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Westgate-on-Sea Town Council

Proposed 2000 Houses Development

Land at Westgate on Sea Community Exhibition

These are the exhibition boards from the Community Exhibition held on Thursday 7th November at St Augustine's, they give information in relation to the proposed settlement extension which is at the community planning stage.  The exhibition was facilitated by JTP Architects on behalf of Millwood Designer Homes Ltd.

https://www.jtp.co.uk/projects/westgate

CPRE Kent Commentary on JPL “Consultation” NEW HOUSING at Westgate Garlinge

PART 1 OPENING  COMMENTARY on THE November 2019  “CONSULTATION”
CPRE are disappointed that the exhibition on Thursday 7th November  was essentially a set of layout proposals prepared by JTP showing Millwoods as the Clients approach to providing housing on the site.As an opening commentary the Consultation  The thinking behind the scheme is woefully premature given that the final submissions by TDC to the Planning Inspectors appointed to the Local Plan were only submitted in early October and we still await an outcome which will indicate whether the Draft Local Plan is anywhere near acceptable .( CPRE are extremely concerned with the potential loss of High Quality Agricultural Land  At the Draft Local Plan Examination session Thanet District Council agreed an amendment to the Draft Local Plan to the effect  that prime agricultural land should only be developed as a last resort.see

The outlook of the staff and the presentation of the displays at the exhibition were outdated and  exactly the antiquated approach described criticised and  and condemned by CABE in 2004.and by RIBA more recently (see below)

“The traditional view of masterplanning was of a ‘blueprint’ setting out rigidly how to develop an area”(.CABE 2004)

The focus of the current planning system is skewed in favour of increasing housing numbers at the expense of good design and creating sustainable, liveable places. This has inevitably perpetuated an environment of resentment towards development among local residents. Communities feeling locked out of the decision-making process is symptomatic of the wider problem where development comes forward only in the context of numbers of homes supplied

RIBA “Ten Characteristics of Places where People want to Live“” .

To see this approach deployed by JTP at the very first consultation with the public we find (and members of the public have stated that their views confirm that it was ) arrogant and condescending and augurs badly for an acceptable approach the future planning of this or any other proposed development

We consider that you as JTP “Masterplanners” for the   developers  involved in the establishment  of a Development Framework/Outline Scoping for the site should be doing so in accordance with  advice from RIBA and other scources and  the  masterplan should “ be clear about what you are trying to achieve at different stages and the outputs, advice and decisions you need to help you proceed to the next stage”. at this stage of concept development the exhibition we would have expected you to have   provided and explained  

  • An explanation  the spatial vision and development objectives for the area a 
  • An explanation of how the development would be complementing the Local Plan allocations/spatial strategy and vision;
  • the broad distribution of different types of development across the site
  • the approach to  providing  a high level overarching framework to ensure that planning and delivery of development and infrastructure would be is properly coordinated, distributed and timed across the Masterplan area
  • Your approach/ rationale and structure for the Site’s planning and delivery as a comprehensive development;particularly how it is intended to  incorporate ‘placemaking principles and guidance’ for all  individual phases of development;
  •  Setting out how  the key planning issues will be  considered and where possible resolved jointly by all relevant parties prior to the submission of planning applications;
  • Setting out how the economic goals of the developers can be reconciled with the public aspirations for the development including potential community,health and wellbeing and safety gains to compensate for the loss of what many in the community regard as the community benefit of the current open agricultural land
  • Showing how your client  will  ensure that the related onsite and offsite  infrastructure will  be properly financed  ‘
  • Showing how your client  will  ensure that the related onsite and offsite  infrastructure will  be properly provided and how it could  ‘potentially be  ‘front-loaded’ and where possible accelerated,
  • An indication of the approaches that will be taken to provide an appropriate;y high quality of approach to building on site and the future proofing of the new buildings at a time when climate change mitigation has a high public priority

These suggestions we set out above  are fully consistent with the Governments recently published “ National Design Guide” which clearly states

Local communities can play a vital role in achieving well-designed places and buildings and making sure there is a relationship between the built environment and quality of life. Communities can be involved in design processes through approaches such as co-design, design workshops and other engagement techniques, so that places and buildings reflect local community preferences, improve their quality of life and fit well into their surroundings. The design-related chapters of the planning practice guidance explain these and other design processes.  “National Design Guide October 2019

CPRE would have expected that JTP as the “Master Planners and Developers “would  be  incorporating a more  appropriate effective engagement and consultation with stakeholders and the local community, including the Town Council , in order to build a sense of community ownership and to be committing the developers to keep the public engaged and informed  about  the progress of the preparation of the Strategic Masterplan;

CPRE would also expect that an explanation would have been given of how formal planning engagement would take place in the future with TDC as Local Planning Authority  incorporate appropriate and effective engagement with elected Members, including thorough regular update reporting to the Local Plan Cabinet Committee; to enable the Council to endorse the Masterplan as a material planning consideration and reflect the relevant requirements so that it can be adopted in future as a Supplementary Planning Document if required possibly as part of the Neighbourhood Plan for Westgate on Sea

It is puzzling to see JTP seem to be able to work properly with the Community Elsewhere,for example in Oxfordshire (see below).CPRE ask why JTP do not seem to be bringing such  an enlightened approach to Westgate on Sea  in Thanet if it is possible in Oxfordshire

Shaping the future of Blackbird Leys. The local community was invited to our Community Planning Days on Friday 10 and Saturday 11 May 2019.

Oxford City Council are working with Catalyst to develop the District Centre and land at Knights Road. The development will deliver at least 250 new homes, including homes for social rent and shared ownership, as well as improved shops, community and public spaces. The local community joined us to find out more and get involved in hands-on planning. Through walkabouts, group brainstorms and planning exercises, your ideas will help to shape the future of the proposals.” D

Extract from JTP Website

CPRE are concerned that in the interests of transparency the public are entitled to be aware of discussions with Planning Officers rather than these taking place  behind closed doors

A FOI request has been lodged with TDC to require details of meetings that have taken place to date

We note the commentary elsewhere in your portfolio set out in  your CompanyWebsite that  ion 2nd July  2019 JTP claimed to be supporting  “first ever National Housing Design Audit”

We are very delighted to be supporting this national housing design audit. New neighbourhoods should be designed to create communities and not just provide housing. The audit will help assess how well this is being done through providing walkable neighbourhoods with shops, schools, play areas and access to nature within walking distance new homes. It will identify how successful we have been at delivering high quality public realm and access to sustainable transport. By scoring the design of new neighbourhoods against set criteria we will be able to target areas for improvement and ultimately, help encourage development teams to improve the quality of places that are created in the future.

Clare San Martin, JTP

CPRE notes  that the   National Housing Design Audit- which is  using broadly the same methodology as earlier housing design audits conducted between 2004 and 2007(and which has been drawn onto make our suggestions above )-whereby  the intention is to  provide a baseline against which to measure progress on place-making in new housing development going forward.CPRE KENT asks therefore why the  National Housing Design Audit-  can be so readily embraced by JTP in then why is it not being applied here in Thanet

Although JTP’s website states that the audit will be completed in the autumn and will feed into the work of the Government’s Building Better, Building Beautiful Commission. CPRE understand that publication of the Report on the   National Housing Design Audit will take place in mid January

CONCLUSION CPRE Kent suggest that following the initial “Consultation “(S.I.C)in November there is a strong and sensible case for Millwood Homes and JTP to consider the results of its initial findings in the light of the    National Housing Design Audit after its publication,potentially  in mid January 2020 before taking any further steps in developing proposals for the Land at Westgate on Sea

PART 2  COMMENTARY on THE potential loss of High Quality Agricultural Land and consequential suggestions for Mitigation by providing Social Investment

CPRE are extremely concerned with the potential loss of High Quality Agricultural Land  At the Draft Local Plan Examination session Thanet District Council agreed an amendment to the Draft Local Plan to the effect  we await the Inspectors report  and their conclusion as to whether there is actually a policy of   that prime agricultural land should only be developed as a last resort.Obviously the land at Westgate is of great concern in Policy terms as TDC officers appear to welcome development of 3% or more of of the total available Best and

Most Versatile agricultural land in Thanet;

CPRE supports the view that “There needs to be a re-think of our approach to valuing land so that social and environmental returns, as well as land scarcity, are given equal, or higher consideration over economic return”.

Since the formal end of the public examination Sustainability Appraisal Addendum

Report 258960 Issue 4 was published by TDC  on  3 October 2019 in   that report TDC’s “Westgate Development “was re examined (pages 18 to25summarised in table below )and a summary view and supporting conclusions reached relating to the benefits and adverse effects not surprisingly theConsultants report concludes that the  benefits for the Westgate Site are made to outweigh the very significant disbenefits and adverse effects of  development of 3% or more of of the total available Best and Most Versatile agricultural land in Thanet!;

Extracts from ARUP report  “Sustainability Appraisal Addendum Report 258960

Appraisal summary .

“Beneficial significant effects have been identified in relation to providing a

sustainable supply of housing. No significant adverse effects were identified.

relate to the efficient use of land, the Thanet Urban Air Quality Management Area and potential effects on biodiversity. Thesite would result in the direct loss of 2% or more of the total available Best and Most Versatile agricultural land in Thanet; this is considered to have a potentially significant adverse effect on Best and Most Versatile agricultural land.

Topic12. To conserve and enhance the character and quality of the area’s landscape and townscape particularly associated with town centres and coastal areas.Redevelopment of the site would proactively contribute towards a better townscape, if quality design standards are met.

Topic17. To reduce waste generation and disposal and achieve the sustainable management of waste

Temporary Indirect ST +New developments offer an opportunity to proactively address waste management issues in Thanet and implement more modern approaches to waste disposal.Waste management arrangements should be confirmed as

part of the planning process.

18.Topic  To ensure development within the District responds to

the challenges associated with climate change.

New developments offer an opportunity to proactively

address climate change issues in Thanet and implement

more modern approaches to climate change adaptation and

resilience.

Measures to promote climate change adaption and resilience

should be confirmed as part of the planning process.

Page20  “The proposed site allocation would deliver dwellings as an

extension to Westgate-on-Sea.

 This is a large site; therefore, it is likely to be an affordable housing requirement, which

would assist in the provision of a sustainable mix of types

and tenures. The proposed housing density) of housing

on the site may positively impact on affordable housing

provision. The scale of impact is likely to be significant, but

details of proposed developments are unknown at this stage.

However, the provision of housing in this rural area is likely

to directly benefit the area.To encourage benefits, requirements could be set regarding

housing mix and tenure can help meet local demand.

As an attendee at the “Consultation” CPRE’s Chair was surprised that the JTP and Millwoods Staff were not aware of this and possibly very expensive / valuable report -it is hoped that since November 9th your staff have been able to acquaint themselves with the report

In the RIBA report the following commentary is set out

Development agreements need to be appropriately demanding to avoid delay and uncertainty in projects further down the line, and to ensure that every party is held accountable. Making the best use of the land available requires more enlightened stEnvironmentally sustainable places will not only play their part in a low-carbon future but will provide a legacy which coming generations will be proud of. In our own time,homes in healthy, clean, resource-efficient neighbourhoods in the right places are more likely to attract potential owners or tenants by costing less to run from the start and retaining inherent value in the long term.ewardship from both public and private developers. There needs to be a re-think of our approach to valuing land so that social and environmental returns, as well as land scarcity, are given equal, or higher consideration over economic return. This will provide a greater focus on the long-term benefits of development to the public sector and ensure that standards of delivery and quality are not driven down by a single-minded focus on best price; poor quality housing costs more to individuals and society in the longterm. This was a founding principle of the Town Planning movement.  Ten Characteristics of Places where People want to Live (RIBA)”

This approach is reflected in the commentaries in the National Design Guide

18 This guide has been prepared in the context of social, economic and environmental change. Technological change is rapid, with developments in digital, artificial intelligence and machine learning affecting our lives at all scales, both inside and outside the home. Demographics are also driving change, with an ageing population. Younger people’s expectations are changing too. This is leading to new lifestyles and new models of home ownership.

 19 We expect continuing change as a consequence of climate change, changing home ownership models and technological changes. It is likely to emerge and embed in society rapidly. It will influence the planning, design and construction of new homes and places.   “National Design Guide October 2019

Commentary by CPRE on Sustainability and Future proofing

CPRE contend that there are such significant major adverse effects in the loss of 3.5%of the bet agricultural land such that the local community and the Thanet Community should be compensated for by quality design,future proofed construction and enhanced  provision of Social Capital by the  specification of Social Design and building construction standards that will ensure that any future development  in place of the quality  agricultural land must be to the highest standards of placemaking design focussing on healthy sustainable living standard and building construction standards that are future proofed in accordance with aspirations for climate change adaptation..

If the consultation process is carried our properly ( as suggested in Part 1 of this submission) JTP may become aware of the especial challenges that Thanet provides which have been overlooked by the Planning Authority in their headlong rush to comply with government housing Targets  There is a very high dependance in Thanet on private rented accommodation particularly  for   renters in low-skill jobs and elderly people .

.' The provision for 'elderlies' in Westgate Garden Suburb needs to be rather more than tokenistic and it is depressing to  find that  that a 30% 'affordable (to buy ?)  is the only token reference in Millwoods proposals which is a matter which  needs to be developed further. If we do find a need then the prime local requirement will be 'social renting'. CPRE understands that fuel poverty is an increasing problem for private and social renters and therefore a significant factor in all new build must be the provision of zero carbon techniques and improved build quality to minimise building costs .

CPRE Thanet considers that all new building should be to the highest possible standards and we fully anticipate that the National Housing Design Audit  will have a bearing on this issue

Environmentally sustainable places will not only play their part in a low-carbon future

but will provide a legacy which coming generations will be proud of. In our own time,

homes in healthy, clean, resource-efficient neighbourhoods in the right places are more

likely to attract potential owners or tenants by costing less to run from the start and

retaining inherent value in the long term.

145 New construction techniques may contribute towards improving efficiency, productivity and the quality of new homes and buildings. These include the off-site manufacture of buildings and components using innovative and smart technologies, supported by digital infrastructure. They offer the potential to reduce whole life costs and for users to customise the products. Careful consideration needs to be given to placemaking, local distinctiveness and the character of new homes and buildings

CPRE presses for the Developers and the landowners should accept and adhere to a set of up to date and future proofed design standards and specifications that are currently being developed and  adopted elsewhere and here are  set out below a four sets of suggestions as to how you as developers and master planners may improve the Social Capital and future proofing  any new development proposals :-

A Enhanced Building regulations

Reading Council have recently adopted  "Reading Local Plan" criteria for building regs as a step towards a zero carbon housing policy for all new building and a more sympathetic approach to social housing

Abridged STANDARDS FOR NEW HOUSING IN READING

a. All new build housing  as defined on the Proposals Map will

comply with the nationally-described space standard.

b. All new build housing will be built to the higher water efficiency standard under Regulation 36(3) of the Building Regulations77

c. All major new-build residential development  should be designed to achieve zero carbon homes;

d. All other new build housing will achieve at a minimum a 19% improvement in the dwelling emission rate over the target emission rate, as defined in the 2013 Building

Regulations.

e. All new build housing will be accessible and adaptable in line with M4(2) of the Building Regulations where it is viable, unless it is built in line with M4(3)

In addition there are related policies for f  Affordable housing for Local people and

g Social Housing in perpetual social ownership(:Reading Local PlanNov 2019)

B Creating New   Development  For  Better  Health &Wellbeing

At Ebbsfleet the Ebbsfleet Development Corporation is working in Partnership for a Healthier environment based on4 Ebbsfleet  Healthy Community principles as part of NHS England Healthy New Towns programme:

“The development sites are sandwiched between the River Thames and the North Kent greenbelt ‘where London meets the Garden of England’ on the Highspeed1 trainline. Adjacent to existing urban areas with significant health inequalities, the new development will provide an attractive environment that promotes active and sustainable healthy living. Will deliver new models of care, built around people not organisations, and will embrace the third sector and local community networks creating opportunities for co-located services that support strong multi-generational communities.”https://ebbsfleetdc.org.uk/healthynewtowns/edible-ebbslfeet/

CPRE Thanet believe that if Ebbsfleet with an additional 15000 houses can be planned ifor Better Health and Well being then Westgate’s new development (if it is ever necessary) can similarly benefit  from proper design on the Ebbsfleet Model

C Creating a Dementia Village In Dover  “ dementia village” is under construction is based on a social approach that encourages those with dementia to lead as normal a life as possible, engaging with a familiar environment while having access to care 24 hours a day.

There will be a community hub with a café and space for activities, which will also be open to the local community.There will also be a guest house with six bedrooms, fully equipped for who have dementia, so they and their friends

This is an exciting development and represents a new approach in caring for those affected by dementia “Those with dementia often have other long-term health conditions, which can lead to them being repeatedly admitted to hospital.

“This may tackle specific bouts of illness, but it’s a model that doesn’t necessarily address the overall care needs – emotionally and physically – of an elderly person living with dementia.

2CPRE Thanet believe that if Dover  with an additional 9000 houses in its approved local plan  can have a development location for the elderly be   then Westgate’s new development (if it is ever necessary) can similarly benefit  from especail provision for the elderly with disabilities particularly Dementia possibly based on the Ebbsfleet Model

D Improving  and enhancing  water management

In the plans provided at the “consultation exhibition”emphasis was placed on the Highway Infrastructure and it is understood there was considerab;e concern on the effect on the adjoining network .

Also of importance to neighbourhood properties is the effects of 2000 new houses on the drainage in the neighbourhood .Al of the potential new development lies to the south of Westgate and Garlinge and the land drains from the new development land towards the north and Canterbury road through existing development .Land drainage is a vexed matter which is the responsiblity of the District Council . Policies in the daft local plan make provision for the developer to provide Sustainable drainage systems which  aim to manage rainfall in a way similar to natural processes, making use of the landscape and natural vegetation to control surface water. They are used in both urban and rural areas to guard against surface water flooding.In the context of Westgate’s land adequate land drainage provision is vital as the land for 2000 new houses will result in a greater area of hing /roofing and consequentally higher flows due to faster run off and higher concentration.A phenomenon which cased death by drowning in 1953 in Westgate due to higher reu off due to changed ploughing practices 

However a recent report has shown that

Based on a representative survey, the report 'SuDS – perception and progress: A comparison of England and Wales' has revealed that 60 per cent of SuDS professionals in England have experienced planning applications being delayed or blocked because of refusal on the grounds of the SuDS design.

This compares with only 30 per cent of SuDS professionals in Wales experiencing the same issue.

Sustainable drainage systems aim to manage rainfall in a way similar to natural processes, making use of the landscape and natural vegetation to control surface water. They are used in both urban and rural areas to guard against surface water flooding.

England and Wales have different regulatory frameworks around SuDS, with Wales having introduced new legislation in January 2019 that makes SuDS a mandatory requirement for all new developments of more than one house or where the construction area is 100m2 or more.

According to the report, SuDS is more likely to be the preferred method of surface water management in Wales than in England. Sixty-two per cent of professionals in Wales consider SuDS to be the default option in all projects compared with only 39 per cent of professionals in England holding the same view.

However help is at hand in the Midlands where the local WaterCompany Severn Trent takes a much more proactive approach to development than do water companies in the south a new approach is being taken through the use of special reservoir areas undeerground and in aeas oof green open space can be used to hold surface drainage water

8extract from  How regulation can enable new business models for large-scale developments  _ Institution of Civil Engineers.mhtml (2,180K)

 Adopting SuDS assets, designed and built to recognised industry standards, should form an integral part of any integrated drainage system, and therefore should be treated no differently to a standard sewer pipe or other drainage asset :

Developers can be assured that a more cost-effective solution to surface water drainage will be accepted by the local water company, and that the responsibilities for that will be transferred along with the remainder of the sewerage infrastructure. 

Currently local water companies in the south do not take a proactive role in these matters and simply pocket investment on a house by house basis

This is consistent with with the Governments recently published “ National Design Guide” which clearly states

96 Water management maintains healthy water systems and is important for effective sustainable drainage systems. In well designed places, water features form part of an integrated system of landscape, biodiversity and drainage. This includes new water features that manage drainage and also existing watercourses. Together with green and brown roofs, swales, rain gardens, rain capture and other drainage, water features create multifunctional ‘green’ sustainable drainage systems. They also enhance the attractiveness of open spaces and provide opportunities for play, interaction and relaxation.

 97 Alternatively, places or developments may be designed to adapt to flood conditions. Examples may include a terraced open space where lower levels may become a water feature, or homes with habitable rooms lifted above flood level.

145 New construction techniques may contribute towards improving efficiency, productivity and the quality of new homes and buildings. These include the off-site manufacture of buildings and components using innovative and smart technologies, supported by digital infrastructure. They offer the potential to reduce whole life costs and for users to customise the products. Careful consideration needs to be given to placemaking, local distinctiveness and the character of new homes and buildings

Maybe even in the foreseeable future we may be able to look forward to futher drainage developments even the recirculation of “grey water” to reduce water consumption and improving capacity a sewage treatment works -but that may require more rational management of water companies than currently applies in Kent

CONCLUSION CPRE Kent commend these above 5 examples to you as Developers and Master Planners as examples of how you may be able to future proof development and provide an  adequate social capital in the built environment to compensate for the very significant disbenefits and adverse effects of  development of 3% or more of of the total available Best and Most Versatile agricultural land in Thanet