A former public school site in Hythe is heading back to Folkestone & Hythe’s Planning Committee. The homes remain. The affordable housing doesn’t. And behind the paperwork sits a Jersey–Gibraltar property-finance structure that deserves far more sunlight than it’s getting.
There are places in Hythe where planning applications don’t stay on paper. They sit above people’s gardens, old drainage lines and steep banks; behind mature trees; beside roads residents already know well. Foxwood is one of those places. The former special school site at 59 Seabrook Road has been empty since 2016: fenced off, overgrown, deteriorating and waiting for its next life. Now that next life is back before Folkestone & Hythe District Council Planning Committee on Tuesday 16 June as application 25/2112/FH: up to 150 market homes, no affordable housing at the outset, and a viability argument saying the numbers simply won’t stretch.
That’s the polite version. The less polite version is that a former public land story has become an offshore-flavoured finance story, and the public benefit has shrunk while the corporate structure has become more interesting. The committee report says the application is for full permission for 60 homes and outline permission for up to 90 more. It also says the total scheme would be up to 150 dwellings, all market housing, with “no affordable housing provision proposed”.
The number that should make councillors sit up isn’t 150. It’s 33. Folkestone & Hythe’s Core Strategy Policy CSD1 requires 22% affordable housing on qualifying developments. On a 150-home scheme, that means roughly 33 affordable homes. The council’s own report accepts that the scheme conflicts with affordable housing policy because it doesn’t provide those homes at the outset.
So the public-interest question is simple. How does a site allocated for around 150 homes, in a district where affordable housing need isn’t exactly hiding behind the sofa, end up before committee with none?
The applicant’s answer is the Financial Viability Assessement (FVA). Cushman & Wakefield, acting for Ureco Property, put the scheme’s gross development value at £86.68m, total development costs excluding profit at £70.6m, developer profit at £17.33m, a negative residual site value of £2.557m and a benchmark land value of £1m. Its conclusion was a rounded deficit of £3.557m, with nil affordable housing and nil Section 106 contributions. That’s quite a disappearing act. The homes are viable. The social obligations, apparently, are not.
The applicant’s FVA said there was “no scope for any affordable housing provision or other S106 contributions”, but it also said the deficit could be eliminated if the applicant or landowner flexed expectations, if cost efficiencies were achieved, or if revenue growth beat build cost inflation. In plain English, the alleged impossibility was never absolute. It was a commercial judgement wrapped in spreadsheet language.
Then came the council’s independent review. Bespoke Property Consultants first reviewed the applicant’s FVA in February 2026 and concluded the scheme could support policy-compliant affordable housing. Its appraisal produced a surplus of £4,000,549 above the benchmark land value. That matters. The first independent answer wasn’t “nothing can be done”. It was “policy-compliant affordable housing is viable”.
The whole argument then turned on build costs. The council-side cost reviewer and the applicant’s cost consultant were originally £6.302m apart. After further evidence and meetings, Platinum revised its construction-cost estimate to £54.390m, only £1.601m below Spider Projects’ view. Once that happened, the affordable housing story changed again.
By May 2026, Bespoke’s revised 100% market-housing appraisal showed a residual site value of £564,012. That was £435,988 below the £1m benchmark land value, before any affordable housing was added. The policy-compliant appraisal produced a residual land value of minus £1.925m, or £2.925m below benchmark land value. Bespoke therefore concluded the scheme couldn’t currently support affordable housing on site.
But this is where the story turns. Bespoke didn’t say the scheme was hopeless. It said the financial position was “finely balanced” and that a “moderate improvement” in sales values or build costs would make it viable to support a commuted sum. That sentence should be nailed to the committee desk. This isn’t a viability canyon. It’s a narrow gap being used to justify the loss of all 33 affordable homes at the outset.
The accepted final market-only appraisal still includes £86.685m of open-market sales and £17.337m of profit, equating to 20% on gross development value and 25% on cost. It also includes £54.390m construction costs, £2.720m contingency, £3.001m CIL, £4.854m professional fees, £1.300m marketing, £1.300m sales agent fee, £112,500 sales legal fee and £1.080m finance. Affordable housing disappears not because there is no value, but because the appraisal says the value is already spoken for.
The council officer report accepts the independent review and says the scheme is unable to support affordable housing “at the present time”. It then leans heavily on a Section 106 viability review mechanism to capture any future uplift. That sounds sensible. It’s also exactly the kind of phrase that can either protect the public or become a planning comfort blanket with a legal ribbon round it.
The previous Foxwood story makes that more uncomfortable. The Shepway Vox Team reported in 2023 that the earlier Sunningdale application for 150 homes included 15 on-site affordable units and an off-site contribution equivalent to 20% affordable housing. Hythe Town Council objected then, among other reasons, over “insufficient” affordable housing. A motion to refuse on affordable housing, slope stability and drainage grounds was lost before permission was granted.
So the direction of travel is stark. Previous scheme: 15 affordable homes on site plus an off-site affordable housing contribution. Current policy requirement: approximately 33 affordable homes. Current proposal: zero at the outset. That’s not a planning footnote. That’s the story.
The site already has a messy history. The Shepway Vox Team previously reported that Foxwood closed in 2016, that Kent County Council owned the site, that Sunningdale became involved before submitting the earlier planning application, that KCC and Sunningdale later had a legal dispute over sale and purchase contracts, and that KCC received £4.645m for the site according to documents released during the public inspection of KCC’s accounts.
Prospect Capital Security Trustees Limited also appeared in that earlier Foxwood chapter. The Shepway Vox Team reported that a legal charge was placed on Sunningdale House Developments (Foxwood) Limited by Prospect Capital Security Trustees Limited on 18 January 2023. In the current Ureco chapter, Companies House records two outstanding charges over URECO HOME 23 LIMITED, both created on 26 February 2025 and both in favour of Prospect Capital Security Trustees Limited: one over the Foxwood freehold and one fixed-and-floating charge over all assets.
The applicant company, URECO HOME 23 LIMITED, is controlled by URECO LTD, which Companies House records as holding 75% or more of the shares and voting rights and the right to appoint or remove directors. Companies House also shows Stephanus Petrus Du Toit and Lambertus Lochner Eksteen as active directors of URECO HOME 23 LIMITED, both appointed on 4 February 2025, both South African nationals, and both resident in Jersey.
URECO LTD’s filing history records that Prospect Holdings Ltd was notified as a person with significant control on 4 February 2026, while Philip Lloyd Goodman ceased as a PSC on the same date. That matters because the Prospect layer doesn’t stop at a bland Companies House entry. Gibraltar company material reviewed by us identifies Prospect Holdings Limited as an active Gibraltar company, company number 116512, with an official Gibraltar address and an operations start date of 21 November 2017. The same material records Matthew James Lawrence in relation to that Gibraltar company as director and shareholder, with the shareholder entry marked Jersey.
The address matters too. Prospect Holdings Limited is recorded at Suite 3, Second Floor, Icom House, 1/5 Irish Town, Gibraltar. That same address appears in the ICIJ’ Offshore Leaks database, drawn from Panama Papers eight times. ICIJ is clear that inclusion in the database does not imply illegal or improper conduct. But it does show this is not just an ordinary trading address above a shop. It’s a Gibraltar corporate-services address that has appeared in offshore-leaks material.
In ordinary language, the applicant isn’t simply sitting beneath another local developer. Above URECO sits a Prospect holding layer with a Gibraltar/Jersey footprint, at an address that appears in the ICIJ Offshore Leaks database. That doesn’t prove anything improper. It does mean councillors should understand exactly who sits above the applicant, who sits around the finance/security structure, and whether any money is moving between connected parties before the public is told there’s nothing left for affordable homes.
Matthew James Lawrence (pictured) is publicly listed by Companies House as a British director resident in Jersey, including as the person of significant control of Prospect Capital Security Trustees Limited. Prospect Capital’s own website names him as its chairman and says he has more than 30 years’ experience in investing, specialist marketing and corporate finance, with companies founded across Europe and Asia in technology, property, aviation and finance. We couldn’t find a credible public net-worth figure for him, and we won’t invent one. What is public is the property-finance footprint.
Prospect Capital’s website says its senior management team includes Matthew Lawrence, SP Du Toit and Lochner Eksteen. Companies House filing-history material for Prospect Capital Security Trustees Limited also shows director-detail filings for Matthew Lawrence, Stephanus Petrus Du Toit and Lambertus Lochner Eksteen. And the applicant company URECO 23 HOME LTD also shows Stephanus Petrus Du Toit and Lambertus Lochner Eksteen as directors. That doesn’t prove wrongdoing, far from it. It does mean the people around the applicant and the security structure deserve to be treated as connected for scrutiny purposes, not as strangers meeting for the first time at a property networking breakfast.
This needs precise wording. A chargeholder is not necessarily the same thing as the economic lender. A security trustee may hold security for others. So the right question isn’t simply “did the security trustee lend the money?” The right question is: who is the real economic funder, who benefits from the finance costs, and are any arrangement, monitoring, exit, security-trustee, management or related-party fees being counted in a viability appraisal that says Hythe can’t have affordable homes?
None of this proves the viability appraisal is wrong. It does prove that councillors shouldn’t treat finance costs as ordinary background noise. When a scheme is “finely balanced”, even relatively small related-party costs, security fees or optimistic assumptions about developer return can make the difference between affordable homes and no affordable homes.
The Health Impact Assessment adds another awkward note. It says the HIA is required because the scheme is over 100 homes and says the proposal will provide health benefits for the local community in social, environmental and physical terms. But affordable housing is itself part of health, wellbeing and inequality. A healthy place isn’t just somewhere with landscaping. It is somewhere people can actually afford to live.
The HIA’s assessment table asks whether the proposal includes “a range of housing types and sizes, including affordable housing responding to local housing needs?” It answers “Yes”, but the detail then talks about a mixture of houses and apartments, custom-build plots and homes “suitable for first time buyers” or downsizers. “Suitable for first time buyers” is not the same thing as affordable housing in planning policy. Words are doing a lot of estate-agent stretching there.
Hythe Town Council has objected because of concerns over loss of mature trees and habitat, drainage and waste management, and density of buildings. The officer report also summarises neighbour objections raising surface water run-off, sewerage infrastructure, land stability, loss of trees, overdevelopment, pressure on services, highway safety, lack of affordable housing and long-term woodland management.
One Seabrook Road resident’s objection is particularly grounded in the lived reality of the site. They say the application gives inadequate attention to ground stability and surface water run-off affecting properties below the site. And continues by saying the flood-risk assessment deals with on-site flood risk but fails to address run-off onto Seabrook Road properties at the bottom of the steep slope, where uncaptured surface or subsurface water could worsen embankment instability.
That matters because the same difficult site conditions help feed the abnormal-cost story, which feeds the viability story, which removes affordable housing. If the site is difficult, the costs must be properly understood. But if those costs are being used to remove public benefit, they must be interrogated with even more care, not less.
The ecological position is also uncomfortable. The officer report accepts there will be some tree loss and an on-site biodiversity deficit, although it says this would be mitigated through tree retention, new planting, ecological enhancements and off-site biodiversity net gain. So the public is being asked to accept a complicated bargain: no affordable housing at the start, a later clawback promise, a difficult sloping site, drainage worries, habitat loss concerns, and a corporate-finance structure that takes several cups of coffee to follow.
The minimum councillors should demand is a Section 106 agreement with teeth. The baseline appraisal must be locked down. The review dates must be early enough to matter. The late-stage review must not arrive after the value has already been extracted. Related-party finance and fees must be disclosed to the council’s viability advisers. Any connected-party cost should only be allowed if independently benchmarked as no higher than market rate.
Councillors should also require clarity on the actual funder behind the Prospect Capital Security Trustees charge, the terms of the facility, who receives the interest, who receives any arrangement, monitoring or exit fees, and whether any of that money flows to entities or individuals connected with URECO, Prospect, Lawrence, Du Toit or Eksteen. That’s not prying. That’s basic public-interest scrutiny when 33 affordable homes have vanished from the starting line.
The council’s officer report says the benefits of the development, together with safeguards from the viability review mechanism, outweigh the conflict with affordable housing policy. That may be the formal planning balance placed before members. But residents are entitled to ask whether the public benefit is being deferred into a future spreadsheet while private value is allowed to proceed now.
Foxwood may well need redevelopment. Nobody sensible wants a former school site left to rot indefinitely. But redevelopment of former public land, through layered private finance, with zero affordable housing at the outset, is precisely the kind of case where planning committees should remember they’re not a rubber stamp with tea and biscuits.
The question for Tuesday 16 June is not simply whether Hythe gets 150 homes. It is whether Hythe gets anything back from the uplift beyond traffic, drainage worries, lost trees, a promise to review viability later, and a corporate structure that most residents will never be shown in plain English.
The Shepway Vox Team will put it more plainly. If a scheme with £86.7m of projected sales and £17.3m of profit can’t provide affordable housing because the numbers are “finely balanced”, then every pound of cost, finance, fee and related-party payment needs forensic scrutiny before councillors wave it through. And when Jersey– and Gibraltar offshore -linked money sits around the structure, the argument that there’s somehow nothing left for affordable homes doesn’t really stack up without full transparency. Otherwise, “viability” risks becoming what it has too often become in English planning: the magic word that makes affordable homes disappear while everyone else is told to admire the landscaping.
Seen something the public should know about? Send tips, documents or concerns to TheShepwayVoxTeam(at)proton(dot)me. You can contact us in confidence, speak off the record in the first instance, and help us follow the evidence where it leads.
The Shepway Vox Team
Discernibly Different Dissent
