The Site’s Importance
The open, amenity land along Princes Parade is important for many reasons, but principally:
· It is an area of environmental importance,
· It is important as a habitat for wildlife,
· It is the only significant area of open green space in Seabrook,
· It gives an excellent vista,
· It provides a “buffer zone” between the sea and the Royal Military Canal
· It is a recreation space of locals and visitors,
· It is of historic importance because of the Royal Military Canal
The Planning Position
In 2003 Shepway Council attempted to develop the site for valuable, beach front housing.
These development plans were stopped after many local people objected and the report of 2004, Government Planning Inspector said that “it is one of the finest vistas in the district”. She agreed with the previous Inspector that “residential development would be out of character with the site’s open nature” and said “this part of Seabrook is deficient in every sort of public open space.” She concluded “I find this is one of the rare occasions when the need to preserve the open character of a site, and its relationship to both the sea and the canal, is so important that it outweighs the imperatives of PPG3”
Many local people say, this is a very conclusive statement and is even more relevant today than it was in 2004, because of the residential development which has taken place around the site: on the golf course and on the Corniche, the increase in development activity all around the site means the Planning Inspector’s conclusion has even more significance today than it did in 2004.
As a result of the Inspector’ comments most of Princes Parade was designated open space (under policy LR9) with a small part being covered by TM8 (recreation).
Shepway DC are currently working on their new Local Plan. This will include reviewing those saved polices. The Core Strategy which is the basis of the Local Plan was agreed several years ago and envisages around 8000 new homes in Shepway over the period 2006 to 2030. However we understand that the Core Strategy is itself under review. In Jan 2015 Shepway held a public consultation into the Issues & Options stage of the Local Plan. This included a question on leisure facilities on Princes Parade. There were a relatively high number of responses to this option, the vast majority being against development on Princes Parade. Another consultation is currently being carried this time on the preferred options stage of the Local Plan. Princes Parade has been included as a potential development site for a leisure centre and 150 houses.
A New School
Seabrook Primary School is an excellent school enjoying a high reputation locally. A new location for the school has for many years been earmarked at Eversley Road. Planning permission was granted for a new build on this site but KCC pulled the plug at the last minute as it turned out they didn’t in fact have all the necesssary funding.
We don’t deny that the school needs a new building and respect their decision to keep an open mind about all the options but we believe that the Eversley Road site is more suitable and safer than Prince’s Parade (a former landfill site.)
The agenda papers for the November 2015 cabinet meeting conceded that a new primary school on Princes Parade was not financially viable.
A New Swimming Pool
Shepway Council say that the swimming pool in Hythe needs to be renewed. The developers of Nickoll’s Quarry/Martello Lakes are obliged to make a s106 contribution of £3.2m towards a sports,leisure and community facility as well as donate land on which this facility will be built. The developers have paid for a study looking at the best site for the new pool: the existing site, Nickoll’s Quarry or Prince’s Parade. (This report is now on our documents page.)
In December 2012, the Shepway cabinet voted to accept the recommendation that the pool be built on Prince’s Parade. The recommendation was for a leisure centre that will cost at least £12m but there was no discussion as to how this might be funded. A later consultants report reduced that estimated cost to £8.8m but excluded some vital items.
There was no public consultation about the preferred site of the new pool and we don’t believe the proposal to include a new leisure centre on Prince’s Parade is financially viable.Because of its history as a landfill site, Princes Parade will be very expensive and risky to develop.
As part of the planning permission for the Nickol’s Quarry development to the west of Hythe, the developers have agreed to sell Shepway a plot of land for £1 for the construction of a new lesiure centre. This would be much cheaper and easier to development than Princes Parade and would better match the need for a pool on Romney Marsh.
In November 2015 Shepway’s cabinet approved a recommendation that the preferred site should be The Green in Hythe. This is owned by Hythe TownCouncil who later agreed to make the land available to Shepway. Shepway submitted a planning application to themselves before HTC had agreed to let them use the land but in the end the proposals came to nothing – we believe connected to a covenant over The Green.
Here are some links to some relevant stories in the Hythe Herald from 2010:
The Royal Miliary Canal is a scheduled ancient monument. Historic England (previously English Heritage) have serious concerns about developing Princes Parade – more info here.
Shepway’s Core Strategy states
Brownfield Land (also known as Previously Developed Land) – land which is or was occupied by a permanent structure. A full definition is given in national policy.
The National Planning Policy Framework (NPPF) with which all planning must comply has a similar definition.
Flooding and Contamination
Some people are concerned that the site is not suitable for development because of comtamination from the old landfill site and because of the risk of flooding.
The Environment Agency classifies the site as Flood Risk 3.
This is an extract from the consultants’ environmental report http://saveprincesparade.org/wordpress/wp-content/uploads/2012/09/urs_environmental_report.pdf :
The location of the site within Flood Zone 3 means there would be a presumption against development for more vulnerable types of development (e.g. housing, schools) in favour of developing sites within the Shepway administrative area at lower risk of flooding.
Where SDC can demonstrate through application of the ‘sequential test’ and ‘exception test'(detailed in the National Planning Policy Framework (NPPF) that there are no other alternative or more suitable sites for development within the borough, then it would be possible to develop the site. Part of the evidence that would be used to inform the exception test would be data on the hazard to the site.
Should development of the site proceed based on the current SFRA Flood Zone 1 hazard classification of the site, data on the hazard should also be used to ensure the most vulnerable types of development are guided to the areas of lowest hazard within the site. Hazard mapping should be used to assist the siting of development types across the site, this would categorise the flood hazards present on the site arising from a flood (i.e breach of local coastal defences) enabling Master Planners to site vulnerable development types (e.g. housing) in those areas of the site with the lowest hazards, whilst areas of relatively greater hazard could be used for other low risk land uses such as car parks, leisure facilities or public open space.
The latest (July 2015) flood risk assessment for Shepway still shows Princes Parade in flood zone 3 :
and the flood map:
and the flood hazard map:
The contamination study included in the intial Princes Parade report is almost entirely based on a study carried out by Ground Solutions Group Ltd in 2002 which URS admits is out of date. Shepway did not pass on the whole GSG report to URS – the appendices and figures were missing.
Eventually Shepway commissioned a new contamination report which you can read here.
Table 9 summarises the possible pollutant linkage.
It identifies a low risk to the health of current users from heavy metal and hydrocarbon contaminants but one of the claimed mitigating factors is that the site is fenced. It isn’t and won’t be if and when it is developed.
It identifies a low to moderate risk from the same contaminants for future residents and construction workers. The mitigating factor here is that the proposed scenarios suggest predominantly hard landscaping and limited landscaping. Given that one of the supposed aims was to enhance the open space this was never going to be true. There are several references elsewhere in the report to the fact that the houses won’t have private gardens. Really?
As regards protection of construction workers para 7.8.1 recommends that dust levels are kept within statutory limits but the site is often very windy and this does not seem to have been taken into consideration.
A moderate risk of groundwater contamination from vertical migration is identified from all forms of contamination. The report proposes further monitoring. Has this been done?
A moderate risk was identified of hydrocarbons being able to permeate polymeric pipes which could have serious implication for drinking water supplies.
A low to moderate risk of elevated carbon dioxide has been identified and further monitoring recommended. Has this been done?
The Loss of Amenity Land
The key issue to understand is that the land is currently open, public amenity land, once planning permission is granted for any form of development that open, public amenity land is lost and will never be recovered.Many local people are concerned that even if it was just a new swimming pool which was built on the land, this would set a precedent and housing would soon follow.
As the Planning Inspector said in 2004:
The site “…. is one of the finest vistas in the district”…. “residential development would be out of character with the site’s open nature” …… “this part of Seabrook is deficient in every sort of public open space.” …… “I find this one of the rare occasions when the need to preserve the open character of a site, and its relationship to both the sea and the canal, is so important that it outweighs the imperatives of PPG3”
Once any form of development takes place this open amenity land, with its unique wildlife habitat, will be lost forever.
This House of Parliament report sets out the health & other benefits of green infrastructure http://www.parliament.uk/briefing-papers/POST-PN-448/urban-green-infrastructure