TEYNHAM AREA OF OPPORTUNITY (TAO)
IT IS NOT "SOUND"
RESOURCES: AGAINST THE "TEYNHAM AREA OF OPPORTUNITY" (TAO) and POLICY AO1
Community website put together by some residents - it helps with TAO submissions - offering alternatives to the Portal, using the Interactive Form, for example. Very clear and easy to read. Spread the word. This is a good place to start.
- THIS IS KCC'S OFFICIAL RESPONSE TO THE LOCAL PLAN - FAIRLY DAMNING OF SBC'S HANDLING OF THE LOCAL PLAN
- The Lynsted with Kingsdown Parish Council Newsletter, April 2021
- Emerging arguments against the Local Plan submitted by Nigel Heriz-Smith
- Paragraph 1.0.8. - A general challenge on the "soundness" of the Local Plan, especially as it has led to the surprise TAO
- Policy AO1 - challenges to the Policy that lays out specific ideas on our future in Greenstreet, Teynham and Lynsted with Kingsdown Parishes, without meaningful consultation or supporting evidence. Nigel Heriz-Smith long text.
- Short Summary of Key Points under "compliance Headings" - Nigel Heriz-Smith's checklist for Policy AO1. Using the headings of relevant tests of deliverability, justification, legal compliance, compliance with national policy. This may help identify the grounds for arguing "unsoundness" in all the other paragraphs if you want to go there! Please do!
- NEW: TABLE linking longer texts and the Portal paragraphs in one place - an aid to using the Consultation Portal in response to each paragraph of the Local Plan. Drafting by Nigel Heriz-Smith
- Frequently asked questions - I have received some questions that I have answered, but don't forget that SBC have a contact number for this exercise - 01795 417014
WHAT IS WRONG WITH THIS 'SECRET PLAN'?
Please download any graphics (tables and images) or documents you find helpful - files can then be attached to your own comments if you use the SBC Consultation Portal.
It is important to know that you can go in and out of the Portal as much as you like to titivate. When you are happy, hit the "Complete Document" (you can still edit it). When you have finished all your thoughts - hit "Submit" on the Home Page. That is final and you are done.
TAO was never declared under the Regulation 18 consultation, thus singling out Parishes of Teynham and Lynsted with Kingsdown for a treatment that has no equivalence in the Local Plan. An untested and undemocratic innovation without the level of analysis or the rigour of strategic thinking applied elsewhere in the Local Plan. At the time of development of the Policy AO1, there were no Covid-19 or other reason to exclude the two affected Parish Councils from consultation. These facts render the abuse of the SPG mechanism illegal and immoral.
A more detailed description of this failure to consult adequately has been submitted by Nigel Heriz-Smith (long version) under paragraph 1.0.8. This link takes you straight to Paragraph 1.0.8 in the Local Plan (Reg 19) Consultation Portal
Here is the introduction to that piece on legal precedent and associated policies and statements that have NEVER been consulted on - The TAO was a surprise to communities, parish councils, and KCC Highways!
"SBC has ignored the ‘Sedley criteria’ as repeated in the Supreme Court (R (Moseley) v London Borough of Haringey  UKSC 56). The Supreme Court addressed what fairness requires when consulting on a ‘preferred option’ – this step REG18b) has been ducked by SBC since 2020 without fanfare or rational explanation. SBC did not prepare details of rejected options and the reasons for the rejection. Choosing, instead, to launch Reg19 very quietly. What is missing, as part of fair consultation, in particular, is the need to provide consultees with sufficient and accurate information. Most emphatically in the context of the disastrously harmful Teynham Area of Opportunity (TAO).
The key features of the judgments are:
The Supreme Court formally endorsed the ‘Sedley criteria’ for a fair consultation, namely:
– Consultation must be at a time when proposals are still at a formative stage
– The proposer must give sufficient reasons for any proposal to permit of intelligent consideration and response
– Adequate time must be given for consideration and response
– The product of consultation must be conscientiously taken into account."
- Here is a copy of the latest submission to Paragraph 1.0.8. that has been put onto the Consultation Portal by Nigel Heriz-Smith - this is shared in the spirit of openness and to stimulate ideas, whether or not you are pro- or anti-. Go to Paragraph 1.0.8 in the Local Plan (Reg 19) Consultation Portal
- Imperial College modelling of average pollution levels (PM2.5, PM10, and NO2) in 20 square metres of the whole UK. The figures for Lynsted with Kingsdown Parish - created by a Parishioner. I found it very revealing.
- Stacking up housing for Teynham Area of Opportunity - 1,400+ in case you were wondering. Table.
- Green Spaces - "Coffin Path Gateway" - a bid to protect our "Coffin path" access to open countryside. Submitted in August 2020
Comments are submitted under five broad headings:
- Teynham Area of Opportunity (5.5.30 - 5.5.38)
- Issues and Constraints (5.5.39 - 5.5.43)
- Area of Opportunity (5.5.44 - 5.5.47)
- Developing a Teynham Masterplan (5.5.50 - 5.5.51)
- POLICY AO1 - all elements are addessed in one page on the Consultation Portal - so, this is a good place to deposit 'composite' statements rather than submit to every paragraph individually. Of course you can do both!
- Picture 5.5.2
POLICY AO1 - Teynham Area of Opportunity - This link takes you straight to Policy AO1.
If you don't comment anywhere else - this is a good place to bring your thoughts together to have your voice heard.
- Short Summary of Key Points under "compliance Headings" - a checklist for Policy AO1
- Nigel Heriz-Smith has written on Policy AO1. Intended to stimulate ideas. More for each paragraph as we approach the deadline for comments (30th April 2021).
Innovation around Facebook. I am instinctively suspicious of Facebook but I have decided to try a Facebook Page in support of this website - https://www.facebook.com/Aqma5a2. My intention (so far) is to share ideas about vocabulary used in planning and pollution. Perhaps also pick on interesting ideas from the news or policy-makers. For those of you who don't 'do' Facebook, I have added a page to this site in which Facebook posts will appear from time to time. Go to my web-page for non-Facebook peeps.