Faversham Creek Trust response to Vanguard Neighbourhood Plan Project

Initial Proposals presented on 5 th May 2012 1 st June 2012

The Faversham Creek Trust was formed early in 2011 after the Fullwood Report was published and the current owner of Standard Quay gave notice to quit to the then tenants of SQ, who had been operating there as a centre for barge restoration and maintenance for a number of years.

Those two events together were taken as a wake-up call to those concerned for the declining fortunes of Faversham Creek and its Maritime Heritage, as a vital asset of the Town of Faversham.

The Trust's principal tenet is to reverse that decline in the whole Creek and proactively exploit remaining opportunities for development of maritime activities, promoting employment, and utilization of the creek by local residents and visitors.

"Remaining" opportunities because so many have already been exploited for unsustainable exclusive housing, that precludes all maritime activities, and enjoyment by community. 90% of the original Creekside land available for change of use has already been devoted to exclusive housing; "exclusive" because the opportunity to unite the Creek with the rest of the town and make it accessible for use by the community was lost through that exclusivity.

In fact there is no evidence of any benefit to the community from any previous development on the Creekside; some was apparently intended, but vanished on the way, showing lack of commitment by the developer, and interest by Swale Planning. Even the quaysides are unusable for moorings or access to the town.

The opportunity to continue the development of a Shipwrights Apprentice School, after the original one was closed with the completion of the Cambria restoration at Standard Quay, was realised when Morrisons granted a long lease to the Trust on the Purifier building.

Equally important was the fact that this development reversed the visionless pragmatism of the Fullwood report that relegated sustainable and supported use of the Basin to history. This report was universally

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condemned by all parties, especially the Faversham Creek Consortium [FCC], Faversham Creek Trust [FCT] and Faversham Town Council [FTC].

A major feature of almost every documented view of the future of the Creek has been to open the Basin Gates, open the Bridge, activate the shutters to sluice the Creek, dredge the Basin and enable it to be used for maritime activities.

This was enshrined in the AAP2, which specifically excluded further residential development in favour of employment and maritime related activities.

The Trust exploits a specific difference between itself and the Vanguard Project. This is the need and capability to utilise significant external funding for its activities, without reliance upon development and its paltry Section 106 Planning Gain.

However, the Vanguard Project persists in using development contributions as its source, and also mentions that a reasonable proportion of a future Community Infrastructure Levy could be applied in this area. Developers' representatives have already suggested that they would be unwilling to contribute to both.

Therefore there is a clear difference between the focus of the Trust and the Vanguard project, to the extent that the Trust submitted a strong critique of the SHLAA, see Appendix 2.

However, as Vanguard have stated, in the event that the Creek Neighbourhood Plan is rejected by referendum, then the Creek will be thrown open to development with the "presumption in favour of sustainable development".

Therefore, the Trust takes the view that the interpretation of sustainable in this context can only mean a strong presumption in favour of sustainable maritime uses, for Creekside areas that have direct access to the Creek itself, as the planning baseline, as that is the only way to satisfy the sustainability criteria and meet the expectations of the residents of Faversham.

The Trust has extended the area designations of the Creek map, classifying the areas described as;

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1. No Residential Development - NRD2. Residential Development - RD3. Maritime Activities - MA4. Employment – ideally maritime related - EMP

This is an extension of the Vanguard's Mixed Uses approach and it can be seen that there are areas where the Trust's suggestions are the same as the Vanguard's proposed designations. The BMM Wharf has been added as Site 3a as it is not understood why this important site was not included. See Appendix1.

Site NRD RD MA EMP1 Purifier Building y y y2 Ordnance Wharf y y y3a BMM Wharf y y y3b BMM Brent Hil y4 Quay Lane/Belvedere Rd y y5 Swan Quay y y y6 Oil Depot y y7 Coachworks y y y8 Standard Quay y y y9 Standard House y y y10 Fentimans y11 Upper Brents y y12 Chambers Wharf/Iron Wharf y y y

The Trust's response to the Core Strategy is attached as Appendix 3. SBC consistently refers to the Neighbourhood Plan in response to comments by the Trust to the original 'Picking Fruits' consultation.

Yours faithfully

Griselda MussettChairman Faversham Creek Trust1st June 2012

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FCT Comments on individual sites

Site 1. The Purifier Building

Now leased to the Trust for 35years to be used for Maritime Trades and the training of Apprentice Shipwrights. This should set the direction for other uses of the Basin. This facility will need access to the water to enable movement of craft to and from the side of the building [there being no access from Morrison's Quayside]. Inevitably, there will be noise from the activities in the building, which make it incompatible with any immediately adjacent residential development such as on Ordnance Wharf.

Site 2. Ordnance Wharf

The current application to build a 4 storey block of flats on this site has met with vigorous resistance from the Trust, Faversham Town Council and large numbers of the local population. Importantly, if this planning application is given the go ahead, it will set a precedent for further residential development in the Basin. Policy B17, designating the Basin employment sites must remain in force.

There is no doubt that this application will conflict with the activities of the maritime trades in the Purifier, as well as compete for access to the wharf side, potentially being blocked out by the rigid application of riparian rights.

The ideal use for this site is as a space for maritime activities, including cranage and storage and repair of medium sized craft.

Site 3A. The BMM Weston Car Park and Basin frontage

This should be reinstated as a wharf side, by piling and back-filling, to be used as moorings and include a public slip. The Car Park should be used as an open public access area, partly as a small craft parking area but also as grassed open space open onto the wharf side, and the slip.

Site 3B. Brent Hill shown as Site 3

This is not of direct interest to the Trust except that residential development should not be allowed so close nor so high as to conflict with the leisure activities of Site 3A.

Site 4. Quay Lane/Belvedere Rd

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The proposals presented recently, appear to be attractive and integrate existing buildings without interfering with access, use or visibility of the Creek itself. However, the Trusts’ view is that the successful Creek Creative facility should be continued on that site.

Site 5. Swan Quay

This site with its important Creek frontage should be centered on maritime uses, a working quayside available for mooring and access to the town centre. Maritime businesses such as the existing Sail making should be accomodated and the Old Chandlery could even be returned to its original purpose.

Any new building should be set well back from the frontage and restricted to single storey, so as not to dominate the Old Chandlery. Behind that and fronting onto Belvedere Road, separate residential or mixed use development should fit in with the proposed development opposite.

The existing slip adjacent to the Town Quay should be extended for use as a light public slipway and the access and view widened. The fencing barriers should be removed so that public access is linked from Town Green along the front as far as possible.

Site 6. Former Oil Depot

There is an opportunity for some berths similar to those on the opposite bank. The quayside should be usable and accessible to boats to tie up alongside and access the town or Standard Quay. In addition there should be open public access that will continue to Standard Quay.

Any development should be set well back and not obscure the views of the Creek for the Abbey Street residents.

It would be helpful for continuity of design planning if this site was designed and planned in collaboration with Site 7.

Site 7 - Coachworks and offices

The proposal for a mixed use development with ground floor quay side facilities, including toilets and showers, should remove any need to convert the Black buildings for other uses, guaranteeing that they are reserved for maritime trades.

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The scale and alignment should be kept to that of the Black buildings and the style should be complimentary.

Full public access should be maintained along the creek frontage to the existing moorings.

Site 8 - Standard Quay

The Quayside Properties' proposals for this site are confusing and contradictory. Despite the stated aims to maintain the Quay as a centre for Barge and large traditional craft repair, the quay continues to lose the interest of the traditional barge community. Restrictions on use of the quayside and access to the barges by crane; loss of dry dock facilities and the lack of resident shipwrights' skills are at odds with the claimed aims.

Features of the plan, including a turning circle for cars, a leisure area alongside the quayside where there may be Barge Blocks and therefore boat building activities, parking along the quayside, but a complete lack of a proper working area for shipwrights' activities, for such things as Masts and spars and large timbers, and heavy equipment, all contradict the claims.

Any change of use of the Black buildings on the basis of needing to subsidise the quayside and boatbuilding activities should be rejected completely because that will inevitably accelerate their downgrading as a maritime heritage asset, and their use for maritime trades. The insertion of a restaurant in the middle of workshops is not feasible and upgrading the sheds will result in them no longer being affordable workshops.

Site 9 – Standard House – agree with Vanguard

Site 10 – Fentimans – agree with Vanguard.

Sites 11 – Upper Brents & 12 – Iron wharf and Chambers Wharf - Agree with Vanguard - must be preserved as industrial employment or maritime uses.

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APPENDIX1

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APPENDIX 2

Spatial Planning Policy ManagerSwale Borough CouncilSwale HouseSittingbourneME10 3HT

May 17, 2012

Dear Sirs,

Re: Strategic Housing Land Assessment Analysis

We are writing to comment on the above.

First we challenge the process taken to include the sites around Faversham Creek. AAP2 and existing policies have been disregarded, and the basis for suitability has been predicated on the views of Tony Fullwood, whose report on the Creek received considerable criticism during the consultation period last June, from a number of consultees including the Faversham Creek Trust, Faversham Society, and the Faversham Creek Consortium, particularly his assertion that mixed uses are appropriate in the basin – residential and industrial do not mix. The Basin is historically an industrial area and the Trust is now renovating the Purifier building as a shipwrights centre for apprentices and boat repair. These responses to Fullwoods recommendations do not appear in the public domain, neither do they appear to have been presented to Members at any time, and certainly not taken into consideration by this process.

It appears that current policies, such as B17 for the Basin, are being swept away by the Council in order to achieve housing targets and access New Homes Bonuses. The regeneration of Faversham Creek will only happen if the focus is on opening the bridge and sluice gates so that large vessels can access the basin, which will achieve natural dredging, maritime jobs, and tourism potential. The recent wholly inappropriate planning application for luxury flats on the historic Ordnance Wharf, if approved, will kill off the employment prospects and tourism potential of the historic port. You will have noted the huge public outcry and letters of objections.

The Council is pre-empting the outcome of the Faversham Creek Neighbourhood Plan by stating in section 11. "The Faversham Creek Area Plan will give rise to sites that

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should be considered." This SHLAA process has been undertaken in total isolation from the existing local plan for Faversham Creek, which received wide community support and represents the aspirations of Faversham people for the Creek.

Equally we are extremely concerned that the Partnership established to advise the Council on sites, comprises of only housing developers, with the exception of CPRE. The process is therefore developer led without any reference to the community. Whilst it may have been out to consultation alongside the Core Strategy its existence is little known by the general public, and moreover not written and presented in ways which would encourage local people to participate in the democratic process.

We submit that the Creek sites should be withdrawn from the SHLAA at this stage, until the Neighbourhood Plan has been developed and approved by the referendum in 2013.

The sites are:

SW/034 BM WestonSW/203 Ordnance WharfSW/353 Standard QuaySW/354 Fentimans |YardSW/359 Standard |HouseSW/356 SECOSSW/424 Swan Quay/ Belvedere

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APPENDIX 3

Faversham Creek Trust c/o Fleur de Lis Heritage Centre Preston Street Faversham ME13 8RJ17/05/12 16:39

Comments. Draft Core Strategy: Bearing Fruits (March 2012) (26/03/12 to 18/05/12)Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF310 17/05/12 14:46 Statement 3 The Vision for Swale ( View ) SubmittedWeb0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.As in the previous comment there is still no mention of Faversham as an historic port, the raison d'etre for the development of Faversham over the centuries. This is a lost opportunity for realising the maritime heritage tourism potential of the Creek and Faversham.Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF311 17/05/12 14:48 3.3 Core Strategy objectives ( View ) SubmittedWeb0.1Are you supporting or objecting to the draft Core Strategy?Powered by Objective Online 4.0 - page 1Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.It seems that the previous consultation Pick Your Own has been unheeded in that there is still no mention of Faversham as an historic port, an associate member of the Cinque Ports. Why?Where is the strategy for realising the potential of this unique heritage, rather than plans for luxury housing?Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF312 17/05/12 14:50 4.6.3 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We object to this statement insomuch as the real opportunity for increasing the sustainable

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tourism potential is not the market town and food and drink (although these will contribute to the local economy) but the regeneration of the Creek as a traditional maritime waterway for traditional and other vessels to access the Creek including the Basin.We made all these comments in Pick Your Own but the response was on all counts 'this is subject to the neighbourhood plan'. So where and when will these views be taken into account?Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF313 17/05/12 14:52 4.6.4 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy?Powered by Objective Online 4.0 - page 2Please choose one of the options and explain your I support this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We support this statement especially with regard to the designated employment sites around Faversham Creek within AAP2, and the related policies B17 and B4 which MUST be retainedComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF314 17/05/12 14:53 4.6.6 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We do not support any further housing on and around Faversham Creek.. , as this will further erode the potential for conserving and enhancing the traditional maritime heritage for Faversham as an Historic Port, and the longterm local economic benefit that the much needed jobs and tourism potential will derive from sensitive appropriate regeneration of Faversham Creek.Comment by Comment ID Response Date Consultation PointFaversham Creek Trust (ms Brenda Chester) BF315 17/05/12 14:58Table 3.0.4 Sites from within Neighbourhood Plan Final yields to be determined by Neighbourhood Planning process.. ( View )Status Submission Type Version Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Submitted Web 0.1Powered by Objective Online 4.0 - page 3Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We strongly object to any further housing on the creek frontage and including the basin. These sites should remain as industrial and a visionary integrated plan developed to regenerate the Creek as a traditional maritime waterway, which will provide skills, jobs and tourism potential for our historic port. Visitors will not come to look at luxury houses. Nor will these developments provide affordable housing for local people in need - look at the waiting lists..

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We seriously question how some of these sites, especially Ordnance Wharf and Standard Quay, came through the Strategic Housing Land Assessment as recommendations for inclusion as housing sites? We shall be objecting separately to this.You will have noted the huge amount of community oppositionto the recent planning application for 11 luxury flats on the historic Ordnance Wharf. Clearly the developer was encouraged to submit this application because of the sites inclusion in the SHLAA. This was premature given the early stage of the Neighbourhood Plan, but worryingly the SHLAAproposals seems to be taken as read by the Vanguard steering group, regardless of the views of the communityComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF316 17/05/12 15:00 3.3 Core Strategy objectives ( View ) SubmittedWeb0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We object to the omission in Places of Faversham Creek- the conservation and enhancement of the Creek is the key to the sensitive regeneration of Faversham which will bring long term benefit to the local economy - not luxury housing.Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF317 17/05/12 15:01 4.2.6 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy?Powered by Objective Online 4.0 - page 4Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We object to the statement that it is an 'employment led strategy' because it is not as the focus is on housing so that the Council can access the New Homes Bonus, clearly illustrated by the proposals for 102 housing units in and around the Faversham Creek. If these housing developments are allowed the employment opportunities will be killed offWe disagree that additional housing is required for new employment sites to avoid 'commuting in', because it is local people who need the jobsComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF318 17/05/12 15:03 4.2.28 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy? Please choose one of the options and explain your I am giving qualified support to this part of the Corechoice in the text box below. Strategy Please explain why you are supporting or objecting to this part of the draft Core Strategy. Whereappropriate, tell us what changes you would like to see made.We agree that development should be limited and conservation led. However, this is not

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borne out by the Councils housing site proposals for Faversham Creek within the Strategic Housing Land Assessment AnalysisComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF319 17/05/12 15:12 Table 4.3.7 The location of development ( View ) SubmittedWeb0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Powered by Objective Online 4.0 - page 5Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.We strongly object to the 102 housing units around Faversham Creek being proposed. Any development for the Creek is subject to the Neighbourhood Plan currently in progress but this proposal and has evolved from the SLHAA without any reference to the AAP2. Why?. Any more luxury housing (it is certainly not affordable housing) will erode further any opportunity for skills and jobs opportunities for local people, and the conservation and enhancement of the the maritime heritage of Faversham for generations to come.Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF320 17/05/12 15:14 4.6.1 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy? Please choose one of the options and explain your I am giving qualified support to this part of the Corechoice in the text box below. Strategy Please explain why you are supporting or objecting to this part of the draft Core Strategy. Whereappropriate, tell us what changes you would like to see made.We agree totally that conservation should be the primary aim for Faversham, but this statement is not evidenced by the Councils proposals for Creek side sites being suitable for housing, and these proposals must be withdrawn from the SHLAA, and be subject to the Neighbourhood Plan public referendumComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF321 17/05/12 15:21 5.4.8 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy? Please choose one of the options and explain your I am giving qualified support to this part of the Corechoice in the text box below. StrategyPlease explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.Powered by Objective Online 4.0 - page 6Yes housing strongly influences the character of a place so why does the Council support proposals for luxury housing on Ordnance Wharf and elsewhere along the Creek, which would erode the heritage of the conservation area, and prevent sustaiable regeneration for community benefitComment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF322 17/05/12 15:26 Policy ST 5 Faversham

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Area ( View ) ProcessedWeb0.3Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.It is claimed that this strategy is jobs led - this is clearly not the case in Faversham, as it seems to be predicated on housing developments, especially around the Creek, where 62 units are proposed either on the waterfront or second line, derived from the Strategic Housing Land Assessment Analysis (SHLAA), without acknowledgement whatsoever of AAP2 for Faversham Creek, nor the current neighbourhood plan process, which is supposed to be community led.If the strategy is employment led, then why has there not been a proactive action plan by the Council to market the Nova Furniture site, vacant for years?Comment by Comment ID Response Date Consultation PointFaversham Creek Trust (ms Brenda Chester)BF32317/05/12 15:48Swale Borough Draft Core Strategy: Bearing Fruits (March 2012) ( View )Status Submission Type Version Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.Processed Web 0.3Powered by Objective Online 4.0 - page 7This consultation has been poorly advertised, presented and navigating the website very difficult for people not familiar with consultation portals. The responses have been very minimal on the website, with many paragraphs/ statements having no comments registered. The Council should not take this as tacit approval of the strategy, but a failure of the consultation process.Comment by Comment ID Response Date Consultation Point Status Submission Type VersionFaversham Creek Trust (ms Brenda Chester) BF324 17/05/12 16:11 6.6.7 Paragraph ( View )Submitted Web 0.1Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.The first sentence does not make sense grammaticaly - there are word(s) missing.Also, the Fullwood report October 2010 is mentioned often but there is no mention of the considerable numbers of criticisms of his statements and recomendations during the very short consultation period May/June 2011. made by the Faversham Creek Trust, Faversham Creek Consortium, and Faversham Society. The responses to this consultation have not been reported, nor do they appear on Swale Borough Councils website. Why have these responses not been made public, and importantly not been taken into account?

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Comment by Comment ID Response Date Consultation PointFaversham Creek Trust (ms Brenda Chester)BF32517/05/12 16:37Policy NP 1 Faversham Creek Neighbourhood Plan ( View )Status Submission Type Version Are you supporting or objecting to the draft Core Strategy?Please choose one of the options and explain your I object to this part of the draft Core Strategy choice in the text box below.Please explain why you are supporting or objecting to this part of the draft Core Strategy. Where appropriate, tell us what changes you would like to see made.Submitted Web 0.1Powered by Objective Online 4.0 - page 8It is astounding that the creation of jobs and enhancement of the maritime heritage of the Creek is not stated here, and we object to this omission most strongly. For example, current policy B17, which states the Basin sites are for employment use must be kept.The repair of the sluices and swing bridge are crucial to the successful regeneration of the creek, especially to the basin which would facilitate the provision of maritime skills and jobs and enhance the maritime heritage tourism potential of the Creek. These aspects should be fundamental to NP1Powered by Objective Online 4.0 - page 9

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