This is the response to the Faversham Creek Neighbourhood Plan from Lady Dido Berkeley on behalf of the organisation Thamesbank:
Thamesbank has been fully involved with the River Thames and its ecosystem plans and planning policies for the last 15 years and during that time have realised that there are land plans and there are land/waterway plans, which fully respect our waterways.
The fundamental flaw of this Faversham plan that it is a land/housing plan – the subtle detail in the objectives & vision focussing on meeting housing targets on what is essentially river land or its vital bufferzone land in and on either side of this famous and beautiful creek.
The functions of the creek and waterway of Faversham Creek have not been effectively respected in the plan or any targets put in place to monitor the enhancement and protection of its key functions to sustain its maritime heritage for generations to come and to maintain the unique conservation for Faversham.
The Creek’s waterway linking Faversham with its vital Cinque Port connections and its importance to the rest of the River Thames, Henry VIII’s shipyard at Deptford etc., must not be ignored, or its internationally [important] maritime heritage and industry, which has helped England, through Faversham’s gunpowder, become the seafaring nation that it is today.
The key functions of a river, creek & waterway as defined for the River Thames and tributaries (Regional Planning Guidance for the River Thames , RPG3b9b 1996 – this may be old; the functions remain the same) are:
1. drainage and water supply
2 . landscape/ setting
3 . open space and ecological corridor
4 . transport
5 . leisure, recreation and tourism.
The River Thames has now has a Blue Ribbon Zone with its own policies and protection preventing inappropriate development with no river uses (attached is a doc explaining the need for waterway policies).
There are no “brownfield” sites along the very special Creek, this is a misnomer – they are “bluefield ” sites – previously encroached or land used for waterway/ marine uses. Housing is only appropriate after all riverside functions’ targets have been met and related to the rest of the River Thames.
Faversham Creek’s waterway, the creek bufferzone & functions need to be to be enhanced and possibly regenerated, not turned into a glorified housing estate, reducing the flood and floodplain capacity, reducing biodiversity and marine industry and bringing people in to LOOK at the creek instead of activating all the marine functions with OPEN space. 4/5 storey buildings which can be built in other places on land are totally inappropriate along this small, beautiful open space Creek.
The plan is neither “robust” – there is no credible evidence to show that the maritime heritage and industry of the area is respected with any priority over housing – nor is it “effective” as there are no marine targets related to the rest of the town and other sites along the River Thames (essential for the EIA) and therefore there is nothing to monitor. It will be essential to have identified what Faversham as a Cinque Port Town needs to retain and sustain its maritime heritage and facilities for future generations.
A specific waterway plan needs to be done first before considering what other essential are added long before any residential homes are put in.
There are 3 Strategies along the River Thames already and the Thames Heritage Alliance has written a waterway plan for the whole Thames (like the Bluebelt and the Blue Ribbon Zone of the London Plan), ensuring that maritime uses are prioritised.
Thamesbank has a meeting with the Minister Richard Benyon, SS for the Natural Environment, to ensure that the Waterways are targeted and monitored better and planning policy protecting the environment is properly implemented.
There is a great deal of evidence now showing that prioritising the environment actually enhances the economy and builds decent social communities – building the Cambria is an economic example of success, sustaining Faversham as well as the Creek and bringing the pride and community together.
Thamesbank greatly supports Arthur Percival’s submission.
We would be more than happy to help Faversham link further with the rest of the River Thames and estuary, as you already have the Thames Heritage Alliance, which Faversham is helping to look after the heritage of the whole River Thames.
We look forward to working together for our exciting maritime heritage.
Thamesbank. 5th July 2013.