The fields at Brickfields, pictured here in October 2014, are not a building site, they are Grade 2 (very good) agricultural land within a Conservation Area and an AONB.
On Saturday many Bridge residents received a copy of the Consultation Draft of the new Neighbourhood Plan. The plan is a proposal for a legally binding document, covering the future direction of a variety of aspects of our village for the next 16 years, and it has been put together by a committee, some of whom are not elected members of Bridge Parish Council and are not named in the plan so, unfortunately, we have little idea of who they are and what are their interests and associations. We understand that Bridge Parish Council itself has not yet approved the draft plan and they will vote on whether or not to formally adopt the final plan at a later stage.
BridgeNature.org being an advocate of environmental protection, our particular concerns within the proposed plan concern any proposals for building development on green field land in the area and any other policies which may have environmental impact in our Area of Outstanding Natural Beauty and green spaces. In this respect one might initially be reassured by the statement on page 16 of the plan which says:
“The Neighbourhood Plan will continue to oppose any development in the Area of Outstanding Natural Beauty (AONB) on the south side of Canterbury to maintain the existing open space.”
Bridge is of course within the AONB on the south side of Canterbury. It is astonishing then to discover these policies put forward in the plan:
To support further development at Brickfields, Mill Lane for more affordable, rentable family homes with local connection restrictions.”
To support the small-scale development of ‘retirement’ dwelling units that allow local people to down-size but stay within the community.”
To provide at least one small home with two or fewer bedrooms for every one large dwelling with four or more bedrooms.”
BridgeNature.org greets these policies with dismay, and we remind readers that Brickfields is green field land in a Conservation Area within our protected AONB. Building on such land is not permitted in law unless a case can be proven for exceptional need to do so. Section 14 of the National Planning Policy Framework 2012 (the current law) states:
“14. At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking.
For decision-taking this means:10
●approving development proposals that accord with the development plan
without delay; and
●where the development plan is absent, silent or relevant policies are
out of date, granting permission unless:
–– specific policies in this Framework indicate development should be restricted.9
9. For example, those policies relating to sites protected under the Birds and Habitats Directives (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park.”
The Neighbourhood plan’s next policy, Policy 5 appears to create more confusion:
To make maximum use of brown field sites for housing development and not support building on green field sites unless they have been designated as exception sites. (Policy C2 above).”
Referring back to ‘Policy C2 above’ which supports building on the field at Brickfields may give readers the impression that Brickfields has already been marked for housing because it has been designated as an ‘exception site’. This would be a misunderstanding of the facts. The National Planning Policy Framework 2012 allows for local authorities to make exceptions to planning restrictions on green field land if a need can be shown for small scale rural developments of affordable housing, providing a number of other strict criteria can be met. Any area of such building would be an ‘exception site’. Brickfields has not been the subject of any formally accepted application or legally verified investigation of these criteria since the introduction of NPPF 2012, so to label it a designated exception site would be wrong. Amidst this confusion, by saying that it will… ‘not support building on green field sites unless they have been designated as exception sites’ Policy 5 can be read as indicating that the plan will support building development on any of our local green fields, all of which are potential ‘exception sites,’ if special need and criteria can be proven by interested persons. This is an alarming confusion.
So what are the special circumstances which would justify building more housing on protected green field land? Primarily affordable housing for locally connected people if a need can be shown. The plan indicates that the current affordable housing was over subscribed. Surely this is inevitable: there is no doubt that the country is short of housing and lots of people with some family or historical connection to Bridge would like to live in brand new, affordable housing overlooking beautiful countryside. But that doesn’t explain an exceptional need to build within a Conservation Area and AONB here in Bridge when we are about to see 4,000 houses built a short walk away just across the A2 at Barton Farm. There are few jobs in Bridge and we only have one school which has limited places (at primary school level only) so any new residents are likely to travel frequently to Canterbury past Barton Farm in any case for work, schooling, shopping and other activities.
By law, any new affordable housing development must comply with sustainability guidelines. The land at Brickfields and other fields on the edge of the village has been shown not to comply with those guidelines on a whole range of criteria because housing there would inevitably exacerbate our water, drainage and sewerage infrastructure problems and place a further burden on our school, medical and transport facilities while encroaching on the green fields of our AONB.
One might have assumed that last winter’s flooding disaster, right through the Nailbourne Valley, with groundwater and sewage entering people’s homes, might have put paid to any further talk of housing development in the area, so it is astonishing that it should be proposed now. However the plan adds a caveat on page 9.
” In view of recent flooding in the village (2000/1 and 2013/14) the plan will campaign vigourously to ensure that any new housing development has adequate drainage and sewerage facilities….”
It goes on to list some of its demands in Policy E2 indicating that: Surface water is… only discharged into the ground. Surface water will not be permitted to discharge …into the Nailbourne, …the water gully, …a combined sewer …the foul water system.
So where do the authors of the plan think the surface water from these developments is going to go, and what are they going to campaign for? The plan advocates Sustainable Drainage Systems (SuDS) for any new homes. So, what are SuDS? Essentially they are areas of nice green space that soak up the water; a great idea in cities, but on the outskirts of Bridge green space is exactly what the new houses would be covering up! The idea doesn’t make sense, because SuDS are primarily about creating green spaces within large urban areas so that water doesn’t drain down the streets and overpower the drains. At Brickfields any drainage or groundwater released into the fields will simply drain down to the river upstream of the village adding to the already serious flooding problems of Bridge, Patrixbourne, Bekesbourne and beyond. This proposal would merely add to our flooding problems and any implied guarantee that ‘the authors of the plan will campaign vigourously’ for better drainage is sadly rather meaningless.
Brickfields Close. Inevitably run off from this area all runs downhill to the Nailbourne.
Regarding the Brickfields land itself, it seems there are some perpetuating myths about it which abound within the village and should be dismissed for what they are:
Myth 1: Brickfields is a brown field site.
Not true. Apart from the footprint of Brickfields Cottage, the fields are by law green field land in agricultural use. The fact that they were once used for digging up clay to make bricks no more makes it a brown field site than if it had been used for digging up potatoes.
Myth 2: It’s written into the deeds of houses in Western Avenue that houses can be built on Brickfields.
Not true. The covenant on house deeds in Western Avenue was an agreement between the home buyer and the builder in the 1960s that the builders could build more houses in the area if they got the necessary permissions. Any such private agreement does not imply that planning permission was granted, will be granted, or should be granted by the Local Authority 50 years later. Furthermore planning law has changed dramatically since the 1960s, particularly in regard to restricting building developments in Conservation Areas and AONBs so there is much more legal protection on the land today.
Myth 3: Brickfields is just waste ground which was designated for housing in the 1960s.
Not true. The land at Brickfields is Grade 2 agricultural, green field land in agricultural use and it has been rented on a long lease for that purpose. (Grade 2 is the second highest level out of 7 effective classifications. Half of the farmland in England is Grade 3.)
Myth 4: Canterbury City Council own the land so they can do what they like with it.
Not true. Even Canterbury City Council must comply with national planning law including special protections for Conservation Areas and AONBs. Should they attempt to bypass these laws it is the duty of Bridge Parish Council and our residents to stop them.
BridgeNature.org was created in order to champion and campaign for the protection of our local countryside, so we must speak out on this issue. We understand that people need housing, but we find it extremely disappointing to be presented with a plan which advocates building houses on a protected green field within our own AONB when there are already proposals to build huge numbers of new houses in the district, including 4,000 homes a short distance up the road. For many of those new residents Bridge village centre will be nearer and more convenient than the centre of Canterbury. Any new housing in Bridge will only add to the infrastructure and welfare problems of our village.
We urge Bridge Parish Council to reject this plan in its current form and to state within a revised one that it does not support any further building on green field land within our AONB. We also ask residents to voice their opinions against these building proposals in the questionnaire enclosed with the plan and at a consultation session with the plan’s authors at Bridge village hall on Saturday 1st November between 10am-1.00pm.