Proposed Revisions to Draft Local Plan (Preferred Options)

Comment ID 11423265/1/8408180/-
Document Section 2. Sustainability Appraisal (no name) [View all comments on this section]
Respondent John Repsch [View all comments by this respondent]
Response Date 16 Mar 2017
Do you consider the document is Legally Compliant?
Do you consider the document is Sound?
On which grounds do you consider the document unsound? (if applicable)


Table 1: SA Objectives

 Health, Safety and Security

Objective 2: "to maintain appropriate healthcare." But QEQM and Birchington surgery can't cope with current demands, let alone future ones.

 Objective 4: "To... reduce crime and fear of crime."  But it is strongly feared that the developments planned for Birchington are already attracting interest from London boroughs, and that thousands of homeless people and untrustworthy characters will be dumped in the area. Dumping has already happened in Westwood, where new people requested to be returned to London. 


Objective 7: "To increase levels of employment." But what about the reduction of employment opportunities on the fields because of mechanization and decreasing farmland? 

 Wealth Creation

Objective 8: "To... encourage industrial and employment development at key sites... to support priority regeneration areas." But are these sites brownfield or are they also grabbing farmland? 


Objective 9: "to protect and enhance the areas' natural landscape?" If that were the truth, planners would leave it alone. You don't enhance the landscape by covering it in tarmac and concrete.

  To "support the tourist economy" you need to think big. eg.

1.  Make Manston an occasional summer tourist attraction: Manston at War.

2,  Re-live Thanet's glorious history with a Margate Experience virtual reality project.

3.  Raise and rejuvenate a sunken wreck from the Goodwin Sands, along the lines of the Mary Rose.

 Built Environment

Objective 10: "to improve efficiency in land use."  Restoration of old buildings uses less CO2 greenhouse gas than building new ones. Let's use what we have got. (In England & Wales there are 600,000 empty properties.)  The Government's current desire is to make up for the so-called shortage of new housing developments by creating more rental properties. Can TDC not do the same and replace the number of dwellings earmarked for farmland with renting in already existing properties? This measure could be conducted alongside the recent Government recommendation that sole occupiers of large homes should be offered financial incentives to move to smaller homes.


Objective 15: "To provide a sustainable public transport network that reduces reliance on private vehicles."  But it is a fact of life that cars fill the road space they are allotted. Building new roads and widening others simply attracts more cars onto the roads and fewer passengers onto buses.

 Climate Change

Objective 18:  "Reduction of greenhouse gases."  Road-building; attracting more vehicles onto the roads; new-build instead of restoration of old-build are not the way to reduce greenhouse gases. 


Objective 19: Flood risk? Yes, exacerbated by TDC allowing home-owners to concrete/pave over their gardens, and people's fear of trees blocking light and forcing roots under foundations. And yet they soak up water and remove the risk of flooding.


Objective 20: "To conserve and enhance biodiversity." Building over wildlife habitats and rooting out hedgerows will conserve nothing but concrete.

 Energy Sources

Objective 22: "To reduce global, social and environmental impact." Instigate a congestion charge on vehicles inside town centres, and build no more homes with garage or parking spaces.

 Policy SP01

By hitching itself to the NPPF, the Local Plan is able to compare itself very favourably with "no policy options". How convenient. No doubt a policy that provides control is indeed preferable to a situation of uncontrolled development. But that doesn't give the Local Plan the authority to claim to be actually enhancing the environment or even claiming that its plans will be sustainable. 

 Policy SP02

I suspect that most of the job opportunities will be in building the developments, and thus transient.

 Policy SP04

A far better economic plan would be for Manston to rise again as an airport. Its achievements in freight alone were trumpeted at the Winter Gardens meeting on Feb 4. It could also be a major tourist attraction if days in the summer were set aside for the UK's only aerial dogfight displays. 

 Policy SP05

"Robust design... and... further studies relating to potential environmental impacts are likely to help mitigate these adverse effects." How can destruction of wildlife habitats, loss of prime farmland, noise and air pollution and increased risk of traffic accidents be mitigated?

 Policy SP06  Thanet's Town Centres

If the plan is to facilitate more shops in Westwood, Margate and others will be down to cafes, charity shops and estate agents.

 Policy SP07

Lack of foresight shown by over-zealous planners in encouraging more and more retail outlets has rendered the local road network inadequate.

 Policy SP08

Sounds ok but vague.

 Policy SP11

"Areas of new-build homes... may be perceived as being safer." They are scraping the barrel with this one. New-build areas are just as likely to be used as dumping grounds for suspicious characters.

 Policy SP14  Strategic housing site in Birchington

There is nothing beneficial in this policy. And it would probably be due to the encouragement of an increased population that there would be any benefit in building a new primary school. There is that totally inappropriate word 'mitigation' again. (Also see my response to SP05.)

 Policy SP20  Redevelopment in the Countryside

"The proposed policy is likely to have a beneficial effect on the majority of the SA objectives." What kind of policy for the countryside sees a benefit in its destruction?

 Policy SP21/22

Vague, groundless predictions.

 Policy SP23

"... provision of wildlife habitats." This is not so magnanimous when considering how many will be destroyed. 

 Policy SP24

Biodiversity enhancements: at the cost of biodiversity destructions.

 Policy SP25  European Sites, SSSIs, NNR. 

Do we have these in Thanet? I think the cliffs are an SSSI.

 Policy SP26  Protection of Open Space. 


 Policy SP28  Quality Development. 

My bet is that the proposed housing will be 3 - 4 storeys high and crammed together to fit more in, especially the 'affordable' ones. It will not blend in with the local area.

 Policy SP29  Conservation & Enhancement of Thanet's Historic Environment

"... is predicted as being likely to have positive effects..." No doubt means that if the effects turn out to be negative, the planners are off the hook.

 Policy SP30 Climate Change

The road currently running from Brook's End to Acol is located at sea level. I understand that housing is planned for both sides of it. Very risky.

  Housing design - eg. insulation - should reduce emissions of CO2, but the actual building of the housing will still be adding to global warming through producing and transporting the materials.

 Policy SP31  Healthy & Inclusive Communities

Everyone wants better healthcare, and it is currently being stretched to breaking point. Talking about enhancing services as though everything will then suddenly be all right is ludicrous. The extra-enhancing will be vital to the thousands of people descending on Thanet.

 Policy SP34  Safe & Sustainable Travel

"... seek to grow and enhance safe, sustainable methods of transport."  What methods: cycling, LPG, electric?

 Policy SP39  New Rail Station

"... likely to result in significant beneficial effects, particularly... employment..." I read that the station would be unmanned. If it is referring to the building of the station, that is just temporary employment. I also read that this extra station would only survive off other stations' passengers. I expect that the trains would be annoyingly loud, given the speed they would have to travel at. That would mean more urbanization.

 Policy E02  Home Working

This is good for getting vehicles off the road, but bad for the extra heating and lighting needed.

 Policy E05/E06  Sequential & Impact Test

If the planners want to stop large, new retailers weakening the market for those in town centres, they should prohibit any more being built at Westwood.

 Policy E08/E09  Self-catering Tourist Accommodation

"... accommodation that potentially may not contain residents that actively contribute to community..." That's what happens when towns like Margate are used as a dumping ground for non-British citizens and, theoretically, British and non-born British citizens, whose new home and lifestyle are significantly different from their previous ones.

 Policy E15  New build Development for Economic Development in the Rural Area

If the planners think this will bring benefits "whilst avoiding... traffic impact, visual and landscape effects and adverse effects on nature conservation", they are living in cloud cuckooland. More likely they are trying to pull the wool over our eyes.

 Policy E18  Best and Most Versatile Agricultural Land

They raise the subject and then say nothing about it. Thanet's soil has been described as being amongst the top fifth in Britain. It should be sacrosanct. And meanwhile the so-called "benefits for the protection of greenfield land" are being nibbled away like the Amazonian Rainforest.

 Policy H05  Rural Housing Need

"appropriate residential development... could be to the detriment of environmental sustainability." Surprise, surprise! And how much detriment will be wreaked by the wholesale over-development of Thanet?

 Policy H06  New Agricultural Dwellings 

".... effects on the built environment, landscape, heritage, ecology and the water environment are uncertain." These plus loss of choice farmland and inadequate infrastructure are all reasons to curtail development on greenfield sites. The planners also admit to "Potentially adverse effects... in terms of energy and resource consumption as well as waste generation..."

 Policy G01  Locally Designated Wildlife Sites

"...policy would undoubtedly enhance the protection of wildlife sites."  How is the rooting out of hedgerows and building on set-aside land going to protect it?

 Policy HE02  Development in Conservation Areas

"... to preserve and enhance sites, features and areas of historic archaeological... importance." So, builders prepare the foundations of a house and uncover archaeological remains, and they are not removed or destroyed; they are preserved. I don't believe a word of it.

 Policy CC01  Fluvial & Tidal Flooding

"... will aid flood mitigation efforts but potentially at the expense of local archaeological integrity." Then no housing should be built on floodplains.

 Policy SE08/SE09  Aircraft Noise

I understood that the majority of residents local to Manston Airport did not find aircraft noise unacceptable. This is in line with the fact that most, if not all, of them moved there in the full knowledge that airports produce aircraft noise.

 Policy SE10 Light Pollution

TDC have already shown their concern about light pollution by ignoring Thanet Earth, which is England's 2nd highest light polluter.

 Policy TP04  Public Transport

"The policy would... reduce the number of vehicles upon roads..." Probably by very little. Many people are wedded to their cars and would always prefer driving alone to sharing a bus with others.

 Policy TP09  Car parking provision at Westwood

A reduction in size of Westwood's current car parks would at last increase trade in the surrounding towns. 

 New Policy SPXX  Land at Manston Court Road/Haine Road

"Any new development of greenfield land is likely to have the potential for adverse effects against environmental objectives." This is worth repeating because it is common sense and undermines most of the proposals set out in this Local Plan.

 New Policy HOXX  Land at Manston Road/Shottendane Road

My reply as per SPXX.

What changes do you suggest to make the document legally compliant or sound?
Do you consider it necessary to participate at the oral part of the examination? No
Why do you feel it is necessary to participate at the oral part of the examination?
Officer's Response Not yet available.
Proposed Change