Chilmington Green – sample letter of objection to the building development

Mock Lane, Chilmington – the future view
Chilmington Green Urban Extension Landscape and Visual Impact Assessment, Sept 2014. Turkington Martin

.View Sample of Objection here

Ashford Borough Council Revision to Local Plan

New housing numbers a done deal and the potential for even more housing

A report from Cllr Winston Michael, Ashford Independent

Every 5 years the Ashford Borough Local Plan has to go through a review and so the 2006 Local Plan known as the Core Strategy needs revision.

The current revision has resulted in Ashford Borough Council looking to add some 4000 homes to what remains undelivered in the 2006 Local Plan. With a 5-yearly revision and a Council with a voracious appetite for many more houses no matter what the consequences, residents continue to face unacceptable uncertainty about the countryside and their quality of life. Since 2011 Councillor Winston Michael has represented Ashford Independent Party on the Planning Task Group Committee during which time he has vehemently opposed more housing on the grounds of sustainability and an unsound stated need.

Ashford Strategic Housing Market Assessment (SHMA) conducted by consultants
G L Hearn proclaims a need for circa 720-730 homes per annum. This number is based on demographics and inward migration to Ashford, with 42% expected from natural resident growth and 58% to people relocating to Ashford, thought to be predominantly commuters. This implies only 306 homes are necessary to serve local natural population growth and economic growth.

The net inward migration figure is justified on the grounds of past relocations to Ashford but no analysis is given to support as to why people come to Ashford. Official reports point to the much lower cost of housing, fast train service to London, and available housing supply. Homes in and around London are very expensive and buying a home in Ashford releases equity and reduces mortgage payments for Londoners. The past large inward migration was certainly not through an economic boom in Ashford drawing in workers because business / employment figures do not support. To justify the 58% it is stated the National Planning Policy Framework (NPPF) would not allow a reduction in net inward migration but this is questionable.

The NPPF Guidance notes allow for adjustments to overall housing number where migration levels may be affected by changes in employment growth, a one-off large employer moving in or out of the area, or large housing development such as an urban extension in the previous five years, etc. In Ashford’s case an adjustment can be made since previous inward migration is distorted by high speed trains to London, lower house prices, and housing availability; and not because of increased economic activity. So a reduced inward migration figure can be supported.

In 2011 ABC commissioned G L Hearn to produce an Employment Options Report (EOR) with Cambridge Econometrics (CE) providing the data and modelling. The report projected growth scenarios from cautious to highly optimistic and the conclusion leaned toward medium growth. A handful of Councillors including Ashford Independent Councillor Winston Michael challenged because the data was suspect and the method to extrapolate statistics beyond 2021 (the Government statistics end date) to 2030 was questionable.

Following the EOR, ABC commissioned G L Hearn to produce the Ashford Strategic Housing Market Assessment (SHMA) as demanded by the NPPF. Since November 2013 when the headline numbers were revealed to Councillors, Ashford Independent Councillor Winston Michael sought details of the underlying data, and sight was given at the end of February 2014.

The SHMA dropped the previously agreed jobs led approach in favour of a demographic and migration approach. This statement appears to be contradictory since the SHMA uses the CE data model to make comparisons as a balance and check. The SHMA looked at similar scenarios to that of the EOR, introducing Government Sub-National Population Projections (SNNP) data into a G L Hearn model. The finding leaned toward SNPP data / G L Hearn modelling even though this is based on pre-census data, went no further than 2021, and required manual intervention to extend to 2030.

In the meantime CE had updated their data model in 2013 with the 2011 Census data and latest economic forecast. This later CE data model revised downward their previous projection for Ashford and the stated need was now 518 homes per annum. Amazingly G L Hearn settled on 726 homes per annum a number based on pre census data, and to justify this number comparison was made against the CE 735 homes per annum projection that was based on old data and not the new CE data model which came out with a need of 518 homes per annum. Needless to say Ashford Independent Councillor Winston Michael challenged the report’s inconsistencies and inaccuracies.

More recently G L Hearn decided to update their data model with 2011 Census data and this came out with a marginally higher housing number per annum.

In summary circa 730 homes per annum is the stated Ashford need but by removing the 58% for net inward migration 306 homes per annum is the demand for growth of local demographics and economy. The latest CE data model projection that Ashford needs 518 homes per annum is 212 homes more and is sufficient to cater for a reasonable level of migration. AI Councillor Winston Michael supports 518 homes per annum and as a lone voice voted against the higher number at the Planning Task Group meeting. Given the present Local Plan has 9700 homes that could be delivered during the planning period, 518 homes per annum represents a 19 year supply that takes us to 2030, so no further land is really necessary.

The overall housing number may be added to because of the NPPF duty to cooperate policy. This requires Ashford to provide for any land shortfall in housing need by surrounding districts. For example if Canterbury show a need for 20k homes but has land for only 15k then it can ask Ashford to provide land for 5k homes, and Ashford would need to provide evidence it is unable to service this need. Ashford call for land yielded over 200 site submissions containing in excess of 22k homes. The overall housing number circa 730 per annum equates to 13870 houses for the period 2011 to 2030 but within the current Local Plan 9700 of these houses could be delivered by 2030 and so Ashford has to find additional land for 4000 homes. With land submissions containing 22k homes and only 4000 homes required this could expose Ashford to the duty to cooperate. Already there is a shortfall at Hastings which has a remote possibility of hitting Ashford.

Ashford Independent Councillor Winston Michael thinks there may be a time bomb lurking in the Local Plan under the guise of “an area of strategic development”. At Council he sought an answer and is waiting a reply. The question is whether designating an area as strategic development would open it to more development than identified in the Local Plan and whether the designation makes it difficult to challenge. So the one to watch and fight are these designations because they could lead to further Chilmington Green time bombs.

Cllr Peter Davison, Leader Ashford Independent Party, comments:

Cllr Winston Michael is the Ashford Independent Party representative on the Ashford Borough Council Planning Task Group. The Manifesto of the AI Party, its election platform, seeks to protect our environment and ecology in the areas of natural beauty around Ashford and opposes large building developments on greenfield sites and urban extensions where there is no need for them and there is strong opposition from residents.