Development for Hartley? An appraisal - Hartley-Kent - Hartley-Kent: The Website for Hartley

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Development for Hartley? An appraisal

Hartley-Kent: The Website for Hartley
Updated 18.8.2018 with information from Sevenoaks Local Housing Needs Study.  Updated 19.8.2018 with statement from local surgery. Updated 1.9.2018 with latest information from both sides.

The hot topic at the moment is undoubtedly the Billings Group plans to build 700 houses at Corinthians and Downs Valley.  An opposition group exists called "No Hartley Expansion" (NHE); they have published leaflets and posters, but it is unclear who they are.  I was unable to attend the meeting held on the 7th August, so don't know what was said there.  

What follows is my research on the proposals.

It is described as an extension of Hartley, although the majority of the land is actually in Fawkham parish.

700 houses would represent a significant increase over the existing number of houses which in 2011 was 2,259.

This is not an actual planning application at this stage, but rather a proposal to list the site in the district plan as one where the council would allow development.  Once it is in the district plan, development would be extremely likely.

The Planning Background

The background for this is the country's urgent need for more houses, particularly affordable ones.  Sevenoaks Council estimated they would need 12,400 new homes in the district in the period 2015-35, which the government has since upped to 13,960 because Sevenoaks is one of the most unaffordable housing areas in the country outside London.  As part of the planning process, Sevenoaks Council are required to idenfity sites which could meet this need.  They do this by asking landowners to nominate sites they want to develop, which they then consider for inclusion in the district plan.  

They are allowed to make an allowance for what are called "windfall" sites - that is, those not named in the district plan, but do become available for development.  Most of Hartley's recent development (with the exception of the old allotment site at Caxton Close which was a site listed in a former district plan) would be classed as windfall.  However in making the allowance, authorities are not allowed to count windfalls arising from building on garden land, which would appear to rule out a lot.

Another problem facing Sevenoaks is the limited amount of land that is not green belt.  93% of the district is green belt land and 60% has the Area of Outstanding Natural Beauty designation too.  This may make it difficult for the council to meet their obligations without removing some land from the green belt.  

The current state of play is set out in the Strategic Housing and Economic Land Availability Assessment (July 2018).  They have split the sites that passed the suitability test and could be developed in the next 5 years into 4 categories in descending order of desirability:

(Category 1) Within identified settlements (24 sites, 331-408 units)
(Category 2) 100% brownfield land in green belt (23 sites, 447-603 units)
(Category 3) Partial brownfield land in green belt (47 sites, 622-847 units)
(Category 4) Green belt next to identified settlements (36 sites, 2,666-3,558 units)

The problem for Sevenoaks is that they appear to need 3,500 houses in the next 5 years but brownfield will only yield about half that number.  Even with an addition for windfall sites, it does seem difficult to avoid the conclusion they will have to build on the Green Belt somewhere.  It also means that the rate of building will need to more than double from the 296 per year averaged over the last 8 years.

The SHLAA rejected most of the Corinthians scheme, but does support an extension of the Parkfield estate to the crest of the hill.  This would result in 141-188 houses being built.  It also rejected proposals to build at Manor Lane, Hartley and Johnson's Farm, Ash.  However it did support building 6-8 houses at Eureka Naturist Club, Fawkham.  This assessent is not the end of the matter though, as the call for sites is still out and the draft district plan will need to be approved by the Planning Inspectorate.  

Full details of the SHLAA site assessments are on the Sevenoaks Council website, Corinthians is a Category 3 site, Downs Valley is a Category 4 site.  Probably over half of the category 4 sites will need to be developed to meet the housing target.

If Sevenoaks do not allocate enough sites to meet their housing targets, then potentially that can be used against them in determining planning appeals.  If a council doesn't allocate enough land, then the minister can say the need for housing outweighs the district plan.  We have an example locally of this happening - in the 1960s Kent County Council was dragging their heels in providing housing sites, so the minister Richard Crossman granted approval for the first application from Kent that came across his desk, and there we have New Ash Green!

If the council does allocate enough sites, then they are probably fireproof from developers trying to bounce them into allowing development on other green belt sites.  This was the inference from a recent case in Cheshire.  The minister has rejected a proposal for 900 homes on the Gorstyhill Golf Club.  It is not exactly the same set of circumstances, in particular the development was bigger than the existing village, but a key point is that they might have got planning permission had Cheshire East council not been able to say there was sufficient land allocated for housing in the next 5 years.  The locals and the council there spent 5 years opposing the development according to a blog.

The Corinthians Proposal

The Billings Group have issued a brochure setting out their plans called "A Community Vision for Hartley" which they have since updated following comments received.  As well as the Corinthians Sports Club, the plans also affect the fields that lead from Downs Valley to the Fawkham Valley Road, and half of the meadow by St Mary's Church, Fawkham.  In all the site is 74.6 ha (184 acres) of which 34.7 ha are allocated to build 700 houses, 27.9 ha to open space and the remainder to other community and business uses.  

They suggest that Hartley and Longfield should be treated as one urban area (in fact the Office for National Statistics does treat Hartley, Longfield and New Ash Green as one urban area); and that Hartley has good links to rail stations, district hospital and regional shopping centres.

They argue that special circumstances apply to this land and that it should be removed from the green belt.  They say their proposals are sustainable development and should be decided on planning grounds, not local politics.  They think they have met national criteria to justify releasing green belt, but acknowledge it requires the council to have exhausted all non-green belt options first.

They also claim that as part of a national trend, membership of the golf club has fallen in recent years, and that the members could be accommodated by the other Billings Group Golf Course at Redlibbets.

Other key proposals are:

  • New primary school and special educational needs school (the proposals have the support of Hartley Primary School because they say the exsiting site is unsuitable and moving to Corinthians will allow them to become a 3 form entry school to meet demand).
  • Retirement village of bungalows
  • 40% of housing to be "affordable"
  • Provision for self build housing
  • Parkfield road to be extended to Fawkham Valley road to act as a relief road for Castle Hill.  Additional road from Hemmesley's Yard to Fawkham Valley Road
  • "Satellite" GP surgery to offer services 8am - 8pm 7 days a week.
  • Community Allotments
  • Some business units
  • £3.5m for local authority from new homes bonus

No development poster at entrance to (Billings!) Bramblefield Estate

Appraisal of the Proposals

(a) Green Belt Policy

The Corinthians proposal would appear to fail at this first stage.  In the Government's Housing Policy Paper "Fixing the Broken Housing Market" it states that:

Maintaining existing strong protections for the Green Belt, and clarifying that Green Belt boundaries should be amended only in exceptional circumstances when local authorities can demonstrate that they have fully examined all other reasonable options for meeting their identified housing requirement

Since the Council's Strategic Land and Housing Availability Assessment document already identifies enough sites to build the 3,500 houses they are required to within the next 5 years, then Corinthians as a site is clearly not required, so it is difficult to argue that exceptional circumstances apply if all the council's approved sites go ahead.

It must be remembered though, that the limited extension of Downs Valley to the crest of the hill is one of the approved sites that they say can meet their housing target.  So to avoid Corinthians being built people may have to accept green belt building elsewhere.

(1.9.18) For the whole of the district plan term of up to 2035, the council has only just been offered enough sites to make the 14,000 target, so unless other sites come forward or neighbouring councils offer to take up some of Sevenoaks's target, then it seems the council must approve the whole of the Corinthian site in the longer term (Source: Draft District Plan, chapter 1).  

(b) Housing Need

Clearly the need for more houses, and in particular affordable housing, is a national priority recognised by the main political parties.  The evidence is that demand will still be there, even if immigration were to fall.  If you privately rent in Sevenoaks, a massive 52% of your salary will go on rent on average, which is way above anywhere else in Kent.  Homebuyers in Sevenoaks need more than 13 times the average income to buy a median priced house (ONS - Housing Summary Measures)

While most people agree with the principle, many will say they should be built "somewhere else"!  And to be fair, this is what the call for sites does, it asks local people to decide which of the offered sites are most appropriate.  What will not be acceptable to the government is if the council doesn't allocate enough sites to meet their target.

What are local housing needs?  Developers will always want to build larger houses as they are most profitable to them.  Policy 8 of the draft District Plan expects houses to be built in the following proportions: 1 bed (15-20%), 2 bed (25-30%), 3 bed (35-40%), 4+ bed (15-20%).  Also it is common for developers to get councils to reduce low levels of affordable homes even lower through "viability assessments", where they argue that the project isn't viable unless fewer affordable homes are built.  These are kept secret from the public, and by implication anyone who could test the accuracy of the claims (New Statesman "Developers are using a trick to get out of building affordable homes", 10.7.2017).  In this case it would be hard for the developer to argue land acquisition costs were too high because they bought both sites as agricultural land in 1949-1950.  The Downs Valley land cost about £100 an acre where as building land it will be worth nearer £1 million an acre.

It is clear that the real need in Hartley is not for large houses but for small ones.  This was the finding of the Hartley Parish Plan.  

A lot of work locally on housing needs is contained in the Sevenoaks Local Housing Needs Study (2017).  The aim of this document is "to equip the Council and their partners with robust, defensible and transparent information to help inform strategic decision-making and the formulation of appropriate housing and planning policies." (para 7.1)

The study found that the lower quartile price for Hartley ward was £365,000 (if there were a 100 sales arranged from cheapest to the most expensive, the lower quartile would be the 25th cheapest).  This means that the household income required to buy is £94,000 or £61,000 with Help to Buy, this puts housing out of reach for many first time buyers.

The Housing Needs Study (paragraph 5.12 ff) also gauged local demand by asking people what sort of house they would like to live in and what sort they expected to live in (usually smaller than what their aspiration was).  They then compared it with the current housing stock.  What they found is that the North East part of the borough (including Hartley) had no need for additional 4 + bedroom houses but a shortfall of smaller ones.  They estimate the North-East part require an additional 158 affordable houses each year over the next 4 years, 131 general needs and 27 for older people.  This would be split 60% for rent and 40% for intermediate sale.

The age profile in the 2011 census shows a big lack of people aged 20-40 living here.  It is clear there is not enough affordable housing for younger people.  

More housing for older people downsizing is also a clear local need.  The Sevenoaks Housing Needs Survey found that about two-thirds of older people would like to continue living in their own home but about 17% would like to downsize (paras 6.25-6.30).  The size of the waiting list for Bramblefield shows there is a demand for smaller housing locally.  However placing the retirement bungalows at Corinthians would be some distance away from the services they would need to use.

There is a counter argument that the problem with the housing market is property speculation, which building more homes will not solve (see e.g. "Why building more homes will not solve Britain’s housing crisis", Guardian 27.1.18), but the council cannot use that argument to not plan for more houses.  However it does highlight the risk that even if low cost housing is built, it may not benefit the people it is meant to help, but be snapped up by foreign and British property buyers to become yet more buy to lets.

(c) Health Centre

The plan includes a "satellite" GP surgery but is thin on what this actually entails.  Without an attached chemist, its use would be limited, because people would still have to go to Longfield or New Ash Green to collect their medicines.  There is no evidence that the local GP partnership would want to use the site.

Largely out of the public gaze, health services locally are going to be reorganised by what are called "Sustainability and Transformation Plans".  The driver is partly to save money, but also to meet modern health needs.

STPs propose 3 levels of GP surgeries:
  • Small GP surgeries as now, some services offered by them now may in future be done by the hub surgeries.
  • Extended GP surgeries serving areas of 20-40,000 people.  This appears to be clusters of GP surgeries joined to offer longer hours and more services and integration with social care services.
  • Hubs, larger surgeries serving 50,000 people.  These would have out of hours servies, specialist GPs and offer minor injury care.

Where the proposed health facillity at Corinthians would fit into this is unclear. There would be a potential benefit to the area if it became one of the higher level surgeries with longer opening hours and more services, however Hartley's poor bus links would appear to rule it out being able to serve a wider area, which was a criteria when setting up similar clusters in West Kent.

However the local surgery thinks it at least does offer the opportunity to improve local health services, if the development is done properly (see press release):

This may represent an opportunity to improve the breadth and level of services we offer locally to our patient population. However at present, we are not aware of any planned extra provision for 8-8 seven day a week services. This is not something Jubilee Medical Group would ever provide directly.  Recently the local Clinical Commissioning Group (CCG) has opened 3 Hubs across the area which are beginning to offer 8am-8pm pre-bookable appointments from Monday to Saturday. Because of difficultly recruiting GPs this service is yet to reach full capacity but is improving week by week. In the future we would obviously welcome a local ‘rural’ hub shared by other local surgeries (ours currently being located in Gravesend), but again there are no current plans, funding or  agreement on location for this from the CCG.

(d) Roads and Rail

Roads is probably one of the weaker points of the developer's case.  Ash Road is a C class road but gets traffic levels comparable to many of the local A roads.  A recent traffic survey at Hoselands Green found there were 15,000 traffic movements per day with up to 1,400 per hour at the busiest times (sum of traffic going north and south).  

In the 2011 Census there were 2,672 workers in Hartley, of whom 2,028 have to commute outside Hartley.  Of the commuters 304 take the train, 75 take the bus and 1,426 drive.  For drivers the most popular employment destinations are Dartford/Bluewater (280), Bexley borough (150) and Gravesend/Northfleet (123).

If we assume about a third increase in this number it would suggest another 100 passengers at Longfield, and 500 extra peak hours car movements.  

It is difficult to argue that this would cause significant problems at Longfield station as this would represent about 10 extra passengers per rush hour train (the developers say they are talking to rail industry about any effects).  The overall effect of development in Kent is a concern for the railways though.  Up until 2024 they say the increase in passengers can be accommodated (at a cost) by lengthening trains to 8 and 12 carriages long.  There is clearly scope for this at Longfield as some rush hour trains are only 4 or 6 carriages long.  Although not all trains can be 12 carriages because many stations cannot accommodate them, this in part includes Victoria, where some platforms are only 8 carriages long.  In the longer term they think capacity issues will be "challenging", which will require trying to eke out more train paths from the existing infrastructure (Source: Kent Area Route Study, Network Rail 2018)

However the effect on the roads is likely to be much more serious.  With its distance from services, it is unlikely anyone on the Corinthians estate will not use their car to go to the shops etc.

The proposals are for some traffic to be directed to the C Class Fawkham Valley Road, which has its own problems of no pavements and a width restriction at the railway arch at Longfield.  (1.9.18) Billings Group have now offered to "improve" Fawkham Valley Road, but there are no further details on their website.

How much would the alternatives be used?  You could imagine a scenario where people from New Ash Green and Hartley travelling to Dartford or Bluewater might find it quicker to cut through the Corinthians estate or Parkfield and bypass Longfield thus maybe reducing traffic on Ash Road, but not if traffic is slow because of the pinch point at the rail bridge.  On the other hand, there would be additional traffic for those heading to Longfield Station, Longfield shops, Longfield School and Gravesend.  The conclusion is that the amount of traffic on Ash Road will rise.  However the developers do not appear to have done any traffic modelling work.

(1.9.18) NHE have raised concerns about increased vehicle pollution.  I think there are a number of reasons why this is unlikely to be the case.  The precipitous fall in sales of diesel vehicles, entailing the gradual withdrawal of existing diesels, will have great benefits in vehicle pollution levels, although not for CO2 emissions.  But in the longer term it is clear the number of hybrid and electric vehicles will rise sharply, and with it a fall in emissions to cancel out the greater number of cars locally.

There is clearly a need for an alternative route to Ash Road to access Hartley which was strongly supported in the last Hartley Parish Plan, as Castle Hill gets jammed when there is a problem on Ash Road.  However although the proposals appear to partly address this problem, they may have created another by creating a new access onto Castle Hill for a large number of houses.  (1.9.18 - In the latest proposals the Castle Hill link has been withdrawn).

The developers have floated the idea of a cycle route, which would be a very good idea for cyclists if it can by-pass Hoselands Hill.  Also welcome is the proposed pedestrian access to Longfield station, although the council will need to be very sure that the developer can deliver this, as the land in question is currently unregistered and therefore ownership is not clear.

Clearly the developers need to do a lot more research on this and come up with better proposals.  Many developers provide improvements to local public transport to minimise the number of extra cars on the road.

(e) Utilities

The NHE leaflet says "there is currently a severe problem with providing water to this area".  This is presumably a reference to South East water area being designated one of serious water stress, requiring compulsory metering (within the SE Water area, Hartley is an area where the water stress is serious).  

However my suspicion is that this development would not be objected to by the water company.  They have recently published a draft "Water Resources Management Plan 2020-2080".  This plan takes account of local authority housing targets, and appears to imply they will just live with them and plan accordingly.  They will shortly have a windfall of 9 million litres a day for domestic use from the former newspaper print works at Aylesford and in the much longer term believe they can get 30m litres per day from desalination works on the tidal River Medway (but acknowledge it is a very expensive process). They also forecast a fall in household average consumption.

I think Hartley's waste water goes to the Long Reach facility at Dartford.  According to Kent County Council, this is already being expanded to support housing growth.  Again it says development plans up to 2023 have been taken into account by South East Power Networks in their plans to meet increased gas and electricity demands.

(f) Effect on Grade 1 Listed building

The Billings Group own half of the meadow adjoining Fawkham Church, which is nearly 1,000 years old and is next to the Baldwins Green local conservation area.  The original plans did not envisage building there, but have since been amended to be filled up with houses.  Given the heritage value of the site, these plans in particular should be resisted.

(1.9.18) Since first suggested the applicants have withdrawn the proposals to build here and suggest some community use instead.

(g) New school

NSE says a move would be "upheaval" but it must be said the proposed new school site has the support of Hartley Primary School and its parent Leigh Academies Trust.  This is understandable given the buildings are mostly 50 years old, and so at the age where they will need much more maintenance.  The constrained nature of the site also causes difficulties with traffic.  Similarly Milestone School has parking difficulties, especially given its wide catchment area, and Leigh AT claim the current site needs considerable investment to bring it up to date.  It is suggested the new site will allow the school to expand, although whether it would need to without the extra houses is uncertain.  The effects on the nearby primary schools at Longfield, New Ash Green and Fawkham is also unclear; they may be affected by competition from the larger academy school.

Currently the Round Ash Way site is owned freehold by Kent County Council under a lease to the Leigh Academies Trust.  Presumably (this is not entirely clear) this would revert to Kent County Council if the school were to move.  The chances are then that both existing school sites would be available for further housing development, although policy 14 of the Draft Local Plan does say that they will have to consider community use first.

A leaflet from NHE says the new site would be away from the community and "unsustainable".  This is less likely to be the case with Milestone School, which has a very wide catchment area (an FOI request of the Department for Education revealed that only 6% of Milestone pupils live in the DA3 area).  It will probably result in an increase in the numbers of pupils at Hartley being driven to school, but from the congestion around the school at the beginning and end of the day, it would appear this already occurs to a large extent.  Leigh Academies Trust say:

"The relocation provides an opportunity for ample parking and dedicated pupil drop-off/collection access, thus minimising  isruption to the academies and
surrounding residential areas." (July 2018 newsletter, page 13)

(h) Country Park

One of the NHE leaflets says there is enough open space already in Hartley, which may be true for the east side, is less so for the west, especially since the landowner stopped informal access to the fields at Downs Valley, following the Parish Council's village green application at Hartley Wood.  

They also say it will cost money to run, which is true.  The parish council spends about a quarter of its income on maintaining the current open spaces.  However the cost could well be the subject of any section 106 agreement between the developer and Sevenoaks Council.  How much it costs to run very much depends on how the land is used, especially if part is retained in agriculture.  The 65 acres of Northfield have cost an average of £5,500 to run in the last 4 years.

Ownership could be a key issue here.  It is not clear whether ownership will be retained by the developer or transferred to the public.  The title deeds of some properties in Downs Valley contain a statement that Old Downs Wood would be transferred to the community on 99 year lease, but this has not happened.

(i) Village "atmosphere"

A perceptive councillor from outside Hartley once said Hartley is the sort of place people who live there call a village, but outsiders will see something more.  Certainly Hartley is not a village in the mould of say, Stansted or Fawkham.  I am told some people in Fawkham refer to Hartley as "the town on the hill".  In the decades I have lived in Hartley, I have seen the place become more and more urban.

While a 30% increase in population is a shock for any community, a smaller number of additional people living here is not necessarily a bad thing.  It would certainly help the sustainability of many local services, as well as local clubs and societies, which seem to be constantly under threat. But of course this needs to be balanced against other factors.

Sevenoaks's appraisal of the Corinthians site in the SLAA raised a fundamental question as to whether the site would be capable of being integrated into the wider Hartley community, because of its location.  However they felt this objection does not apply to the limited extension of Downs Valley option.

(j) Section 106 agreement

In big developments, the council usually gets the developer to sign an agreement under section 106 of the Town and Country Planning Act 1990.  This allows councils to require the developers to build so many affordable homes, or pay monies to meet the effects of the development on the wider community.  This might be road improvements, contributions to bus and train services, car share schemes or improvements of local amenities such as repairs to Hartley Village Hall.

For example in the old Longfield School site, the developer promised to build a proportion of affordable houses; while in the Waitrose Supermarket site, they agreed to allow free parking for 1½ hours and public access to the toilets at the shop.

Developers naturally try to minimise the amount they have to pay on viability grounds, but as mentioned in paragraph (b) above, in this case the current site owners should be able to afford a large contribution because of the low land acquisition costs.

(1.9.18) A Section 106 agreement would hopefully meet the concerns of NHE as to whether the community facililties will ever be built.  Often these agreements are worded so they can't built any houses until the community facilities are built.

(k) Golf Course

It is difficult to tell from the filed accounts whether Corinthian Sports Club Limited makes a profit or loss, due to the small amount of detail the government now requires and the fact it is part of group of companies which deal with each other.

They are right that nationally golf is declining in popularity.  The numbers playing golf have fallen by 27% in the last 8 years.  The applicant is not about to share membership statistics with the wider public though, so it is impossible to know whether Redlibbets could take over the existing Corinthian membership.

(l) Sports facilities

This tends to get lost in the arguments about housing, but perhaps a bigger issue than it seems.  Part of the proposal is for a new sports club at Corinthian including a 3G sports pitch and indoor racquet and sports pitches - and a sports bar.  The NHE expansion group in their 2nd leaflet have objected to this because of the perceived threat to the Hartley Country Club and other facilities locally.  It is certainly noticeable that a lot of the opposition to the proposals have come from this direction.

From their latest accounts (2016) the Country Club made a profit of about £9,000 and has about 930 members.  Its membership has declined modestly by about 100 over the last 10 years.  Most of its income is in membership fees, and from bar and catering.  Clearly if the Corinthian Sports Club took customers away from them then their profitability might be threatened.  Normally it is not the purpose of the planning system to protect businesses from competition, but this is slightly different in that the facilities being offered are meant to benefit the community to compensate for the loss of green belt.  The Sevenoaks Playing Pitch Strategy document found that local tennis facilities at Hartley Country Club and New Ash Green are very underutilised (table 7.3).

Of course the Country Club is a private members club with fees which may deter sections of the community, but there is no guarantee the Cornithian club will not be be same.  In their favour though is the fact that they appear to be offering some facilities not available at the Country Club.

(m) Commercial land

Looking at the current map and the proposals, it appears one area containing 0.28 ha (0.63 a) at Chapelwood Enterprises would be lost.  However the proposals do envisage a modest increase in employment land to 1.34 ha (3.31 a) which is to be welcomed as there are a lack of local employment opportunities.  As an edge of settlement development it would meet one of the three criteria of paragraph 6.7 of the draft district plan.  If the units include office space then the district council would definitely be interested (para 6.9 of the draft district plan).

Confusingly this is not one of the employment sites listed in draft plan policy 13.

Overall summary

My view is that the developers have not demonstrated that the full 800 house development option will work.  Sevenoaks have already identified enough houses in the Strategic Housing and Land Assessment to meet their target for the next 5 years, so additional building on the green belt is not necessary.  I think they have not sufficiently explained how the Corinthian developmernt could integrate with the rest of Hartley, and how the problems of new development can be removed or mitigated.

I do believe there is an arguable case for a much more limited number of new houses in Hartley, provided they are mainly affordable housing and not snapped up by buy to let landlords.  Undoubtedly the country is in urgent need for more affordable housing for young people and the elderly, and Sevenoaks is an area more in need than most.  Since the land acquisition costs were minimal we have a golden opportunity to maximise the number of affordable units.

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