Gravesham CPRE

Respond to the consultation

If you go to the consultation website you will find 25 large documents there that describe the Councils policy and strategy for the local Economy, Retail areas, habitat management, infrastructure plan etc.  It is really the 'soup to nuts' policy of the Council that it is consulting on.  As part of this government rules require them to review their housing plans and provide sufficient land supply to meet housing needs according to a formula (the 'standard method').  Their land allocations can be viewed in the "Local Plan Core Strategy Partial Review and Site Allocations" documents, including Appendices 1-3. The first document (69 pages) will take you through the questions asked in the consultation response form (a must read to understand this consultation).

Here is a summary list of the sites being proposed to build on (our 'sites list' page).

You can answer GBC's consultation questionnaire online or you can get a copy in word format here (you need the nattily titled: "Part 1: Local Plan Core Strategy Partial Review and Site Allocations response form") it contains about 48 questions - YOU DO NOT NEED TO COMPLETE THEM ALL, however you must fill out your name and address for the response to count.  You will also find their consultation leans towards their conclusions (if you dissagree with them, they want you to present evidence why) and the answer to most questions is to allocate more land...

If you choose not to answer the questionnaire, you can also write or email your response to them; Planning Policy, Gravesham Borough Council, Civic Centre, Windmill Street, Gravesend, Kent DA12 1AU 
or by email to

Here is a list of the sites Gravesham have proposed:                           (follow this link for sites list).
Here is a note on writing a letter in response to the consultation  (follow this link for how to object).

If you would like to know more about housing need and the planning system        (follow this link for Housing Need).

If filling out the questionnaire or online response; remember that YOUR OPINION MATTERS.
Here are some alternate views to those in the Councils documentation - but it's your opinion that counts.

Questions 5 & 6

Should the housing requirement follow the standard method?

In our view it should not; because that is what is driving the Greenbelt Grab. 

In the most recent government guidelines (6th Aug 2020) the government requires only 6,480 homes in the plan, not the 10,480 GBC is suggesting here. The lower figure would require no greenbelt.

Recent ONS population stats indicates the inflated numbers are not required, as projected growth falls. And Gravesham is special; it is over 73% Greenbelt! The current 'standard method' is just perpetuating the current South East centric approach.

The government aims to deliver new land to build 1million new homes by this method. But there is space for 1.3million homes on existing brownfield sites. Releasing greenbelt just ensures brownfield sites remain unused.

Questions 8&9

Would you like to see more homes for the elderly and special needs?

Good question; be careful how you answer, a Yes will mean more housing.  Perhaps conversion and adaptation of existing housing stock would be more appropriate?

In any event, the proximity and availability of services is critical for such residents; so building these in the greenbelt is inapropriate.

Question 12

Should new housing be built near rural train stations?

This assumes a commuter market.  What about those that don't commute?  Do people who currently live near to rural stations use them, or do they drive to a station with better connections?

Who's interests are the council looking after here; is it commuters who want to migrate from more expensive suburbs to rural Gravesham, or those who live and work here?

Questions 13-16

Housing mix and affordability.

Of course the Council should plan and require housing that meets it's needs.  But allowing developers to decide normally means building houses that make them the most profit.

Affordability is a key issue; however homeless people cannot afford to buy, and developers don't build houses that they cannot sell. The argument that 'building more than you need reduces the price' is false.  Driving up land supply leads to land banking, not oversupply of houses.

Question 25 - 27

Q25  We believe the existing hierarchy is best and that the combining small communities within larger villages is unacceptable. We reject the revised settlement hierarchy.

Q26 - 27 We would be positive to all these suggestions.

Q28 has recently (25th Nov) been amended to change it's meaning. You may choose none of these options, they all assume building on the greenbelt is inevitable - you can use the comments to make the point that it is not.

Q29 - Neighbourhood plans; these are a very good idea, giving locals their own plan on how to develop their neighbourhood. But they are onerous to the parishes to produce. Vigo spent 5 years producing theirs only to have it rejected. Help in creating them is essential.

Questions 30 & 45

Q30 We would disagree with including f (the newly proposed greenbelt land) within the criteria. Including f is really quite cheeky, as it assumes the currently proposed sites are already lost although this first time we have heard about it.  This question allows you to propose your own criteria.  How about: To exclude any greenbelt development where brownfield sites exist elsewhere within the borough that have not yet been developed (for any reason).

Q 39 - 45 Climate Change. We (CPRE) are very keen to promote zero carbon development standards. Read page 66-67 of the consultation document and consider our plans for future generations.

Where now?

The Gravesham Core Plan review has been going on for 2 years now and is unlikely to be completed before the middle of next year.

The housing figures have been the most contentious part of the review and are being driven by government policy at the present time.

As you will have read (if you managed to wade through the GBC document to page 51) this is a national problem - but one we are determined to overcome.

If you would like to become a part of the national solution join our campaign now.