‘Minor’ modifications to Neighbourhood Plan

The modifications to the Neighbourhood Plan which have been proposed in order to satisfy the concerns of English Heritage can be seen here.

With 12 pages of closely-typed amendments to 33 pages of the original plan, describing these as minor modifications does seem to be stretching the language a bit.

The first modification says “All sites allocated for development have been assessed initially through the Strategic Housing Land Availability Assessment 2011 conducted by Swale Borough Council, and the Strategic Environmental Assessment [date] prepared for the plan by Swale Borough Council.” This is a little mystifying, since no Strategic Environment Assessment has ever been seen, despite repeated requests for it – if it exists – to be made public.

An accompanying email says “Without prejudice to comments that Historic England might wish to make on individual development proposals that may come forward under the Neighbourhood Plan, I am happy to confirm that subject to the modifications being accepted the revised Neighbourhood Plan would address the concerns raised in our response to the consultation on the submission version of the plan dated 18th December 2014. As such, we would be happy to confirm that within the areas of interest to Historic England the plan would meet the basic conditions and would receive the support of Historic England.”

It should be noted that this does not necessarily mean that the plan would meet the basic conditions in any other respect.



5 thoughts on “‘Minor’ modifications to Neighbourhood Plan

  1. Sue Cooper

    I am sure you’ve told us this at some point but, given that the Kent Historic Towns Survey Archaeological Assessment referred to (undated) in this document actually seems to be dated 2004, can it then be assumed that 2008 is not too old for an SEA? ie will the apparently now discovered one be this one here (it looks like it thinks its an SEA) : (sorry would have made it a link, but couldn’t find how to do it!) http://www2.swale.gov.uk/media/adobepdf/l%2Fg%2FScoping_report_addendum_1_Faversham_AAP_v2_December_08_without_App.pdf )
    I must confess to not having read every single bit, but it didn’t look like a housebuilders charter, but what do I know? None of this makes any sense to me…

    1. Hilary Whelan

      Very interesting – where did you find this, Sue? It is not an SEA, it is a scoping report for an SEA (or SA – Sustainaibility Assessment), which lays out the parameters against which a development plan should be measured. It concludes by saying that the next step is to assess the various options put forward against these parameters, plus: Testing the plan objectives against the SA Framework; Developing and refining options; Predicting and assessing effects; Identification of mitigation measures; Developing monitoring proposals; Reporting the conclusions in a Sustainability Appraisal Report – in other words, that different options should be compared on the basis of how they meet environmental/sustainability criteria. It also says that the scoping report should be reviewed over time. There is no documentation to indicate that any of this was done at any stage during the development of the Neighbourhood Plan, and certainly there was no comparative assessment of alternative options, since the steering group refused to consider alternative options.

      1. Sue Cooper

        From this Swale ‘scoping’ document for a Strategic Environmental Assessment (SEA) – which has been through consultation (so it says). The following (and other statements) seem to strengthen the protection awarded by the 2008 AAP2 for Faversham Creek and to be totally at odds with what the Steering Group subsequently did with the Neighbourhood Plan. The Conservation Area Appraisal is the 2004 one which we have been led to believe was ‘out of date’ (at least tacitly, given that it has been effectively totally ignored). The Appraisal says of Standard Quay: “Consequently the quay is characterised by the traditional sounds and smells of waterside activities: of timber being sawn and shaped, of ironwork being fashioned and repaired, of the smell of varnish and paint, and also the aroma of old ropes and Stockholm tar.”

        It is notable that English Heritage have got the reference to smells and sounds re-incorporated into the Neighbourhood Plan. When I spoke against the Baltic House application I mentioned the smells and sounds – to me these are important and irreplaceable. I can go anywhere any time and sniff the stink of extractor fans from kitchens combined with car exhaust fumes; listen to the sound of cooling petrol engines and slamming car doors; dodge around gleaming parked cars.

        I do not understand how anyone can justify replacing what used to be on Standard Quay so recently with these commonplace and unattractive sights and smells. I realise of course that is not the intention. But when something really fits its environment like the SQ boatyard did then everything that goes with it is just quite simply right and fitting.

        When I mentioned them at the planning meeting for Baltic House, the comment was somewhat rubbished by Cllr Henderson – which i think was a shame. I probably hadn’t expressed it well (it is difficult in 3 minutes) but I am really heartened that English Heritage have put it back.

        This 2008 scoping report seems to me to be strengthening not weakening the protection for the Creek as we want it for tourism, employment, community. I guess this is why it has been buried.

        A couple of extracts from the Key Messages for the AAP:
        “Faversham Conservation Area Appraisal demonstrates the importance of the historic environment of the creekside area, and specific features to be preserved and enhanced.
        “The town is awarded conservation importance in the Kent and Medway Structure Plan and in the Swale Borough Local Plan, which generally aim for small scale, organic growth for the town. Policy SW1 of the Kent and Medway Structure Plan states that historic
        conservation is of “prime consideration” at Faversham and that “peripheral growth… for residential development is not envisaged. The policy also states that employment development should consider scale in context of the historic environment. Policy AAP1 of
        the Swale Borough Local Plan aims in part to “conserve and enhance the architectural
        and historic fabric of the centre”.
        The cultural heritage document review emphasises the need to promote the high protection of the borough’s townscapes and to provide protection to all aspects of the historic environment including archaeological remains. Growth should be small-scale and organic. These messages should be clearly reflected in the AAP and in objectives developed for undertaking the SA.

  2. Caroline

    Hi Visions, is there any mileage in a Freedom of Information request for the “Strategic Environment Assessment” ? If they have one they would need to release it under an FOI request or provide you with a very good reason why not.


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