“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.