Objection to Princes Parade Planning Application Y17/1042/SH

Please accept this email as an objection to the Hybrid planning application Y17/1042/SH for Princes Parade.

As stated in SDC's own Environmental Statement (Technical Annex 7) http://beta.shepway.gov.uk/StreamDocPage/obj.pdf?DocNo=4028588&PDF=true&content=obj.pdf

Shepway District Preferred Option Places and Policies Local Plan (Emerging) states that "Development proposals will be supported where:

...

"2. They are accompanied by appropriate heritage assessment to demonstrate that key features of the Royal Military Canal and its setting, which contribute to its significance as a Scheduled Monument would be preserved and enhanced and the overall scheme would not result in substantial harm to the heritage asset.

"3. Any less than substantial harm is clearly and convincingly demonstrated to be outweighed by the public benefits of the proposal, which should include heritage benefits."

It is the pre-application advice of Historic England that there would be "serious harm" to the setting of scheduled ancient monument of national significance (Royal Military Canal) as per their letter to the applicant on 25 May 2017 - http://beta.shepway.gov.uk/StreamDocPage/obj.pdf?DocNo=4028387&PDF=true&content=obj.pdf I agree with their assessment - as should the applicant - and do not believe that the harm that would result from the proposals is clearly and convincingly justified. As such, the application should, on these grounds alone, be rejected.

Although a new swimming pool in the Hythe area is clearly needed there is ALREADY an alternative location for a new swimming pool - with the space for a better facility than proposed for Princes Parade - at Martello Lakes. A study conducted by Lee Evans for SDC in 2015 confirmed that that site is available for acquisition under a S106 agreement for the larger Nickolls Quarry development and likely to be cost effective. The site would serve Hythe and Romney Marsh well, and with some tweaks to public transport can serve the whole area well. The site should be available for construction by 2020 - almost certainly realistically before any construction could start at Princes Parade given the additional reports, surveys, remediation of above and below ground contamination and other works the Princes Parade site will require.

There have been repeated reports of sighting of Japanese Knotweed on the application site. The eradication of the Japenese Knotweed on the site, with certified evidence of the same from an independent accredited expert, should be a pre-condition to the consideration of any planning application on the site. Without such eradication, the development may cause its spread, including via construction vehicles travelling through Sandgate and Hythe, and infest all properties developed on the site. Without such an independent assessment, the application should be rejected.

I also object to the re-routing of the 1881 road line (described with even SDC's Design and Access statement as "an impressively linear road with views over the sea") which offers simple access to the beach and views over a stretch of seafront in a way unequalled elsewhere in the district. The road itself is a part of the heritage of the area, and should be left in place, rather than moved to enhance the cost of beachside housing.

There is no social housing proposed in the development. The proposal states that of 150 units "up to 45" are proposed as affordable. However there is no indication of potential unit costs, and there is NO suggestions units would start at under £150,000 for the smallest one bedroom flat, and presumably much more for larger units. Given an average weekly wage of £421.90 in Shepway (https://www.kent.gov.uk/__data/assets/pdf_file/0020/8183/Earnings-in-Kent.pdf - around £22,000 a year) a £150,000 flat would be almost seven times annual earnings: well outside any reasonable idea of affordable.

Finally, despite the hybrid application, there is still a funding gap to meet in the provision of a new pool, and there are no answers as to how that funding gap will be met. If this application was to fulfil the criteria of an enabling development - such as one passed by SDC a few years ago to allow otherwise unacceptable development on Sandgate Escarpment to fund heritage works to 2 Martello Towers) detailed funding documents had to be prepared and agreed as demonstrating the application would deliver the return required to fulfil the developments stated intention. In this instance, the stated intention is to deliver a new swimming pool, but the development as a whole doesn't even guarantee the funding for the new pool. This could lead to a position where development is started, the setting of the RMA is compromised, and yet the remedial works required are so extensive to leave insufficient margin to fund any new pool or social facilities.

Overall, as a local resident living near to the development, I oppose the hybrid application and ask that it is rejected.