English Heritage comments on the neighbourhood plan

“At present the draft neighbourhood plan requires a number of revisions to provide an appropriate guide to decision making with regard to the historic environment, and to fulfil the requirements of national policy and guidance and to conform with the District Council’s strategic policies.”

This is the conclusion of English Heritage, in its formal response to the latest consultation on the Faversham Creek Neighbourhood Plan.

In a nine-page letter, Robert Lloyd-Sweet (Historic Places Advisor, South East England) raises concerns about whether the plan meets the basic conditions set out in the Localism Act with regard to heritage. The letter says there has been no adequate assessment or analysis of the significance of heritage assets or sites of archaeological interest, or any positive strategy for their conservation and enjoyment, as required by the National Planning Policy Framework and Planning Practice Guidance. It points out that the entire plan lies within the Faversham Conservation Area and this in itself is a designated heritage asset, so everything within it that contributes positively to the special interest and character of the conservation area must be treated accordingly.

It adds that this “may not reside solely in the buildings and spaces, but may also result from the activities that traditionally were, and in some cases continue to be conducted within these. The loss of key employment sites that contribute to the viability of the area for a range of waterside industries, notably boat building, that contributes to the working character of the waterway and creekside, would represent a loss of significance of the conservation area as an historic focus for such activities and ultimately, a reason for the town’s existence.” It considers that residential development and the requirement for uncontrolled public access to the waterfront would interfere with such activities.

The letter identifies particular concerns with Ordnance Wharf, BMM Weston, Swan Quay, Standard Quay and Standard House. For Ordnance Wharf, it refers to the site’s “potential to contribute to the character of the conservation area as an area of maritime industrial activity, as well as the wider character of Faversham, including its small-scale historic character and maritime traditions” and says that different options should be considered: “The potential impacts of different land use allocations and scales and forms of development for this site should be considered to identify its optimum viable use, as part of the designated heritage asset.”

The National Planning Practice Guidance defines optimum viable use: “If there is only one viable use, that use is the optimum viable use. If there is a range of alternative viable uses, the optimum use is the one likely to cause the least harm to the significance of the asset, not just through necessary initial changes, but also as a result of subsequent wear and tear and likely future changes. The optimum viable use may not necessarily be the most profitable one.”

Concerns about BMM Weston relate the original house (now part of the offices) and the archaeological potential of the site, which is recorded as having been a Roman urnfield.

For Swan Quay, English Heritage has “serious reservations about the appropriateness of the development proposed” and considers that demolition of the open-sided shed “would be regarded as substantial harm to the conservation area and would not normally be expected to receive permission.” It also says the plan should not include a description of a specific development, as it does here.

For Standard Quay, the letter expresses surprise that the plan does not pay regard to the planning inspector’s reasons for refusal of the restaurant application for Building No 1, and does not identify any public benefits that would outweigh the harm to the character and appearance of the area that would be caused by proposed developments.

English Heritage says it would welcome dialogue to see how the plan might be amended to “provide an approach to planning for the neighbourhood that better aligns with national and local strategic planning policy, whilst delivering the aspirations of the local community.” It remains to be seen whether Swale Borough Council and Faversham Town Council will be willing to engage in such dialogue.

Cllr Nigel Kay, who chaired the neighbourhood plan steering group, is reported in the Faversham News (8 January) to be surprised at English Heritage’s comments at this stage, and complains that they should have responded to the previous consultation. (The Town Council says it wrote to English Heritage at that time, but English Heritage says it has no record of any such communication.)

Cllr Kay seems determined that the plan should go ahead regardless. He is quoted as saying “It is vital that this process is not delayed as the position is linked to the replacement of the Creek Bridge and that is now in need of urgent replacement.”

The logic of this is unclear, since the replacement of the bridge is being handled by a separate group, led by Kent County Council, which is unconnected with the neighbourhood plan. The plan itself, on page 13, distances itself from the matter, saying that, as a land use document, it has no authority to deliver an opening bridge.


7 thoughts on “English Heritage comments on the neighbourhood plan

  1. Sue Cooper

    It is appalling that the Steering Group have quite clearly not adequately consulted the organisations they should have done. It is bad enough that they ignored and side-lined local people who tried to make positive contributions to shape the plan in a positive, aspirational, achievable way. But they have clearly had one idea in their heads for some reason that was not going to be shaken by any amount of local lobbying. To ignore national bodies takes this to a whole new level.

    However, while I abhor the way the whole thing has been run and the resultant granting of inappropriate planning applications on Standard Quay and while I really am completely baffled as to why people who say they represent the people of Faversham can have ignored their electorate and shown such contempt for those who have put in a lot of work to argue very reasonably that the Plan was misguided, I would also like to say I am disgusted by the actions of anonymous people attempting to bully Councillors. To send anonymous letters to anyone, particularly those making unfounded allegations, is cowardly and ultimately totally counter-productive. Such actions serve only to make those who have made bad decisions cling to them even more firmly than before in the mistaken belief that be doing so they are standing up to bullies. These people do no favours to those of us who have put forward our ideas clearly and in public. If you have something to say, sign your name. Councillors have to and so should we.

    1. Griselda Mussett

      I agree with what Sue Cooper says in her second paragraph. I am very sad to read in the paper that councillors are receiving anonymous letters with ‘cash’ inside. I do not approve of it, and do not in any way condone it. I do not think that our councillors are corrupt or have taken bribes. However, I know that there are people in the community who do think that may have happened, and this nasty campaign is evidence of that.
      Standing for election as a representative of the people takes time, dedication, patience, generosity and a strong sense of responsibility – all our councillors have shown those qualities. Recent passionately-held beliefs about the future of the creekside have raised the emotional temperature, but sending anonymous letters is not the right way to express such feelings. What we have to do is debate the arguments, not make personal attacks.
      I have been very disappointed in the decisions made by the council regarding the creek’s future, and I disagree with those decisions, but making personal attacks on anybody is quite wrong.
      We still have so much work to do to regenerate our creek and our community, and we have to work together.

  2. David Walker

    Why do we listen to Councillor Kay? What authority does he have when the neighbourhead plan is supposed to be in the hands of the local populace? His only function is to assist the local populace to in the presentation of their plan NOT to produce his own! Its not a Councillor Kay plan its a part of the localism policy that government officials are supposed to be supporting.
    Why is Councillor Kay not up in front of the Judge and being asked to produce evidence of the “previous correspndence” …. as a failure of duty?
    Please let 2015 be a celebration of the success of common sense over the devious manipulations of some local dogsbodies.
    David Walker

  3. Griselda Mussett

    I am surprised that the Town Council (represented by Cllr Kay) is putting more importance on the ‘process’ of the Neighbourhood Plan, rather than looking at the content and implications of the English Heritage response. In the future, in fact for generations to come, no-one will care which month the EH response was received, but they will certainly care about the development decisions made as a result of the Plan.


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