Many people are questioning the thinking behind a development twice the size of the central, walled part of Canterbury, on a greenfield site that would in-fill between three distinct villages: Tyler Hill, Blean and Rough Common.
Local planning papers and housing strategy tell us why this proposed development is unsuitable and unworkable.
Significant negative impacts
The inclusion of this site in the Local Plan comes as a surprise, as previous assessments have found it unsuitable for housing development for a large number of reasons. The most recent Strategic Land Availability Assessment from December 2023 notes there would be: “Significant negative effects on Biodiversity, Geology, Landscape, Water, Historic environment (site contains a Scheduled Ancient Monument and is adjacent to Grade 2* and Grade 2 Listed Buildings, with likely impacts on the heritage assets and/or their setting) and Land use (site is a greenfield over 3ha).”
Impossibly demanding deliverability targets
The latest Strategic Land Availability Assessment goes on to say: “While the SA has identified significant and minor negative impacts, it is determined, when reviewed alongside the SLAA on the balance of impacts and considering possible mitigation and design, that the majority of these impacts can be addressed.”
However, the possible mitigations are so demanding and unlikely that they cannot be achieved:
- The site is within the Green Gap and would lead to settlement coalescence. Due to the size of the site, character of the area including projection into the open countryside, isolated location separate from the urban area/settlement, and existing views, development would have a significant adverse impact on the surrounding open countryside.
- There are significant heritage sites and conservation areas all around the proposed area for development, protected by national planning laws.
- The site is a greenfield area of more than 100 hectares, and is Grade 3 agricultural land currently used for arable crops and grazing.
- This would be a large-scale car-dependent development (even with additional buses planned). Tyler Hill Road is narrow, and the junction between Tyler Hill Road and Blean Common has had several incidents meaning more traffic could cause significant negative impacts on the highway network.
- The previous Local Plan to 2045 included a Western bypass as a proposed way to expand local road capacity, as the Council recognises that local roads in North Canterbury are already at their limits. The Western bypass has now been removed from the local plan, with no alternative suggestion for how 2,000 additional households with cars could get around the city.
- Loss of such a large, well-used and significant open space cannot be adequately “reprovided” within the site – it is a huge local asset and amenity, which no amount of mitigation or substitution can replace.
- Flood risk is given a positive assessment in the latest SLAA – a big point of concern as we believe the SLAA is wrong. The majority of the site is London Clay (as noted in the Landscape Character Assessment and Biodiversity Appraisal 2020) so not free-draining and liable to flooding. A huge amount of mitigation would be needed to make the site viable for thousands of houses, paved gardens and tarmac roads. Planning advisors say it may be virtually impossible to mitigate against surface flooding. Councils across the UK are increasingly facing flash-flooding compensation claims from residents and businesses for poor flood planning.
- The SLAA notes there are still “Uncertainties” regarding biodiversity: “no biodiversity evidence but within an orange area for Great Crested Newts.” There is in fact significant biodiversity evidence, with multiple protected species being sighted, studied and mapped on national data sets such as the National Biodiversity Network Atlas and iNaturalist.
- There is also a note re Uncertainties around practical timings between the loss and “reprovision” of Blean Primary School. The local communities are deeply concerned that a primary school rated Outstanding by Ofsted could be closed for a long period and/or massively disrupted.
Impact on the whole Canterbury District
The proposed housing development north of the University would swell the current population – around 3,700 across the three villages – to an estimated 10,000. All the associated pressures on traffic, GPs, hospitals, waste management and water supply would follow.
The Stodmarsh Issue – where Natural England has had to call for a pause to house-building to stop irreversible damage to the Stodmarsh River and National Nature Reserve, caused by nitrates from non-organic farming and human sewage – is also still a major concern and needs to be managed at the District level.
Population projections
The National Housing Strategy to build 300,000 houses a year plays into this new proposal, with the Council facing the challenge that new houses need to be built somewhere in the district otherwise Canterbury will miss its targets.
However, the number of houses that need to be built in each area are based on figures produced by the Office for National Statistics (ONS). The Alliance of Canterbury Residents’ Associations (ACRA) has concerns around the district’s failure to use the latest population projections, and has urged the Council to plead Canterbury’s case for exceptional circumstances due to a falling population in the district.
A report commissioned by Canterbury City Council in 2021 shows that the rate of growth forecast by the ONS is no longer realistic. The Edge Analytics report predicts population growth of 8% between 2023 and 2040 – half the rate forecast by the ONS.
Under the new National Planning Policy Framework, the Council can make the case to Central Government that Canterbury has “exceptional circumstances” and therefore should have its local housing targets adjusted – we strongly urge them to do so.