31 December 2020

Planning Department
Gravesham Borough Council

31 December 2020.

Dear Sir / Madam,

Gravesend Borough Council: Local Plan Regulation 18 (Stage 2) Consultation.

Site Allocation reference GBS-K

I am writing on behalf of the Medway Green Party to strongly object to the allocation of 200 acres of Grade One agricultural land at Chapter Farm for the construction of 1400 houses.

The site is adjacent to the Medway Council Area and part of the Green Belt that is intended to provide open countryside both around London and between Gravesham and the Medway Unitary Authority.

As such the land enjoys legal protection and any development other than for agriculture would be against the National Planning Policy Framework and current Government Policy.

The lack of connection of the site to existing urban areas and infrastructure within Gravesham and the proximity of the site to the Medway Council Area will put an undue strain on the existing facilities in Strood.

Medway Council will inevitably be faced with costs both financial and social when they are forced to share scarce resources with the new residents, of Chapter Farm, needing to access doctors, schools, shops and other services close to their new homes.

We recognize that recent misguided pressure, from Central Government to build more and more houses, has led to a frenzy of planning applications being made on agricultural land all over the South East of England.

Gravesham Borough Council, no doubt, now realize and acknowledge that the philosophy driving the demand to build more houses in the South East was mistaken and the housing need assessment algorithm generating the numerical demand was totally ill-conceived.

The Government has now had the good sense to recognize the errors associated with their previous housing policy and on Wednesday 16 December, 2020 issued details of a new policy that while creating homes for people to live in, will address many of the social problems and inequalities in society that have been highlighted by the current Covid-19 pandemic. 

During the current pandemic we have realised how fragile our food supply chain is and in a post Brexit Britain we will need every square metre of available farmland to grow or own food.

The new housing policy calls on Local Authorities to make the most of vacant buildings and underused land in order to protect green spaces, with a focus for building on previously developed sites.

This approach will protect our farmland and at the same time make our urban areas more viable in terms of community with people once more living in our towns and cities. It will also help us to make our journeys more environmentally friendly, reduce carbon emissions and improve our air quality.

A housing needs assessment designed around population growth rather than mutant algorithms would show that Gravesham Borough Council needs to build many fewer houses than are currently shown in the Local Plan.

Apart from how many houses we build, what is more important for the future is how we build. The current Building Regulations are inadequate and we urgently need to reinstate the standard of insulation and construction that the previous Labour Government introduced under the UK Code for Sustainable Homes.

We were on track to be building net zero carbon houses by 2016. In the years between the policy being scrapped by the previous Coalition Government, millions of houses have been built that will now need to be expensively retrofitted to meet our international binding commitment to be carbon neutral by 2050.

The need to retrofit virtually every single building that has ever been built, is a salutary recognition that not only helps us appreciate the naivety of constructing buildings with such a reliance on fossil fuels to make them tolerable, but the accumulative impact on our environment and health.

The Royal Institute of British Architects and other professional institutes are calling on the Government to legislate for all new buildings to be net zero carbon from now on. The longer this change to our construction methods is left, the more expensive will be the measures needed to rectify it.

It is apparent that the volume house builders do not acknowledge the terrible legacy that they are creating while concreting over our farmland and countryside.

We are, however, confident that Gravesham Borough Council understand the need to conserve our resources and make better use of what already exists.

Yours faithfully,

 Bernard Hyde. DipArch.RIBA.DipTP

On behalf of Medway Green Party

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