The response deadline is next Wednesday September 22nd so you haven't got much time to comment on it.
I’ve had a good read of most of it, though.
All I can say is that in a fair and just world, this planning application should have been laughed out of the planning office during the pre-application stage. (But of course, it’s Medway Council we are dealing with here, with their vainglorious dreams of city status…)
The absolute, unavoidable reason why this application should have been kicked straight out by Medway Council is that building new buildings on green belt land is still pretty much forbidden. End of. No argument.
The National Planning Policy Framework 2021 sets out what the Government’s planning policies are for England and how they should be applied. Section 13 details protections for Green Belt land (in which the proposed development lies) and paragraph 149 is unequivocal:
149. A local planning authority should regard the
construction of new buildings as inappropriate in the Green Belt.
It is noticeable that the Shrimplin-authored Planning Document refers to many sections of the NPPF and other planning guidelines, yet funnily enough, it fails to mention this one. The biggie. The "er, we're not really allowed to do this, are we...?" one.
In desperation, the Vineyard Farm application to build on Green Belt land relies on claiming that the winery building is an “agricultural” development and is therefore exempt from Green Belt/ANOB planning restrictions.
This is complete and utter
rubbish; indeed, the Planning Statement tries to pass off Lord Foster's
spectacular £30m design as some sort of farm shop! The proposed winery building is, first and foremost, a sophisticated
entertainment venue with a “visitor’s centre” comprising of a large restaurant, bar
and café. It will be used primarily by
visitors and restaurant customers – how can they claim it is an agricultural
building?
Foster & Partners own series of beautiful, highly impressive but desperately superficial “Design and Access Statements” (and in particular, Volumes 3, 4 and 5) show the emphasis that is being placed upon the visitor reception, restaurant, café, retail and wine-tasting areas. It is absolutely clear that the basement production facility, although large, is very much secondary to all of this.
How many farm buildings have a 31,000 litre ornamental lake as a fixture, I wonder? (As an aside, I’ve wondered about that lake. It seems quite fashionable for billionaires to want to fly rockets these days. Maybe the owner of Vineyard Farms, Mark Dixon, has similar aspirations…?)
Anyway...
The staffing level for the whole building is stated to be around 50 FTEs and although the planning document is careful not to mention it, the transport documentation tells us that the staffing of the production area is 10 FTEs. This alone gives the lie to the argument that the hospitality operation is “ancillary” to production. If your staffing levels are 4 hospitality guys to every one production worker, where does that show your emphasis to be?
To try and prop up this paper-thin case for exemption to Green Belt planning rules, Shrimplin also cites a legal precedent where planning permission for a wine plant was given in a green belt area (Millington v. Secretary of State for the Environment). The similarity of that development to this one being put forward by Lord Foster is pretty much zero and, I think, would be laughed out of court were it used to try and overturn what should, in a just world, be a straightforward rejection of these plans by Medway Council.
This single factor should be enough to kill this planning application stone dead. Foster’s Flying Saucer is not an “agricultural building”. It is not a farm shop. It is a vainglorious visitor’s reception/wine bar/restaurant/café-style country club that just happens to have a wine plant in the basement.
It must also be emphasised that were this activity to be primarily focussed upon the production of bottled wine, the fermentation and bottling operations would take place at a facility with better transport access than that offered by Upper Bush – and one that would not cost £30m. Crushing the grapes on site (to reduce possible bruising and oxidation damage to the fruit) could take place in very modest facilities, possibly even existing ones at Court and Brookers Farm in Luddesdown. Based on 900 acres with a 3 ton per acre yield, it would subsequently need only approximately 90 tanker movements to transport an entire annual juice harvest to a separate fermentation and bottling plant built elsewhere, maybe on a local business park with access that allows easy delivery of bottles and process consumables, and distribution of finished product. This would eliminate at least half of the HGV movements in Cuxton that would otherwise result from the existing proposals.
This option has not been discussed at all in the proposal, because it would negate the need to build the large facility they want on green belt land in Upper Bush.
If the spurious nature of the claim that the development is primarily an “agricultural development” is recognised, then the submission meets none of the other criteria cited for permitted development within green belt land/AONB. Assertions of conformance made within the Planning Statement are completely and demonstrably baseless.
And, villagers of fair Cuxton, Luddesdown and Halling, you need to be shouting about this outrage from the rooftops. You must not be seduced by Lord Foster’s glossy brochures, or the promise of a swanky restaurant on your doorstep, or even a bit of local discount on the wine they are planning to make.
These plans are a stalking horse.
In Section 2 of their Design and Access Statement, they boast that:
“The planning application for the Kentish Wine Vault forms the first project of an estate-wide strategy for Vineyard Farms Ltd that will evolve in subsequent years across it’s (sic) Luddesdown and Upper Bush estate”...
If they get planning permission to build in the green belt, it will open the floodgates not just for development in Bush and Luddesdown Valley, but in every bit of green belt land in the country.
It’s a test case, being closely watched by Boris’s building chums everywhere, who are licking their chops and rubbing their wallets in anticipation of developing the UK’s green belt for cash. If Vineyard Farms get their way, it will set a national precedent. This would be just the start.
"Oh, we've bought a wine kit from Boots and we'll put it in the cellar of our proposed shopping centre, because that makes it an agricultural building" will be the next stretch of the argument. Maybe followed by "little Johnny might grow some mustard and cress on a bit of damp kitchen towel in his bedroom, so can we call this housing estate an agricultural development, please...?" There's just too much money in development land these days to rule out any argument in favour of building stuff as fatuous. Big companies can pay clever lawyers fortunes to argue that black is white. Killing folk on zebra crossings doesn't matter to them.
So, Cuxton/Halling/Luddesdown villagers, you have to speak up, not just for yourselves, but for everyone. Get engaged. You owe it to yourselves, your kids and your grandkids. We can’t let Foster and Partners build on our green belt land. We simply can’t. Please, please, go on to the Council planning web page, find the application (MC/21/2328, or type in "winery" as described above), click on "comment" open an account and register your objection to this scheme. Yes, it's a faff but you have to do it. Or just write a letter to them.
This has to happen by September 22nd.
Tell them that the Vineyard Farms proposal must be rejected because it is inappropriate for Green Belt land, as spelt out unequivocally in paragraph 149 of the National Planning Policy Framework 2021.
Tell them that the case made for an exemption to Green Belt planning restrictions, based on the assertion that the winery building is primarily an agricultural building, is clearly unsupportable. Say that the Foster and Partner Design and Access statements clearly show that the prime function of the proposed facility is that of a hospitality venue (of a nature of which Kent is already well-served by) and not a wine manufacturing plant.
Tell them that no consideration has been given to a proper agricultural business-based process flow assessment (which would logically conclude that the fermentation and bottling operations should be conducted elsewhere due to access and transport issues) solely because that would undermine the case for the proposed scale and design of the visitor’s centre in green belt land.
Tell them that Vineyard Farms shouldn’t be allowed to fly Thunderbird One out from under that lake (no, don’t tell them that, I made that up. Mind you, it’s no more ridiculous than a lot of the stuff in the Vineyard Farm proposals).
If you love Cuxton, Halling and Luddesdown, its beauty, its peaceful woods and farmland, its wildlife and its scenery, you have to oppose this planning application. You have to make your voice heard.
If you don’t, our children and grandchildren will look back at pictures of how it all used to be and will never forgive us. "Grandad, what's a tree...?"
Please watch this space. I have more to say about the traffic and the environmental assessments in my next posts.
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