbon development. It contains a stately home and the last remaining part of the the Whitstable Canterbury railway embankment (incl bridge) which is wooded. All over-spill from Whitstable over the lip of this valley can be seen for miles. With the landscape designation that was applied to the valley removed under the NPPF the Bogshole valley needs to be made a green gap to prevent coalescence of Whitstable and Blean, between the northern watershed and the ridge line of Pean Hill. The justification for this is also clear when the other green gaps are considered in our view. Changes sought Mark the Bogshole Valley from the Pean Hill ridge up to the valley’s northerly watershed as a Green Gap on the allocations map. If this area is not recognised as a green gap it should be as an AHLV.
4.52 Similarly Whitstable has limited retail capacity. As such significant additional out-of-town floor space should not be permitted.
4.52 OBJECTING All Whitstable shops need to be defined core or they will be lost under the new permitted right to convert then to residential. Changes sought… define the whole retail centre of Whitstable as core.
3.64 The Council also believes that there is a strong case to be made for grammar school provision at the coast. This not onlywould broaden educational provision, but could also reduce the volume of students travelling to other parts of the District, oroutside the District for schooling. The Council will work with KCC on possible options for such provision.
3.64 OBJECTING We support, but the environmental and time saving benefits of this are seriously underplayed. The benefits of the new grammar working with the existing secondary school at the coast are not even mentioned despite the fact that the Community College, Whitstable, for one, cannot even offer all major courses due to lack of resources. Changes sought…. Fully describe advantages and describe others such as joint working with coast schools.
Policy OS14 Permission will only be granted for development proposals that involve the loss of existing allotment land and/orcommunity garden land if both the following criteria are met :Demand for allotment land and/or community garden land within the locality no longer exists, or suitable alternative provision ofallotment land, of comparable quality, can be made available locally; and The allotment land or community garden land is notsuitable for, or not required to rectify any local shortages of, public outdoor playing space.
OS 14 OBJECTING Council beach hut sites should be included in this policy or a policy for them stated elsewhere. Beach huts use protected open space as do allotments and policy for both should be set down which maximises the use of that open space and ensures it is maintained so as not to look unattractive to the others once licensed or short leased to individuals. If not used or not maintained, consideration should be given for new users or failing that, having the huts on allotments or beach huts sites removed and returning the sites to public use. Changes sought.,.. Introduce a policy for publicly owned beach huts sites alongside or similar to, but separate to that for allotments, to ensure effective use and care for the sites.
Note on Infrastructure (attached to our responses)
Growth and Infrastructural Capacity
This is a response from the Whitstable Society relating to many elements of the Draft Canterbury Local Plan. The only major failing of the plan for Whitstable relates to the unalloyed commitment to expansion of tourists /visitor without a holistic plan. There was similar problem in the last local plan. Ironically, the proposal for a marina to the east of the harbour comes in for detailed restraint to ensure the infrastructure can cope (rather than planning for improvements of the infrastructure). By contrast the specifically identified Tile Warehouse site can be turned into a hotel and is likely to be approved even without enough spaces for the guests that might stay there. The imbalance in the quality of planning that should not be expected is illustrated by the minutia of support for visitor/tourists. For example there is an extraordinarily tough restriction on closing visitor accommodation in Whitstable apparently to encourage job creation in the current and last plan, yet it was left to the Whitstable Society in the last plan to ask for a restriction on turning offices into residential accommodation in the town centre; to preserve job locations of a sustainable nature ( ie that can be reached by walking and cycling.) As has always been the case, certain policies seem to be written for the City of Canterbury and Whitstable put under them unaltered for unthinking simplicity. For example , Whitstable needs more all year jobs and not the seasonal jobs that tourism provides directly and indirectly whereas Canterbury has non-seasonal jobs in excess of its working residents due in part to policy of focussing all colleges/universities in the City, and tourist jobs are filled by students/ temp residents. The difference with Whitstable is extreme yet not reflected in the plan. In the case of Whitstable, the visitor business is out of control. The underlying problem seems to lie is a failure to perceive the problem that visitor/tourist numbers above the capacity of the town can create. For example, we have no pedestrian High Street, so extra visitor cars on very narrow pavements endanger safety, as they do not in Canterbury and car parking capacity disappears for we have no park and ride as Canterbury has for visitors. Councilor Ashley Clark has also commented on this and there is no point is writing an alternative for the area he covers. ‘All this means that what the locals in the 60’s referred to as a “dump” with a population of 17,000 has now been transformed into a bustling town of some 35,000 with a huge number of visitors throughout the summer months and most weekends from February to November. The town bucks the national trend in terms of shop occupancy. The current trend for “staycations” should ensure the town’s continued popularity. Unfortunately all this has not been without a cost in terms of pollution and congestion with consequences for the quality of lives of local residents. The town is in danger of becoming a victim of its own success. In the long term this could reduce the popularity of the town itself and there are ramifications for the local economy. Over the years there has been little increase in car parking facilities (particularly over the last 10 years of popularity increase). Some areas have been lost entirely and others such as Tankerton Road (despite considerable opposition) are under consideration for sale and development. Roads into town are frequently choked with long queues of vehicles. The narrow Victorian streets suffer from pavement parking, obstruction to emergency vehicles and driveways and local people have difficulty in parking near to their homes. Traditional values of consideration have lost out to inner city habits meaning that parking now takes place anywhere without yellow lines and this includes arterial roads. This in turn causes further obstruction, pavement mounting and further damage to the town’s parlous footpaths. ‘ To this we add the following matters.
1) The pavements in the High St section nearest to the beach and in Harbour St cannot cope. They are often completely full, forcing people into the street. This is a major safety hazard which the local plans should have already addressed. This is made worse by an effective pedestrian crossing (one of the most heavily used by visitors), between Red Lion Lane and the Horsebridge which is on a blind bend.
2) There has been no attempt to stop the loss of car parking places in the town. Even in the draft plan there is no attempt to en¬sure that new residential and visitor developments development have adequate parking for all residents and visitor. It is the shocking fact that the current draft plan would permit the development site identified as the Tile Warehouse in Sea St to be used as, for example, a hotel, without sufficient parking places for those who come to stay, hence crowding out more local shoppers and residents.
3) Whitstable has a unique structure in the District of a restricted centre, with an alternative 100% car based ‘town centre’ on the Old Thanet Way with free parking always available. The economic activity based on visitors and the large number of second home owners is seasonal and gives a new seasonal distortion, not the town’s economy which did not exist before. Businesses that serve local needs are affected by this to their detriment because the usage of parking capacity in peak times by visitors and the intensity of traffic jams on the western approaches, sometimes up to the Thanet Way, drive local people who used to drive to the High St to go to the Thanet Way shops. To make matters worse this is habit forming as these potential shoppers do not know if there is a jam or parking space before they set off, so the easy option is not to bother and their custom is lost even in the off-season. This applies to the western part of the town . The eastern part is less affected.
4) The trains are useless for many visitors, so cars dominate and buses become crucial for more local visitors and locals. But the jams delay the buses, often severely.
We ask for an overall review of these problems and actions to address them: for example, a) All development in the town centre must provide parking space for residents/visitors /users so not extra burden is placed on ex¬isting parking facilities
b) The Council should actively seek out extra off road or on road spaces for the needs of the town and not just the needs of the res¬idents by the parking spaces.
c) A large park and ride with demand related extra bus service
d) Widening of narrow pavement in the centre.
e) Much better signage should be made so that any visitors know that the centre and eastern part of the town where most of the attraction lie and the biggest car park, can be reached by access via Church St or points further east on the Old Thanet Way or via Cromwell Rd if the visitor is already approaching the centre. Most importantly signs must also show the reverse guidance for those going home . Extraordinarily, there are no such signs at present.
f) All parking restrictions on the main routes must be examined holistically. The attempts are desultory. For example there is an infamous pinch paint outside The Peter Cushing Wetherspoon pub where parking is permitted despite there being a stretch of a few metres where the road is very narrow . Given how long these problems have existed, the length of time results have put in and the uses of central government grants, we must label the management of this aspect of infrastructure not competent and something the plan should address as a matter of structural urgency.
g) The same applies to cycling from the western and south of the town. For example the pedestrian railway crossing could be converted to permit cyclists to use it and it that way the ride into and back out of town would become safer and cycling encouraged
Any encouragement of the visitor economy should be conditional on these and other infrastructural requirements being committed to : ie guaranteed to happen.
Contact: mail@whitstablesociety.info
or telephone 077110 79369