Mark Hourihane, a seasoned local community activist, adds his voice to concerns about The Place Plan
Time frame for comment and accessibility issues
I write with some comments on the 101 page Place Plan draft consultation, along with the supporting 84 page Urban Appraisal and 28 page Engagement Report, which were released to the public on 10 August. We were told we could comment “until 20 August” – a mere 10 days to absorb a lot of information. I have mentioned before that using phrases like “until x date” is rather vague and unhelpful, and this has been corrected in the past, though it continues to happen. Could we perhaps have a policy that a deadline is time-specific? Does until Friday mean by close of business on Thursday, before midnight, by the time the office opens on Friday (although I think that’s a virtual opening still?) or by close of business on Friday? I think last time, the answer was actually by midday – which is an option I wouldn’t have considered! After all, the portal for the Core Strategy etc. does have a specific midnight deadline.
Unfortunately, as this was sprung upon us rather suddenly, I have not been able to clear my schedule (including the Prince’s Parade demonstration and a family funeral) at short notice to give this the time it deserves for proper contemplation and response. I shall try to get something in by tomorrow, but I would appreciate you considering the comments in this e-mail in case I cannot.
It has also been pointed out to me by several people, especially those of a more mature age and with disabilities, that they found the small text and strange colour palette difficult to read. I would have to agree that it does not appear to have been designed to WCAG 2.1AA standards, as is legally required. A consultation agency well-versed in dealing with Local Governments should be aware of this requirement; I mentioned it after the initial documents, but they continued to produce documents that were hard to read. I should not have to remind you of your legal requirement to make ‘reasonable adjustments’ for the disabled under the Equality Act 2010, such as access to a large print version or an audio recording. Are these available for the Place Plan? There is no mention of it on the website. My own disability contributed to my inability to complete the mammoth consultation task in just 10 days as I need time to read and absorb a large bulk of material, including copious rest breaks. The small text and poor colour scheme did not help matters.
Consequently, I believe the consultation has not been conducted per your Statement of Community Involvement, which sets out five key Community Involvement Principles for planning consultations:
- Involving the public as early as possible
- Transparent planning process
- Choosing appropriate ways to involve as many people as possible
- Listen and feedback
- Involving the public as early as possible
I quite agree with the document you approved in 2015 – involving the public as early as possible is so important, it deserves to be on the list twice! However, I suspect as the specific point in the second occurrence is “provide accessible feedback on the results of consultations and how they have been used” that this should have been something else – perhaps ensuring the results are accessible to all? It is concerning that such a document has been approved and sitting unnoticed on the website for six years. Perhaps this illustrates the importance of having sufficient time to read the document in its entirety very carefully? I trust that the Cabinet have had more time to do so, and feel they are therefore well-informed and in a position to assess whether the Place Plan should be adopted.
Unfortunately, the seminars were rather poorly attended, when you consider how many people there are in Folkestone and the surrounding District. Time was limited, mostly taken up by the slide presentation, leaving little time for questions, so there were questions left unanswered. The questions were cherry-picked by the team, supposedly based on ‘upvotes’ from the public, though the chat window kept scrolling down when you tried to read comments, so it was practically impossible to upvote them. There was not a lot of advertising, especially on Facebook (which many people use) and it is rare to get two posts reminding you of a consultation. And it was unfortunate that the pandemic meant people couldn’t get to a library or the Civic Centre to view a printed copy. This alienates those who can’t afford or don’t want an Internet subscription and device capable of downloading documents and/or participating in webinars. Whilst they could telephone and order a copy, this means they first had to be aware of the consultation, and have access to a phone line.
Furthermore, we were not consulted as early as possible – there has not been sufficient time to consult on the draft document and I suspect your response rate this time will be far poorer. It was several months into the contract that it was even revealed to the public, and We Made That were hired to look at Guildhall Street in January 2020 – around a year before we knew anything, yet we were not consulted. The consultation, therefore, was not so much “what do you want?” as “what do you think of this?”. Except, of course, for studies such as the Watermelon Survey – again, poorly conducted where two people stood in the precinct, each with a target of 15 people per day, for a few weeks. Neither of them wore clothing that identified them and they weren’t afforded a stand. I went into town specifically to find them – it took me over an hour, then I had to wait nearly 30 minutes to be interviewed as someone else was being interviewed. Meanwhile, hundreds of people walked past.
Therefore, the consultation has not appropriately involved people, nor have the public been involved as early as possible, thus the process fails to comply with the SCI.
The Urban Appraisal
I would like to make a few quick points about the Urban Appraisal. When I started reading it, I thought it made some good points – both positives and negatives. However, as I was already familiar with the earlier webinar versions of the Place Plan, I felt these points were not being addressed by the plan – surely the purpose of the document? “Here’s an issue, here’s how we will endeavour to solve it.” However, some glaring errors soon came up – including some that I had previously pointed out. It is disappointing that We Made That have not taken all feedback on board. Some of these make it clear it was written by someone with little knowledge of Folkestone, whilst others are even more alarming.
- The road alongside Central Station is Station Approach – not Folkestone Station Road. This name is confusing, as Station Road is by Folkestone West. A cursory glance at SouthEastern’s website would have confirmed this. This may have been due to an over-reliance on Google Maps – as a Google Local Guide, I was able to have the erroneous name corrected. I did point this out to We Made That – whilst they corrected other errors, they left this in.
- Central Station has 70 car parking spaces, not zero. Again, this information is on the station’s website. I fail to see how they missed an entire car park!
- The Lower Leas Coastal Park is sometimes missing the ‘Lower’. It is incorrect to say that “Leas Coastal Park extends all the way to Harbour Street” or that “Road of Remembrance traverses down Leas Coastal Park”.
- If you look at the maps, you will see that there is missing data (e.g. Fishing Museum absent, no Leas Cliff Hall or Quarterhouse on the evening activities map, no DISK or Rainbow Centre as facilities of that type) or outdated information (e.g. Junction 13 is on there, despite closing before the pandemic, but One Foot in the Grape is not) and that the colours are very close to each other (e.g. the map on p.30 has a light green for play parks and a slightly darker shade for retail, an orange for hotels and salmon for leisure – but I can’t even see any play parks marked e.g. Payer’s Park is not) – it is necessary to zoom in to a level where the image quality breaks up to see the data.
- Mentions of the “Triennale” despite my having pointed out it is “Triennial”.
Perhaps most seriously, though, there is data on page 46 regarding road and rail noise. It suggests that “the general noise levels are below the acceptable range of 90 Hz”. There are several issues with this data:
- The key suggests that the data indicates “the level of noise according to the strategic noise mapping of rail sources within areas with a population of at least 100,000 people”. We don’t have a population of 100,000 in Folkestone.
- The map highlights roads as particularly noisy, yet the data is allegedly from “rail sources”. This is very misleading.
- 90 Hz is a frequency, not a unit of noise levels. A 90 Hz sound is of fixed pitch, approximately that of an F sharp on the low E string of a guitar. A violin cannot play a frequency below 196 Hz. The use of Hz is repeated throughout the map key rather than dB, or perhaps more accurately a weighted unit such as dB(A).
- Even if they had said 90 db(A), this is not a ‘range’. A range would be, say, 80 – 90 dB(A).
- There is no legal limit for road noise, although there is in the workplace – employers must assess the health risk for employees and provide relevant training at 80 db(A) daily or weekly average exposure and provide ear protection and hearing protection zones at 85 dB(A). It is worth noting that continued exposure to 70 dB(A) will eventually cause hearing loss and that even continued exposure to 60 dB(A) can lead to shortened lifespan – see this article on London traffic noise levels and WHO recommendations. Note that the decibel scale is logarithmic.
It is extremely concerning that a consultancy agency with a background in Place Planning does not know the difference between frequency and noise levels and would give misleading and incorrect information. If in doubt, this should have been checked with a health & safety expert.
On that note, I have to say that I am most disappointed that the Folkestone & District Local History Society was named on the “stakeholders to be invited to External Stakeholder Workshops” in the Engagement Strategy, yet I can categorically state as a committee member that we received no such invitation – despite there being a workshop on heritage. How can you discuss heritage and history without involving the local history society? I must say that Emily kindly telephoned me for a ‘one-on-one’ session lasting probably between 60-90 minutes when I pointed this out, for which I am most grateful. However, it is a shame that they didn’t consult with us on the Historic Development section of the Urban Appraisal, perhaps asking our opinion on facts (as Historic England recently did with the Debenhams listing application) as it is highly inaccurate. This reflects badly on the Council.
Elements within The Place Plan
Heritage appears to have been given scant regard in the Place Plan. Originally, it suggested moving the War Memorial, which is outrageous. You will know the uproar caused by an attempt to do that to the Weston Memorial. That said, paving around it and painting art on the ugly concrete buildings that surround it does not do it any justice, either. Despite many heritage assets being pointed out in consultation, little notice was taken. For example, the recent confirmation that Saint Eanswythe’s relics are, in all probability, her is a huge deal. It means pilgrimages to Folkestone to see the earliest known remaining relics of an English Saint and likewise the earliest known of a Kentish Royal Family member – if not the Royal Family. This would mean coaches would need to be able to get near the Parish Church. Yet you are proposing closing roads near the Church to pedestrianise around the War Memorial, making access harder. The plan suggests the Church is not visible enough. Well, that’s because it has trees in its churchyard, which must not be removed. We all know it’s there. The problem is the World doesn’t know of Eanswythe’s relics as we aren’t advertising the site. The plan’s solution is to “redesign West Cliff Gardens to highlight the link to the church”. West Cliff Gardens is itself primarily heritage buildings. Unless you’re going to knock down the old Herald office (which you aren’t) – you do nothing to aid the Church and this is a complete waste of money. Also, the suggestion of an “improved entrance to the path to the Parish Church of St Mary and St Eanswythe” is absolutely despicable – the path in the churchyard is Listed, as are the bollards at the entrances and the lamp bracket in West Cliff Gardens. Likewise, the cobblestones in the Old High Street are not to be messed with – both they and the pavements are old and characterful. And that’s pretty much the only mention heritage gets – everything else is a vague “heritage assets are refurbished and open for the public to use” and that should be “in-line with the Heritage Strategy”. The trouble is that the Heritage Strategy is still in draft, with no timeline for completion. And it does not include a Local List of Non-Designated Heritage Assets, so all heritage is currently at risk. Likewise, the Conservation Area Appraisal was abandoned in an extremely draft form in 2009 (along with four others – and several areas didn’t get one at all, not to mention potential new areas) and hasn’t been touched since – and it didn’t even look at the entirety of the Conservation Area. You have a statutory duty to review Conservation Areas and consider new ones ‘from time to time’ – I would say 12 years in draft is rather stretching the meaning of the phrase. This is despite other heritage assets being pointed out – such as a shop that played a part in the birth of television. And why isn’t the Fishing Museum mentioned? It is fantastic!
I could say the same of culture in general – with the exception of the Creative Quarter, which is a private enterprise, it gets little consideration. Where does the plan embrace Folkestone Music Town? It even left the two main venues off the evening things to do map! St. Eanswythe’s School are struggling to raise funds to save Dance Easy, an Asset of Community value, as a much-needed community hall with less than three weeks to go. Why could this not have been in the Place Plan as a Town Centre venue… and why are the Council not supporting the project in the first place? Why is the bandstand not mentioned? It is a heritage asset badly in need of restoration. Folkestone Festival and Chambers have provided a free programme of music on the bandstand YOU own (or at least run), and allegedly support according to the flyers, yet you haven’t bothered advertising it, at least not until I pointed out to your Facebook team that you advertised the air display but (yet again) not the other great events happening on that day! Much in the same vein as the Harbour Arm / Creative Quarter not advertising the Park & Ride scheme that only benefitted them, as I believe it didn’t even stop in the Town Centre (yet stopped at the train station – the last place you’d want to go if you’re parked in Cheriton) – rather counter-productive! And there’s the crucial issue – why do we not have a Tourism Department or Tourism Officer? Where’s the Tourist Information Centre? I was present at the extraordinary meeting to rename the District and heard Cllr. Monk saying that “we used to have a Tourism budget – that was a waste of £200,000”. It most certainly was not, and that’s an appalling attitude for a seaside town to have. We desperately need our tourism to be promoted – including heritage tourism, which is very popular. It is most disappointing to hear our Heritage Champion say such a thing.
As you will hopefully agree, it would seem that the We Made That team did not consult with / listen to either members of the public or Council Officers in preparing this document. Surely you could have pointed out that the Coastal Park doesn’t run all the way up to the Burstin and that there’s a car park at the station?
Sadly, the above only scratches the surface. I have eight pages of rough notes on the Urban Appraisal alone, and have not had time to check all the changes in the Place Plan. I must say, though, it seems as though We Made That have simply looked through 22 existing documents, taken the key points from them and repeated them, then gathered a few ideas from a few of hours of webinars and stakeholder workshops and put them all together with pretty pictures. Is that an efficient use of £82,390.50? I certainly shouldn’t have had to spend the amount of time correcting basic errors such as multiple incorrect spellings of Eanswythe when you are paying them this much. In future, I’ll just let them remain in the document and allow it to make the Council look rather foolish. As for people being surprised about things that were already in the Core Strategy and similar documents such as making roads two-way and ridding the town of Lidl, it just goes to illustrate the fact that we are not properly consulted per the SCI, as nobody had any idea those policies were in the existing documents. You do not engage with us sufficiently, thus we do not feel like we are really a part of the process. I would hope you would wish to rectify this, as I am sure it is disappointing to hear from your constituents who vote for you.
I would also comment that, by sheer fluke, Joe Lycett’s Got Your Back this evening had a feature on Low Traffic Neighbourhoods and the £2 billion that the Government has set aside to give Councils who implement Gear Change: a bold vision for cycling and walking within the next few years – a document I had not heard of a few hours ago. May I ask how much you have / hope to receive from this scheme? Is there a reason why it wasn’t named as a background document? Or will I have to submit a FOI request to receive that information? I should warn you, should you choose to watch the episode, that it is a comedy-based consumer rights show and he can be rather puerile.
I have spent countless hours discussing the Place Plan with several groups and many individuals, including AFRA, Go Folkestone and Shepway HEART Forum. There is a general consensus that:
- Proper engagement has not happened and our views for the future of OUR town have not been considered
- The underlying methodology was flawed
- The downside of proposals are not given due regard
- There will be a knock-on effect that does not make sense (e.g. you want more residents in the Town Centre and you want them to walk or cycle. Yet you want to remove Lidl, Sainsbury’s and Iceland from the Town Centre (though you now say a supermarket may stay at the Iceland site) – leaving only Asda. This seems counter-intuitive
- We need a Tourism Department and Officer
- We need more consultation, as promised at the end of the Place Plan – though not only in the future, but before the document is adopted
- The Place Plan as it stands is not fit for purpose
- This is being done ‘to’ us, not ‘with’ us
- Many say there is no point wasting your time giving your opinions, as the Council will ignore them – it is merely a box-ticking exercise as your minds are already made up and it is a ‘done deal’ despite what the majority may say (much like the democratic Prince’s Parade vote you overruled)
I would dearly love for you to prove the vast majority wrong in the latter instance and vote that this document needs more work, and more time for public comment, before being adopted.