In the previous edition of the Newsletter Richard Oades and I wrote about the “partial update” of Thanet District Council’s Local Plan, adopted in 2020, extending its timescale from 2031 to 2040, and the Society’s intention to respond to the consultation. The Society’s response was submitted in early February, and the full document is online.
Our main point was that the proposed update is indeed very “partial”: it almost completely ignores what we called the “elephant in the room”, namely, the issue of what is to happen to the Manston site. We don’t need to repeat what we have argued before other than to say that, whatever the final outcome of the Development Consent Order, currently on the desk of the Transport Secretary, it will have enormous repercussions for the Local Plan, and that we believe there is no case whatsoever for the retention of the designation of the site as “for aviation use”.
Since the UN Earth Summits in Rio de Janeiro (1992) and Johannesburg (2002), the latter of which I attended, the concept of “sustainable development” has become widely accepted in public policy. One of the excellent papers produced as part of the Update process, the Sustainability Appraisal (SA) Scoping Study, provides a set of 14 sustainable development Objectives against which plans and projects can be tested.
We have argued that, if the Local Plan continues to retain the aviation use designation for Manston, it will contravene a number of the objectives, including those on housing, health, air quality, mitigating climate change and particularly number 8, which emphasises the “re-use of previously developed land”. The Planning Inspectorate might therefore rule against the updated Plan on the grounds of lack of “soundness”, one of its key criteria for plan approval.
Our response also considered the Housing Needs discussion document, which indicated an annual requirement, up to 2040, of 1085 new dwellings per year for Thanet, or 21,700 in total, and a need for “affordable housing” (for rent and for purchase) of 548 dwellings per year. We pointed out that this would suggest an affordability requirement ratio of just over 50%, whereas TDC’s policy is for only a 30% affordable housing requirement. While we understand the difficulties faced by developers, it is essential that TDC adhere strictly to the 30% requirement and not allow off-site provision or financial contributions in lieu of on-site provision of much needed affordable housing unless there are exceptional circumstances.
We expressed concern about the scoring system which is to be used when evaluating different potential sites for new housing, which has a built-in bias to smaller sites, and fails to reward brownfield over greenfield sites. If TDC is to meet its housing targets, set by central government, and meet the sustainability objectives, it would make much more sense to plan for a comprehensive mixed-use redevelopment of the brownfield Manston site with 3,500 to 4,000 houses. This would relieve the pressure to develop small sites on agricultural land at the edge of Thanet’s villages, often very unpopular with the local population.
The Stone Hill Park planning application in 2018 (before political changes at TDC gave support to re-establishing aviation use for the Manston site) provides an “oven-ready” scheme for comprehensive redevelopment, including 3,600 homes.
Our other main point concerned papers dealing with retail, leisure and employment need, where we felt there was a surprising lack of focus on the importance to the local economy of tourism. About one in five jobs in Thanet are in the broadly defined tourism sector, and that proportion is likely to increase in the future: there was significant growth in visitor numbers prior to the Covid pandemic, which saw a big downturn, but they are likely to pick up sharply in the next decade.