Proposed Modifications to the Thanet Local Plan

Document Section Main Modifications Strategy & Implementation MM/004 MM/004 [View all comments on this section]
Comment ID 222
Respondent Gill Gray - Westgate-on-Sea To… [View all comments by this respondent]
Response Date 27 Jan 2020

MM004 Main modifications

The Town Council completely disagrees with this approach. The Local Plan must be correct from the start and therefore if TDC needs an extra 6 months or longer to get it correct, then we would respectfully ask that it is granted this time.

If this local plan is just signed off simply because we can “Get it done” and “we are fed up with it dragging on”, then we risk unnecessary developments being agreed without proper policies attached.

As an example of this is Thanet Earth. These are large greenhouses positioned at the entrance to Thanet and are a massive light polluter in the area. Despite recent changes in the law to stop light pollution, these laws cannot be applied retrospectively.

However, this example is nothing in contrast to the impact of climate change, the biggest challenge that we are facing today. If we do not apply our current knowledge and change our behaviour NOW, this local plan will be a farce.

We know that there have been two significant changes in the world since the Local Plan was initially drafted in 2015 and we will discuss the most important first.

  • The government declared a climate emergency. We are now aware that we are heading to climate disaster and that if we do not do something about it, our world will be a very hard place to live for our children and grandchildren.

Please see the following text taken from evidence published by the Intergovernmental Panel on Climate Change reports last year:

On Oct. 8, the Intergovernmental Panel on Climate Change (IPCC) released the much anticipated Special Report on 1.5°C in Incheon, South Korea.

The report shows that climate change has already caused global temperatures to rise about 1°C above pre-industrial levels. Unless emissions are rapidly reduced, temperatures could rise 1.5°C by 2040, 2°C by 2065 and 4°C by 2100.

It’s hard to be certain what this level of temperature rise will mean for the world’s natural systems, economy and human society. In the past, it has taken thousands of years for temperature to rise by a few degrees, and big changes are already occurring as a result of a 1°C increase. Scientists say that the impacts will be much worse at even 2°C than previously projected. That means 2°C, let alone 3°C or 4°C, is no longer a safe goal to avoid the worst impacts of climate change. We can avoid much, but not all, of the loss and risk of climate change by limiting warming to 1.5°C.” quoting reports from:


The Local Plan is unsound for the following reasons:

Agricultural land

The impact of climate change on food production could be severe and there could be wide ranging food shortages. We cannot accept a local plan that does not plan properly for our future and our children’s futures with regards to food security.

NPPF and agricultural land

The NPPF is a framework to which we work, however, we must be clear, the idea that we can build on large areas of agricultural land is NOT promoted in the framework.

The framework states that lower quality land should be used first, before higher grade agricultural land. The framework was aiming to prevent building on top quality agricultural land unless absolutely necessary. In the sustainability aspects of the framework, we see further statements preserving the environment and farming. The over-arching idea of the framework is to be sensible in the use of agricultural land for economic purposes and housing, and to balance it with the need for self-sufficiency.

We would suggest that the authors of the framework, did not envisage a district where there was only the best and most versatile agricultural land to build on, as is predominately the case in Thanet. The authors would not have been able to think of every unique scenario in which the framework needed to be applied.

We cannot be sure, but we believe that the authors would be disappointed to find that the framework was being used to allow lawful destruction of great swaths of the best and most versatile agricultural land in the South East of England.

We disagree that the plan should be signed off, as it is unsound with regards to its environmental sustainable credentials. The NPPF was not set up to be used to destroy large areas of grade 1 and 2 farmland, and, to try to twist it in this way is not sound application of planning law.

Residents all over Thanet understand that some housing is needed but a very large proportion believe we should not use the prime agricultural land. They feel very disempowered by the lack of effective localism with their concerns and desires being continuously ignored.

The  table below has been collated from the new Sustainability Appraisal (December 2019) and shows that nearly eight thousand dwellings are intended for the best and most versatile agricultural land from the strategic and other larger sites. This list is not exhaustive and therefore there will likely be much more than 8000 dwellings. This level of destruction of agricultural land within one a district is unacceptable. Grade 1 agricultural land is an asset to the UK and should be protected.

The Sustainability Appraisal also shows that the 2000 houses at Westgate will results in a direct loss of 3.17 % of total best and most versatile agricultural land used within Thanet and this will be a significant adverse effect (p62).



number of dwellings


Manston Green












Land at Manston Court Rd/Haine Rd



Land North and South of Shottendane Rd



Westside of Haine Rd, Ramsgate



South side of Brooke Ave, Garlinge



Tothill Street, Minster



St Nicholas



Total planned sites (>30 dwellings) on agricultural land



The application of the NPPF

We understand that the NPPF should be applied to planning in the UK as a whole, however we also realise that a framework is not a one size fits all solution. As we have stated before, the NPPF may work well with larger areas with a variety of land types, such in a Kent wide plan, however when we try to apply the framework to smaller and smaller areas it is not effective. This is the same with any rule applied to social or biological or even statistical systems. It may be statically correct that x number of people behave this way under X circumstances in the general population, however in taking a small sample of people these statistics and rules do not apply. They simply do not have enough statistical power. It is the same with the NPPF – it is being applied to a very unique, small island which has many geographical limitations. The framework does not apply and to force it is unreasonable.

This does not mean that the framework needs completely revising, it simply requires, where necessary, a unique application in unique circumstances. The Isle of Thanet is one of those areas.

Raising sea levels

Across the world sea levels are rising displacing coastal communities and other low lying areas. As we know, the Isle of Thanet was originally an island accessed by the river Wantsum. It is possible that we will become an Island again.

It is therefore imperative that housing is planned for with this in mind. This requires more than just taking into account the flood risk zones in the Local Plan map.

The effect on housing, employment and transport on (and off) the Isle of Thanet needs to be taken into account with this in mind. The local plan is therefore unsound as it does not do this fully.

These issues need to be addressed now and not in 6 months or 12 months time.

The map below shows the areas that could be flooded (in red) for our children’s generation if we do not act now.

Climate central.

Thanet’s water supply

Across the world, the fresh water supply will become scare and there will be water shortages. As this is the most fundamental of all human needs this is exceptionally worrying.

The Local Plan makes it clear that the local water quality is very poor. Thanet’s groundwater is contaminated from industry and poor agricultural practices.

TDC needs to decontaminate the groundwater supply now and stop relying on water from elsewhere.

The ancient people who used to live in Thanet settled here because we had a good water supply. It is abhorrent that we have polluted our own water when it is the most fundamental molecule needed for human habitation. There are some simple techniques to start to decontaminate water that can be employed and we must do this now.

  • Brexit – Leaving the EU, which has now been agreed, completely changes the population projections for the Isle of Thanet. The population projections calculated by the Office of National Statistics (ONS) were based on the assumption that population increase would continue on the trajectory as predicted from a specific five years in the last decade. We now know that these assumptions are not correct.

Approximately a third of the population increase in Thanet each year came from International inward migration, and being close to Europe, a large proportion of the international migration to Thanet was from the EU. As this will decrease significantly due to Brexit, it needs to be fully re evaluated and the OAHN reduced accordingly.

We need to address these issues BEFORE we sign off a document which is based on unsound assumptions and population projections.