Local Plan for Canterbury 2040 is flawed, say campaigners

CPRE (Council for the Protection of Rural England) in Kent has just issued a response to the Canterbury Local Plan. It has significant concerns that this draft plan does not constitute a sustainable or sound plan. The National Planning Policy Framework (NPPF) uses a method that is an advisory starting point for establishing housing requirements. CPRE argues that Canterbury has exceptional features, such as the high student population that, if ignored, produces flawed plans for housing projects.

There are continued failures to properly consider whether exceptional circumstances exist to allow a lower housing target starting point

The Canterbury City Council (CCC) 2021 Housing Needs Assessment, which considered the case for exceptional circumstances, predates the changes to the NPPF. It also predates the recognition by the Office for National Statistics (ONS) that their own approach to student population calculations is flawed. The revised projections with the adjusted methodology have not yet been released. Therefore, the high student population could constitute exceptional circumstances. This was successfully argued in Coventry.

With the changes to the NPPF, other councils are taking the need to properly evidence whether exceptional circumstances exist. Swale Borough Council has recently gone out to tender for a consultant to consider this point. Several other councils are also advancing local plans that evidence exceptional circumstances. CPRE Kent considers it a dereliction of duty that Canterbury City Council persists without questioning the standard methodology now that the NPPF has confirmed that it is an advisory starting point only.

Failure to consider whether the specific constraints of the district mean that the standard method housing target cannot be met in full

Even without exceptional circumstances, CCC must assess whether there is capacity to meet the advisory housing numbers, as Canterbury district is significantly constrained. The Kent Downs Area of Outstanding Natural Beauty (AONB) covers 27% of the district; ancient woodland covers 15.6%; there are two National Nature Reserves, several Sites of Special Scientific Interest (SSSIs), a coastline, and a UNESCO World Heritage Site in the heart of Canterbury.

There is no evidence that a doubling of the annual housing rate is sustainable or that the district would ever be able to deliver such an increase.

The spatial strategy should balance providing housing land with the need to meet the NPPF’s wider social and environmental factors. This was successfully argued in the Worthing Local Plan, which successfully led to a housing figure 74% lower than the standard method figure. More councils now realise that constraints in their area mean that they cannot meet the housing numbers. Ignoring this factor means that their local plan would not be considered sound. More councils are taking Worthing’s approach. Therefore, it is disingenuous for planning officers to advise council members and the public that the standard methodology is the only option.

Flawed spatial strategy

CCC must not be influenced into adopting unsustainable greenfield sites such as the newly proposed greenfield site C12 – land to the north of Kent University – which had already been deemed unsuitable for development but is now included in the plan.

There is concern as to the lack of focus on brownfield sites and the continued unsustainable over-expansion of Canterbury. The large and complicated allocations around Canterbury are already unable to deliver housing numbers. Developers do not want to saturate the market for fear of bringing down market prices. These huge developments, such as those being proposed in southwest Canterbury, have enormous lead times, as infrastructure must be in place before houses are delivered.

These plans could fail the Housing Delivery Test, leading to the threat of unplanned and unsustainable development filling the void. Despite the uncertainty of a new government, CCC must meet the social and environmental needs of the district. However, the current plan will not achieve this if it continues to impose an unsustainable and undeliverable number of houses in the district.

Continued failure to take a genuine brownfield-first approach

The plan is relying on those few brownfield sites that are already on the register and those that have come forward in the call for sites. CPRE Kent wants a more proactive approach to be undertaken to identify brownfield sites. It believes that very few brownfield sites will ever come forward in a call for sites exercise.

There should be detail as to what constitutes acceptable development on identified brownfield sites instead of just calling them ‘opportunity areas’. They should be properly master planned at an early stage to enable an assessment of how many residential units they can accommodate and to maximise density. These sites should be prioritised before allocating more greenfield sites. It is also CPRE Kent’s view that higher-density housing could be achieved on brownfield sites, revitalising urban areas with vibrant communities, relying more on public transport and boosting the economy. This would also be a strategy to protect our countryside.

Loss of the best and most versatile agricultural land must be avoided

This issue must be given more genuine consideration, as the draft plan appears to be allocating significant development on best and most versatile land, yet nowhere is this quantified, nor have they set out the measures they should have taken to minimise its loss. CPRE Kent believes that the loss of agricultural land, which appears to be increasing, cannot be sustained if we wish to safeguard food security.

Genuinely affordable housing must be provided

CPRE Kent believes that the housing crisis is an affordability crisis. This issue is acute in Canterbury, as the district has only built an average of 69 affordable houses a year over the last five years based on the last figures provided. On average, fewer than nine a year have been social rent affordable houses. Only a tiny percentage of Canterbury residents can afford a house on the open market on income alone or buy a house under the shared ownership route. Therefore, most houses being planned are to accommodate the external market instead of local people.

CPRE nationally is calling on the government to redefine ‘affordable housing’ to directly link to average local incomes. It wants to see ambitious targets for new affordable homes required by national planning policies and a new generation of social rented homes. It wants local communities helped to deliver small-scale affordable developments with a streamlined planning process. It does not believe that allocating large, complicated sites that need expensive new roads and infrastructure provided before a house can be built will do anything to solve the affordability crisis.

CPRE Kent wants there to be more focus on small to medium sites, which can come forward more quickly and offer better design opportunities by not relying on volume house builders.

CPRE welcomes some features of the plan

In its response to the Local Plan, CPRE Kent supports the shortening of the plan period and the removal of the Eastern Movement Corridor and certain other sites. The 20% biodiversity net gain is welcomed as long as this commitment is not watered down after lobbying from the development industry. It also welcomes the revised Transport Strategy, which aims for a modal shift to public transport.

Conclusion

CPRE Kent wants:

CCC to properly evidence why exceptional circumstances do not exist, particularly with respect to student numbers.
CCC to properly assess whether there is sufficient capacity within the district to meet the standard model, considering all constraints.
CCC to revise the spatial strategy with a reduced figure to reduce damaging and unnecessary greenfield allocations whilst maximising brownfield allocations.
CCC to have more focus on small/medium sites, which can come forward faster, offering better design opportunities by not relying on volume house builders.

The above is a synopsis of CPRE Kent’s general comments on the Draft Canterbury District Local Plan 2040. For the full response, including general and detailed comments, please go to the document on the CPRE Kent website.

CPRE is the Countryside Charity. Formed in 1926, it is one of the longest-established and most respected environmental groups in England. CPRE Kent is the largest of the CPRE county branches, representing more than 1,400 individuals or groups. The head office is based in Charing.