Proposed Revisions to Draft Local Plan (Preferred Options)

Document Section 1. Preferred Options Revisions Section 3 - Revised Policy SP11 - Housing Provision Revised Policy SP11 - Housing Provision [View all comments on this section]
Comment ID 974
Respondent Scott [View all comments by this respondent]
Response Date 24 Mar 2017
Response Type OBJECT
What is the nature of this representation?
  • Object

The initial Strategic consultation in 2013 which fed into the 2015 draft local and is the basis for the 2017 local plan is out of date.

The information from the initial consultation which took place in 2013 has been used to form the back bone of the decisions in the Local Plan. Only a couple of hundred of people attended this consultation and the decsions they were asked to make are now well out of date. The participants of the initial consultation were asked to think about around 7 thousand houses for Thanet. Four years on, the OAHN has been calculated as 17,100 houses, meaning that this initial consultation for the housing allocation is now irrelevant. There therefore has been no proper consulation for the housing figure of 17,100.


People attending a consultation regarding 17,100 houses, if one took place before allocation were made, may have suggested that a new town should be built rather than the individual allocations bolt onto to existing towns. This could have saved large areas of agricultural land and also the distress caused by the adhoc bolt on allocations to towns and villages. Such a new town could have been competently planned with its own infrastructure and services and not added pressure to the existing individual towns. This is exactly what has been planned in Otterpool, Folkestone.

I suggest that the people of Thanet have not been consulted properly or in a timely manner to keep up with the large increases in the OAN that have been calculated in recent years. The plan needs to be totally re thought and the allocations on grade 1 agricultural land need to be drastically reduced.


I suggest that the people of Thanet should be given a proper consultation on the 17,100 houses and they should be asked if they would like a separate town or bolt on allocations.


The proposed number of people per household


If we divide the number of people projected to come to Thanet over the next 20 years (27.5k) by the number of houses planned (17,100) we have a ratio of people to households of 1.6, in other words only 1.6 people are predicted to live on average in each property. We suggest that this ratio is much too low.

If we have a ratio of 2.5, the objectively assessed housing need would be calculated at approximately 11000 households which would possibly be more acceptable to the general public. At just 2 people per household this would give us just 14000 houses.

Otterpool Park, a recently approved new development outside Folkestone includes proposals for 12000 houses for increase of 29000 in the population which shows a ratio of 2.4 persons per household and we feel that this ratio is much more appropriate for Thanet.

I propose that a ratio of at least 2 people per household should be used and therefore the reduction in the OAN should be removed from the strategic allocations on grade 1 and 2 farmland.

The impact of BREXIT on the housing number


As the arrangements for BREXIT become clearer there is likely to be a decrease in the number of people allowed into Britain from European countries, therefore the calculated OAHN is inaccurate and over inflated. Looking at the historical ONS figures, approximately 200 people per year come to Thanet that are in the “international migration” category. Likely a high percentage of these immigrants are European. If we suggest that 80% are from Europe this is approximately 160 people per year. If Brexit halves immigration from Europe then this would reduce the European immigration to Thanet to 80 people per year, which over 20 years is 1600 people. Using the TDCs ratio of 1.6 per household, this equates to 1000 house or units.

Based on this clear reasoning I propose that the 1000 houses should be removed from the allocations on agricultural land in Westgate-on-Sea.

It has been suggested by Adrian Verrell, Planning Manager of TDC, that if housing numbers were reduced due to BREXIT they would not be taken off of the “Strategic Housing sites” on the agricultural land.

The housing on the agricultural land should be removed first and foremost as the NPPF states that the best and most versatile land should be only be used as a last resort. If we remove the other allocations that are on brownfield sites only then this would break the rules of the NPPF.

The Proposed allocations ST1 and ST2


The Proposed allocations ST1 and ST2 in the Draft Local Plan are not proportionate to the existing built form and local services and should be withdrawn. Moreover it is now clear that the designation of the proposals may have been to provide contributions towards a new highway Route. The “Inner Circuit” requires development contributions which will not and, at the current time, cannot be financed by KCC - the strategic highway Authority.

Also , whilst outside Westgate-on-Sea, but within allocated site ST2 is the Dent-de-Lion medieval gatehouse. This monument is scheduled under the Ancient Monuments and Archaeological Areas Act 1979 as amended as it appears to the Secretary of State to be of national importance.

Government advice is that “All Scheduled Monuments are considered to be of national significance and are to be of material consideration when planning.” Dent De Lion is both a scheduled monument and  “The Gate House” is Grade II Listed.


I therefore propose that to develop on the land between Garlinge and Westgate should be resisted at all costs as it would have a seriously detrimental and adverse impact on the setting of a site containing a Scheduled Monument which has, to date, enjoyed an open, undeveloped aspect to the South.


The loss of significant open spaces and associated birds and wildlife undermining the sustainability section of the NPPF.


The in combination effect of such a large housing allocation in Thanet will impact the birds and wildlife of the area significantly.


I suggest that the Local Plan does not meet the criteria in the sustainability section of the NPPF and the level of building on the agricultural land should be reduced to conform with the Sustainability section of the NPPF.

Building on the best and most versatile agricultural land

Building on grade one and grade two agricultural land, or any agricultural land, is unacceptable. This is more so now than ever before. The Food and Agricultural Organisation for the United Nations (FAO) explains:

“ to provide for a (predicted worldwide) population of 9.7 billion in 2050, food production will need to increase from the current 8.4 billion tonnes to almost 13.5 billion tonnes a year”. FAO, 2017.

We will need much more food in the future and therefore building on our top quality farmland is a very short sighted method of planning for housing.

The FAO goes on to explain that:

“Eighty percent of the additional (food) required to meet demand in 2050 will need to come from land already under cultivation.”

In other words, we will need to make our agricultural land even more productive than it already is. This shows how ludicrous it is to build on this land under cultivation in Thanet.

We are totally against the building of houses on agricultural land as are many others in Thanet and the UK. We need to value and protect our precious commodity. As building on the soil will cause irreversible destruction of the farmland, when it is gone, it will be gone forever.

Trevor Mansfield of the UK Soil Association has written:

“We believe that high quality agricultural land should be preserved for growing and protected from development both now and in the future.  Good quality agricultural land is invaluable - It is the fundamental resource on which human life depends and protecting and improving the health of our soil is more important today than it ever has been.  In the UK it’s estimated that we lose 2 million tonnes of soil a year through erosion (see Defra’s 2009 Safeguarding Our Soils); yet it can take more than 500 years to generate an inch of soil. 

Soil stores 10 times more carbon than the forests.  Climate change will bring even greater challenges in the future, with increased pressure due to waterlogging and drying, affecting the productive capacity of soils”.

He points out that soil is the resource on which life depends and so protecting it is vitally important. He goes on to explain that it can take almost half a century to produce an inch of soil. How sad it would be to see our soils destroyed as if they were of no value, which is exactly what this council is proposing.

 Global Warming is a real issue that will affect us all. It is being caused by ever increasing amounts of carbon dioxide and other greenhouse gases in our atmosphere. Soils store large amounts of carbon and help with balancing our carbon cycle. Also, they assist with flood mitigation and it is clear that if we keep concreting over areas that were previously assisting water drainage, we will end up exacerbating floods, which will also increase with global warming. Not only is this dangerous and devastating to those affected, but the contribution of damaged soils to flooding events in the UK is estimated to be £233 million per year, with the total annual cost of flooding estimated to be £1 billion (POSTnote 484 in POST, 2015).

The Parliamentary Office of Science and Technology carried out research into the importance of soils in the UK and concluded:

“Around 95% of food production relies on soil. The global nature of the food system makes soil health (or quality) an international concern. Soils filter and store water, support agriculture and other plant and animal communities, and harbour a quarter of the world’s biodiversity”.

This investigation clearly states that soil quality is an international concern. How much more concerning is the destruction of soil due to the construction of housing estates. Not only do soils have a multifunctional purpose, but they also harbour a quarter of the world’s biodiversity.

The land at ST1 and ST2 in Westgate-on-Sea is grade 1 agricultural land and it has also had award winning crops grown on it as evidenced by a certificate received last year and copied below. Why would building on this land even be contemplated? People might question the sanity of those who thought this was a good idea whilst conducting the SHMA a few years ago, including Quex Estates themselves. The Linnington family has lovingly fertilized and nourished the soil, keeping the soil from eroding and decreasing in fertility, which has been the fate of many other soils across the world; Over half the world’s agricultural land is subject to soil erosion (POST, 2015). Destroying the soil now would undo all their hard work to sustain this precious resource.



The National Planning Policy Framework itself admits that the best and most versatile land (Grade 1-3 soils) “is the land which is most flexible, productive and efficient in response to inputs and which can best deliver food and non-food crops for future generations”. Protecting soil presents an opportunity to address simultaneously several global challenges such as food security, climate change, water security, waste management and biodiversity loss (POST, 2015).

Thanet District Council needs to remove the large areas of grade 1/2 agricultural land for housing in Thanet. We must protect and value this finite resource and build only the very smallest number of houses on the land. We need it for growing food in a world of ever increasing population and demand on food supplies as explained by the FAO and for mitigation against climate change as explained by Trevor Mansfield of the UK Soils Association. We urge the council to reconsider using agricultural land for its strategic sites in the proposed Local Plan and reduce the thousands of houses allocated for farmland to just a few hundred at most, if exceptionally necessary.

Hannah Scott

PhD soil science research, Natural Resources Institute, University of Greenwich.

BSc (hons) Environmental Sciences


Trevor Mansfield (2015) Private e mail ccommunication.

FAO (2017) Strategic work of FAO for Sustainable Food and Agriculture [Online] Available at

POST (2015) Securing UK Soil Health [Online] Available at: