Author: Lesley

The Environment Agency have objected to the new proposal to drain the surface water from Princes Parade into the canal. Read their latest letter here:

additional – EA – Jul 2018

The council have now released the Savills’ report from which the £14.3m figure for the revenue from the housing land is derived.

Savills Viability Assessment Report – 13.07.17

They have also released some other reports here under latest documents The council have quietly released some other documents here under latest documents http://www.princesparade.co.uk/plans.html

The unredacted document can be read here Financial Viability Report – unredacted

And with thanks to ShepwayVox some”confidential” pages from the officer’s report restricted-pages-145-148

The Princes Parade planning application won’t be on the agenda for the committee meeting on Tues 31 July after all. The new date is Thursday 16th August 7pm.

So our protest is deferred until then too  – 6.15pm. Please spread the word and display this poster (on private property only please – no flyposting) Protest Poster

The deferral seems to be connected to the publication of the unredacted version of the financial viability calculations which we will be looking at in detail.

Re the diversion of the road:

“As far as I am aware the council are in the process of writing to all objectors to the Order.

With regards to a public inquiry, no decision has yet been made.   As things stand the Order is on hold until the Council try to resolve the objections.   No Order can be made with outstanding objections or without a valid planning permission.

If there is a stalemate with regards to the objections then the Secretary of State would then issue a decision, following either a public inquiry or via written representation, however, he cannot do this until a planning permission has been granted.    If, however, there is an inquiry into the planning permission then we would also look to join that inquiry.    All parties will be notified of which route is to be taken as and when this happens.”

Having had a first read through of the officer’s report we think our biggest worry is the fact that he has just accepted the financial viability calculations at face value. So he has accepted that with the revenue from the housing land the leisure centre on Princes Parade will cost the council about £2m – that can’t be right.

And worse still he has accepted the outrageous cost the applicant is claiming it would cost to build the leisure centre at Nickoll’s Quarry.

The planning officers have apparently put questions about the financial viability calculations to the applicant but we don’t know what the questions were nor how they were answered.

The planning committee will be given a confidential appendix which we aren’t allowed to see.

But we are pleased to note that the report says that the emerging local plan carries limited weight in the planning decision because of the number of objections to PP being allocated as a development site. So a big thanks to all of you who took the time to submit a comment during the PPLP consultation.

A lot of the report is trying to balance the harm caused to the setting of the canal, the visual amenity etc against the benefits of the scheme – mainly the leisure centre. That is a very subjective decision and we don’t think it should be made by anybody at the council given the conflict of interest.

It would be so much better if the council would agree to defer the planning decision until the Places & Policies local Plan Inquiry. But of course that is why the council are trying to push the application through before then.

And why the applicant is trying so hard to prove that the leisure centre will cost so much more on NQ because if there is an alternative site then there is no justification for all the harm the development on PP will cause.

There are a number of other things of interest in the committee report.

It claims that new data shows that most of the site is in flood zone 1 not 3. Have we seen this data?

It states that the site will provide 30% affordable housing using funding provided by another site. We know that site is the Imperial Green development and what that means is that the offsite affordable housing requirement for IG will not be provided.

We don’t yet know how the Environment Agency feels about the new plan to discharge the surface water in the canal. They have said that where a 25m ecological buffer along the canal cannot be met then a 20m buffer will be acceptable. But the diagram published recently shows that the diverted road will be well within that 20m buffer for quite a bit of its length.

The council have also published a Design Review which we haven’t seen before. it is very scathing about the diversion of the road. You can read it via the link below.

https://www.folkestone-hythe.gov.uk/moderngov/documents/s28032/Appendix%202%20-%20Design%20Review.pdf

Finally, we have had this response from the MHCLG ” I have been monitoring the progress of this application for some time. The council has confirmed that should the committee be minded to approve the application on 31 July, it will not issue planning permission until the Secretary of State has had the opportunity to consider whether to intervene. “

Following the response to this FoI request,

https://saveprincesparade.co.uk/betteridge-milsom-foi/

we have been doing some more work on the Financial Viability calculations.

This is still not easy as most of the numbers have been redacted but the FoI material has given us some more clues.

There will be 4 phases to the development:

Phase 1 : Remediation of the site

Phase 2 : Construction of the leisure centre; realignment of the road and construction of the western car park; relocation of the rising main; new promenade; creation of the linear park

Phase 3: East residential development and central open space

Phase 4: West residential and commercial development and western open space.

We believe that the council are intending to develop the leisure centre themselves and then sell the housing land to a developer. They clearly believe that the sale of this land will generate sufficient money to cover the costs of  phase 1 and phase 2. (which from p766 of the FoI material is £26.8m). In other words they are assuming that the housing land has a significant value. (They acknowledge they will have to borrow money to achieve phases 1 and 2 until the housing  land is sold.)

However work done by Martin Arnold suggests that the project will make a significant loss after taking account of the cost of building the leisure centre and all the necessary infrastructure and preparation work. Download the Martin Arnold Financial Appraisal (pdf) here.

On page 801 of the FoI material there is a partly redacted summary calculation which shows on the income side £4.7m from the Nickoll’s Quarry s106 money; income from the sale of the existing pool site – redacted but which we know from other sources is about £5m; CIL from the PP site £1.184m (though we think it is incorrect to include this) and £1.4m being the Affordable Housing contribution from the Imperial Green devlopment (which shouldn’t be included – see below). Page 801 gives the total income as £26.6m,  the balancing figure being the land value for the residential plots. This works out at £14.3m which is confirmed on page 819 of the material.

As is stated on page 801, this income equates to the estimated costs for phases one and two although page 801 states that FHDC will need to contribute £1.7m plus funding costs.

With so much of the financial information being redacted, it is impossible to check exactly how the land value has been calculated and in particular which of the costs of phase 1 and 2 have been taken into account. But clearly it is crucial that the consultants have got this figure right. Have any significant costs been omitted? If so, this would mean that  either the land value is being overstated which would have serious implications for the viability calculation or that the council will have to bear the extra costs themselves.

The FoI material states on page 539  that an earlier Savills valuation was £8.7m taking into account the diversion of the road. Another  was £4.73m not taking into account the cost of diverting the road £2.9m. So how have they now come up with a figure of £14.3m?

One of the other worrying things about the financial viability calculation is that it includes £1.4m s106 money.  It’s now clear that this is  the off site affordable housing contribution from the Imperial Green development. But surely the council aren’t intending to build the AH from both the Imperial and the Princes Parade developments on PP? There are two possible implications from this. One is that no affordable housing is being provided for IG which is contrary to the Council’s planning policy. Or, that instead the IG affordable housing is being built on PP , and that actually the PP development itself is not generating the required number of affordable housing, which is also contrary to policy.

The council’s consultants are arguing that the housing is needed to fund the leisure centre. However, as Historic England have pointed out, the NPPF only allows for enabling developments in the context of improving heritage assets.

The other area of major concern to us is that most of the planning application (including the housing) is outline only. This means that when the council sells the housing land to a developer they will effectively be giving them a blank cheque and will have limited control over what eventually gets built there.

In terms of the development and understanding the associated costs, the Council is engaged in an evolving process . Cabinet did not have access to any financial viability information when they made the decision to submit the planning application and have not yet discussed the financial implications – at least not in a  public meeting. The costs and income of the project are still very uncertain and we are concerned that the council are rushing ahead with this proposal without having fully investigated the implications.

We have just submitted, on behalf of SPP, some comments on the new documents that were published earlier this month.

We have objected to the proposal to drain the surface water into the canal (previously the intention was to drain it into the sea); we have raised some concerns about the ecological mitigation timetable as it’s not at all clear to us how this fits in with the proposed work plan; we have raised the issue of the loss of maritime grassland as we don’t feel that it is possible to mitigate for its loss; we have raised concerns about the fact that the applicant is trying to leave lots of major decisions to the conditions/reserved matters stage (ie planning permission could be granted with the outcome of these matters unknown) and perhaps most importantly we have flagged up that the ecological buffer zone along the canal will be much less than the 20m stipulated by the Environment Agency.

You can see the new documents (and our full comment when it is uploaded) here https://searchplanapps.folkestone-hythe.gov.uk/online-applications/applicationDetails.do?keyVal=OV593HNZKSO00&activeTab=summary