CPRE 1: Proof of Evidence – Otham Parish Council Public Inquiry concerning the Appeal for Non-Determination of the Outline Planning Application for 440 Dwellings on Land West of Church Road, Otham Maidstone and the Appeal against Refusal of a Planning Application for 421 Dwellings on Land West of Church Road, Otham Maidstone. Maidstone Borough Council (MBC) References: 19/501600/OUT & 20/500084/NONDET and 19/506182/FULL & 20/500109/REF Planning Inspectorate References: APP/U2235/W/20/3254134 and APP/U2235/W/20/3256952 Appendix 1: OPC Questionnaire Summary Appendix 2: Otham Conservation Area - Appraisal Appendix 3: Otham Parish Neighbourhood Plan Appendix 4: Otham Neighbourhood Plan Consultation Statement Appendix 5: Inspectors’ Final Report on Local Plan Appendix 5a: Updated schedule of Main Modifications to the Local Plan Appendix 6: Policy SP3 Housing Allocations Appendix 7: Map of Anti-Coalescence Function Public Inquiry concerning the Appeal for Non-Determination of the Outline Planning Application for 440 Dwellings on Land West of Church Road, Otham Maidstone and the Appeal against Refusal of a Planning Application for 421 Dwellings on Land West of Church Road, Otham Maidstone. Maidstone Borough Council (MBC) References: 19/501600/OUT & 20/500084/NONDET and 19/506182/FULL & 20/500109/REF Planning Inspectorate References: APP/U2235/W/20/3254134 and APP/U2235/W/20/3256952 Proof of Evidence – Otham Parish Council 1.0 Introduction 1.1 My name is Rachel Gray and I represent the residents of Otham in my capacity as both Vice-chairman of Otham Parish Council, who have been full members of CPRE for at least 16 years, and Chairman of the Otham Neighbourhood Plan Steering Group. I have lived in Otham for ten years. 1.2 Back in 2015, we undertook a wide-ranging questionnaire of local residents to determine their views on the village and their hopes and fears for the future, as shown in Appendix 1. At the time, there were just 193 homes in Otham Parish and residents had become increasingly fearful of the destruction of village life due to the encroachment of urban Maidstone and the increase in traffic using the village lanes as a rat-run. 1.3 We asked residents to list their three favourite things about living in Otham and their top three concerns (items 39 and 40 of Appendix 1). The results then, remain the same today; they value the countryside, the peace and quiet and the views and are worried about housing developments, traffic and the loss of rural character. 2.0 The Local Plan 2.1 At every opportunity from the first Call for Sites through to the Local Plan Inquiry we raised our concerns about the impact the proposed housing allocation sites would have on the historic integrity of Otham, but despite our many objections, the 2017 Maidstone Borough Local Plan was approved, allocating over 1,100 new homes within the boundary of Otham Parish in sites H1(6,7,8 &9) and a further 1,400 adjacent to our parish in sites H1(5 & 10). This represents more than a 500% increase in housing within the parish boundary alone! 2.2 Policy SP3, one of three key urban strategic policies in Maidstone’s Local Plan, is an expansion of south east urban Maidstone. As can be seen on the map of SP3 housing allocations (Appendix 6), sites H1(5, 6, 7, 9 and 10) all sit along the A274 and paragraph 4.41 of the Local Plan states that this ‘new development on the urban periphery in the south east will be underpinned with a co-ordinated infrastructure approach for the area, which will focus on tackling congestion and air quality issues and improving accessibility to the town centre…necessary to mitigate for the increase in population.’ 2.3 These five sites are all accessed directly from the A274 and their individual site policies propose junction improvements and bus priority measures on the A274 to improve access to and from the town centre. 2.4 Paragraph 4.42 goes on to state that ‘at this location the council is keen to limit as much as possible the extension of development further into the countryside along both sides of the A274. This ensures that the more sensitive landscapes in 1 this area will remain protected and development will be consolidated around the urban edge to make best use of new and existing infrastructure.’ Paragraph 4.43 adds that ‘the south east strategic development location has been comprehensively planned in respect of supporting infrastructure and connectivity between sites.’ 2.5 Site H1(8) simply does not fit within the definitions of policy SP3. Unlike the other five sites, it sits more than a mile away from the A274 at the end of a narrow country lane, certainly not easily accessible from the town centre. Contrary to the claim of planning connectivity between sites, this site is a mile away from the nearest other site H1(7), the road between them being a narrow, country lane with no footpaths. Contrary to the aim of protecting sensitive landscapes, this site is the agricultural setting of a Grade I listed Norman church and two Grade II listed medieval houses. In an attempt to satisfy the aim of limiting development further into the countryside, this arable field has been clumsily re-designated from rural to urban, but this field is designated as Grade 2 Very Good farmland by Natural England and is valued as countryside by both local residents and farmers. Contrary to the aim of making best use of new and existing infrastructure, access is to be only from a narrow country lane, Church Road, with no provision of new or upgraded local infrastructure. 2.6 Local people could not believe that this site, so different from the five others, had been included in the Local Plan and how the proposed site’s mitigation policies of widening a road 1.6km away (Gore Court Road beyond White Horse Lane) or prioritising buses and relieving congestion on the A274, almost 2km away, could make this site viable. 3.0 The historic, social and environmental importance of Otham 3.1 Otham is an ancient, historic village with a conservation area at its heart, more than 30 listed buildings and a rural character which serves as a green lung for the surrounding urban areas of Downswood, Bearsted and Maidstone. It is characterised by open farmland, ancient woodland and outstanding landscapes and views, crisscrossed by well used footpaths and bridleways. 3.2. Social importance and emotional well-being During the national COVID lockdown, Otham’s public footpaths became crowded with local residents taking the opportunity to explore the network of public rights of way for their daily exercise. With the reduction in vehicular traffic, Church Road became a regular route for pedestrians, joggers, cyclists and horse riders. Every day, joggers could be seen running on the footpaths and family groups, some pushing pushchairs or 2 toddlers on tricycles, took long walks through the fields, listening to the skylarks singing above their heads. The fields of Otham became a lifeline for residents of neighbouring Downswood, Bearsted and Senacre during the lockdown and a new north-south footpath even appeared across the middle of the proposed development site, a new countryside walk formed by local people valuing the opportunity to walk in the fields to improve their mental well-being. Since the relaxation of restrictions, local people have continued using the fields for running and walking. The footpaths in the fields around the church in particular have remained busy during both weekdays and weekends in all weathers, demonstrating the popularity of these easily accessible rural routes with their open, arable landscape and exceptional views, at the edge of the urban area. In addition, despite the increase in traffic, Church Road has remained popular with walkers and cyclists. 3.3. Environmental and agricultural importance Otham supports arable and fruit farming, horse and sheep grazing, but Otham’s agricultural acreage is being steadily reduced by the use of farmland for housing development. Natural England’s land classification describes the proposed development site as grade 2, ‘the most flexible, productive and efficient in response to inputs, the best to deliver future crops for food use.’ (BMV) This site, recently seeded for its next crop, produced a crop of barley this year, wheat last year and with Brexit, the need to grow our own food has never been so important. Paragraph 170 of the NPPF states that non-BMV land should be used for housing development first, so allocating this very good, most productive farmland for housing is contrary to both the NPPF and good sense. There is no evidence that Maidstone has carried out a survey of its agricultural land within its boundaries. 3.4. Historic and geological importance 3.4.1 The Otham Conservation Area was first designated by Maidstone Borough Council in 1977 as part of a general review of conservation areas in the Borough and the area covered was extended in 1982. The 2009 Conservation Area Appraisal (Appendix 2), produced by Maidstone Borough Council, identifies the key elements which combine to produce the special historic and architectural character of the conservation area. Describing Otham today as ‘a residential community surrounded by working farmland,’ the Appraisal explains that permanent settlements in the Otham area may have evolved in the 7th or 8th centuries and that the Domesday Book notes that it was given by William the Conqueror to his half-brother, Odo. The Domesday Book, compiled in 1085, describes Otham as having approximately 300 acres (2.5 carucates) of arable land in addition to the church, so Otham’s agricultural economy has existed for at least 800 years.