110 Homes, Flood Zone 3 and a Field the Local Plan Never Allocated: Inside New Romney’s Cockreed Lane Application

There’s nothing particularly dramatic about the field north of Cockreed Lane (pictured Orange below). It’s 4.71 hectares of agricultural land on the edge of New Romney: crops underfoot, a watercourse along the northern boundary, houses at Pippin Close to the west and open Romney Marsh countryside beyond. Catesby Strategic Land Limited wants to change that, with outline plans for up to 110 homes, public open space, landscaping and associated works.

The drama starts when you open the paperwork.

Buried among hundreds of pages submitted with planning application 26/1476/FH are two descriptions of the same piece of land which can’t both be true. One says it’s inside the St Mary in the Marsh Neighbourhood Plan area. Another says it’s outside. One document explicitly says the land isn’t allocated for development. Yet the Planning Statement eventually describes the scheme as development on an “allocated site”.

And those aren’t the only questions.

Most of the field is in defended Flood Zone 3a. The applicant’s own evidence records Grade 2 and Grade 3a agricultural land on the site. The field sits within a Local Landscape Area. Catesby’s flood Sequential Test considers 32 alternative-site entries but repeatedly rejects smaller, lower-risk sites because they can’t individually take anything approaching 110 homes — despite its own methodology acknowledging that the national guidance allows an alternative to consist of two or more smaller sites.

That doesn’t mean the application is doomed. Far from it.

What they don’t do is make everything else disappear.

And that’s where the story of this field gets interesting.

The parish had already decided where it thouhttps://www.youtube.com/watch?v=zmwBf5dFLsIght housing should go

St Mary in the Marsh Parish Council started preparing its Neighbourhood Plan more than a decade ago. Its stated purpose was unusually direct: to let local people help shape development and “determine the extent of any future development in the parish and identify where it is best located.” The parish boundary was approved as the Neighbourhood Plan boundary and, once adopted, the plan became part of the development plan used to determine planning applications.

FHDC still lists it as part of its adopted development plan today, alongside the Core Strategy Review 2022 and Places and Policies Local Plan 2020. The council states plainly that the St Mary in the Marsh Neighbourhood Plan’s policies apply to development proposals within the parish.

Which makes Catesby’s paperwork rather awkward.

Early in its Planning Statement it says: “The Site is located within the St. Mary in the Marsh Neighbourhood Plan area.” Later, under the section specifically examining that same plan, it says: “The site is located to the south of the St Mary in the Marsh Neighbourhood Plan Area.”

That’s not planning nuance. It’s one place or the other.

The distinction matters because the parish’s plan wasn’t anti-housing. It positively wanted homes for younger people and first-time buyers, but its preferred way of delivering them was smaller developments, principally one- and two-bedroom properties. One of its objectives was to encourage “small site housing development”, while another was to maintain and enhance “the landscape integrity of Romney Marsh.”

Its supporting text goes further: “The overall extent of farmland will be maintained to safeguard agriculture.” New housing was to be encouraged through one- and two-bedroom homes on infill sites inside settlement boundaries and at existing farm or agricultural complexes, an approach which, the plan said, would limit impacts on the Romney Marsh landscape.

There was a reason for that.

When the plan was written, three sizeable developments were already in the pipeline: 72 homes at the former St Mary’s Bay holiday park, 85 at the former Sands Motel and 55 at the Potato Factory site around Hope Lane and Cockreed Lane. That made 212 homes.

The parish plan then made a striking statement. Those 212 homes, it said, “will meet the general housing need of the area until 2028 and also provide a sufficient contribution to meeting affordable home needs.” Anything additional was envisaged principally as “further smaller developments” aimed at one- and two-bedroom homes on infill land within St Mary’s Bay.

That 212 figure isn’t a legal cap. Housing need has moved on, national policy has moved on and a neighbourhood plan can’t freeze an area in 2019 forever.

But it tells us something important about the plan Catesby is supposed to have assessed: the community had already accepted substantial housing growth. What it envisaged afterwards wasn’t another 110-home estate across an open agricultural field.

Policy H1 reflects that. It supports “Small scale residential development on infill sites within the settlement boundary of St Mary’s Bay”, mainly one- and two-bedroom homes. H2 deals with homes outside settlement boundaries, but for agricultural and rural businesses rather than a general housing estate.

Then there’s paragraph 5.1.18, where the plan says the Romney Marsh landscape is very important and that new homes outside settlements will be restricted to agricultural and rural businesses requiring a rural location. That wording was drafted under an older national planning regime and can’t simply trump the August 2026 NPPF, but it demonstrates just how different the locally adopted spatial approach was when the plan was made.

Cockreed Lane was supposed to be a boundary

Catesby leans heavily on Policy CSD8, the New Romney Strategy.

There’s good reason for that. CSD8 says New Romney should develop as the residential, business, service, retail and tourist centre for Romney Marsh. It also identifies a broad location for residential development north of the town centre, intended to provide around 300 homes including 22% affordable housing.

But “north of New Romney” isn’t the same as “every field north of New Romney”.

The broad location is mapped. CSD8 also contains a particularly relevant sentence: development there should integrate with the physical environment, “including addressing the natural boundary which is currently defined by Cockreed Lane.” If the objectives couldn’t be accommodated within that broad location, the policy says land southwest of Ashford Road could be considered.

Catesby knows its field isn’t in that broad location.

Its Planning Statement says so: “Whilst the Site is not located within the broad development area for new housing in New Romney (which is located in the north-west of the Town)”, it nevertheless argues that being on the northern edge of New Romney makes it a logical place for growth.

That’s a planning argument Catesby is entitled to make.

What it can’t do at the same time is turn the field into an allocation merely by repeating the words “New Romney” and “north”.

Its own Sequential Test states that “The Site is not currently allocated for development in the Adopted Development Plan.” Yet on page 42 of the Planning Statement, Catesby says the proposals represent “a sustainable form of development on an allocated site.”

One of those statements has to go.

Then the water enters the story

The field isn’t merely greenfield. It’s principally in defended Flood Zone 3a, with a smaller part in Flood Zone 2 along Cockreed Lane. Catesby’s Sequential Test records the site as around 4.713 hectares, open and agricultural, with a network of fields and ditches extending northwards.

There are flood defences, and that matters. Catesby’s Flood Risk Assessment says they provide at least a 1-in-200-year plus climate-change standard of protection and that the site sits outside the Environment Agency’s modelled breach extents. The FRA therefore characterises the tidal danger as a residual risk rather than an everyday one.

Even so, the proposed houses would be designed around water.

The development platform would be raised by 600mm. Finished floors would sit at least 600mm above existing ground level. Sleeping accommodation would be restricted to first floor and above. Residents would be registered for flood warnings and the scheme would operate under a Flood Management Plan.

Those precautions tell their own story.

National policy doesn’t say homes can never be built in Flood Zone 3a. “More vulnerable” uses such as housing can be appropriate if the relevant Sequential and Exception Tests are satisfied and the development can remain safe throughout its lifetime. Government standing advice says local authorities should refuse permission where the relevant tests haven’t been done or haven’t been satisfied.

The first question is therefore not how high the houses can be lifted.

It’s whether the houses need to be on this field in the first place.

Thirty-two alternatives later…

Catesby’s Sequential Test runs through 32 numbered entries across the Romney Marsh area looking for alternative land.

A fair few can quickly be crossed off. Some have already been built. Some are under construction. Others already have permission, contain protected open space, have habitat constraints or are allocated for something quite different.

Then come the smaller sites.

Land south of Kitewell Lane in Lydd is in Flood Zone 1 but could take only around nine homes. Land at Moore Close in Brenzett could accommodate roughly 34 remaining homes and is also Flood Zone 1. Cherry Gardens is mainly Flood Zone 1 but has capacity for around ten. Other sites can take five, eight, 15 or 26. Again and again the table says the land can’t accommodate a development of a “similar scale” or a “similar number” of units to Cockreed Lane.

That would be unremarkable were it not for what Catesby writes immediately before doing it.

Its own methodology records that lower-risk alternatives “could, where relevant, be a series of two or more smaller sites” and don’t have to be owned by Catesby.

That wording comes straight from national planning guidance. The current PPG says reasonably available alternatives may comprise two or more smaller sites, provided they can meet the same development need and have a reasonable prospect of coming forward at the same time. Government standing advice also tells councils to consider alternatives the authority hasn’t already identified, including sites currently on the open market.

So where, exactly, is the combined-site exercise?

That doesn’t mean five homes here, nine there and ten somewhere else can automatically be bundled together like Monopoly properties until they add up to 110. Planning doesn’t work like that. Location, ownership, delivery dates, affordability, infrastructure and the market the development is meant to serve all matter.

But rejecting individual lower-risk sites merely because none of them is itself another 110-home estate leaves a fairly obvious question when the guidance expressly tells applicants to consider combinations.

That question became harder to duck after Mead Realisations.

The High Court case concerned the flood-risk Sequential Test and rejected an approach that would effectively require an alternative to reproduce the applicant’s chosen development in every particular. The Court of Appeal dismissed Mead’s appeal in January 2025. The judgment doesn’t mean every development must be disaggregated, but it confirms that questions of size, location, timing and flexibility are planning judgments rather than an automatic demand for one replacement site identical to the application site.

And one alternative in Catesby’s own table is much harder to dismiss than the little sites.

Church Lane

Land adjacent to Church Lane, New Romney, known as SHLAA site 607, is 2.82 hectares. It’s close to the town centre, within walking distance and was promoted for around 100 dwellings.

Most importantly, it’s mainly Flood Zone 1, with areas of Flood Zones 2 and 3.

Now we’re not comparing nine homes in Lydd with 110 in New Romney. We’re comparing roughly 100 homes in principally lower flood risk with 110 homes principally in Flood Zone 3a.

Catesby says Church Lane has constraints: an electricity substation, overhead electrical and telegraph wiring, no current planning application and an estimated five-to-ten-year timescale. It also argues that Church Lane is west of New Romney and therefore less preferable under CSD8.

Those constraints may prove decisive.

But there’s a catch in the spatial argument.

Catesby says Church Lane is less preferable because CSD8 directs development north, while its own Cockreed Lane field is also outside CSD8’s broad development area. And CSD8 itself specifically contemplated land southwest of Ashford Road if its development objectives couldn’t be achieved within the broad location.

That doesn’t make Church Lane automatically sequentially preferable.

It does mean FHDC has a proper comparison to make rather than simply lifting Catesby’s conclusion into an officer report.

The soil underneath the argument

Flood water isn’t the only thing that makes this field different.

The environmental information lodged with the application records Grade 2 and Grade 3a agricultural land on the site, as well as Grade 4. Grade 2 is classed as very good quality agricultural land; Grade 3a as good quality. Both fall within what planners call best and most versatile agricultural land, or BMV.

FHDC’s own Policy HW3 is pretty blunt about that.

It says major development should incorporate productive landscapes and should “Not result in the loss of the best and most versatile agricultural land (Grades 1, 2 and 3a) unless there is a compelling and overriding planning reason to do so”, together with mitigation through productive landscapes on the site or nearby.

Yet within the planning documents The ShepwayVox Team haven’t found a detailed field-based Agricultural Land Classification survey calculating exactly how much of these 4.71 hectares is Grade 2, Grade 3a, Grade 3b or poorer land.

That matters because a broad map isn’t the same thing as digging holes, examining the soil and classifying the actual field.

So before anybody starts talking about an “overriding” reason to lose BMV land, somebody first needs to establish how much BMV land they’re talking about.

Low ecological value isn’t the same as low landscape value

Catesby’s ecology work paints the central field as fairly ordinary habitat. Around 95% is cereal crop. The baseline is calculated at 9.37 habitat units, 0.22 hedgerow units and 2.35 watercourse units. No badger evidence was found and the recorded bird and bat assemblages weren’t judged exceptional.

The proposed development would actually produce substantial biodiversity gains in some categories. Catesby calculates a provisional 34% increase in habitat units and more than 300% in hedgerow units. The watercourse element doesn’t achieve the required 10% uplift, so that shortfall would be dealt with through off-site enhancement or credits.

But landscape isn’t ecology.

The St Mary in the Marsh Neighbourhood Plan describes the Romney Marsh Proper Farmlands as a flat, open, low-lying landscape, predominantly agricultural, where drainage ditches rather than hedges divide fields and where tree cover is sparse. It calls the landscape highly sensitive, with far-reaching views.

That description sounds remarkably like the application site Catesby describes itself: agricultural land, open to long views northwards, with a watercourse along the edge and open countryside beyond.

Catesby’s answer is planting. Its masterplan pushes housing towards the south of the site and places open space, attenuation features, landscaping and a buffer along the northern side. It argues that new planting would soften what it describes as an already hard settlement edge.

That’s a perfectly legitimate landscape case.

But planting a new edge after building across the old one doesn’t alter the fact that the existing edge moves.

Not everything counts against the scheme

There’s plenty in this application which helps Catesby.

For starters, KCC Highways isn’t objecting. It accepts the proposed access, says the residual cumulative traffic impact wouldn’t be severe and has found no unacceptable highway-safety impact. KCC wants conditions covering construction traffic, the new junction, pedestrian and bus-stop improvements, parking, signage and an emergency access before the 50th house is occupied.

The developer’s Transport Assessment predicts around 65 two-way vehicle movements in the morning peak and 64 in the evening peak. However frustrating Cockreed Lane may already be for people who use it, anyone arguing that the application simply falls over on highways now has KCC’s formal technical response to get past.

Southern Water has also confirmed adequate foul-sewer capacity for a flow of 0.99 litres per second, based on a 6l/s pumped discharge, subject to the necessary connection approval. It also wants no habitable room within 15 metres of the proposed pumping station because of possible noise, vibration and odour. The drinking-water supplier is Affinity Water, not Southern Water.

Then there’s health infrastructure.

Kent and Medway Integrated Care Board says the 110 homes would produce an additional population of 237 people once its gain factor is applied. It has asked for an index-linked £149,308 contribution towards creating extra primary and community healthcare capacity, including possible refurbishment, extension or reconfiguration of practices serving the development.

That’s considerably more concrete than parts of Catesby’s own Health Impact Assessment.

The HIA contains the unfinished phrase “[XX%] affordable housing”, despite the rest of the application saying 22%, and another line reads “[Confirm in Energy Statement]”. It acknowledges that the new population will increase demand on GP, dental and NHS services and that education and community facilities will need contributions where justified.

Typos and placeholders don’t decide planning applications.

But by this point they add to a pattern: a neighbourhood-plan boundary which moves depending on the page you’re reading, an unallocated site which suddenly becomes allocated, and different documents apparently counting open space differently.

The Planning Statement says open space accounts for about 15% of the site. Elsewhere the broader package of public open space, landscaping, paths, drainage and green infrastructure is described at around or above 30%. That may simply be different definitions, but it would be helpful to know how much of the green area people can actually kick a ball around on and how much is there to hold floodwater.

Because holding water is going to matter.

The Flood Risk Assessment assumes infiltration may not work because of shallow groundwater. It therefore models the drainage on a worst-case basis with no infiltration, proposes discharging to the watercourse along the northern boundary and applies a 45% climate-change allowance. Detailed infiltration testing still has to establish what the ground can actually absorb.

And the application is still moving.

FHDC’s consultation paperwork gave a 6 October 2026 reply date to bodies including the Environment Agency, Kent County Council as Lead Local Flood Authority, Affinity Water, KCC Ecology and KCC Archaeology. Their formal responses could materially change parts of the picture set out above.

That’s why this isn’t really a story about whether 110 homes are “good” or “bad”.

It’s a story about whether the case being made for putting them on this particular field survives contact with its own evidence.

Catesby has a serious argument in its favour. FHDC needs homes. New Romney is the Marsh’s strategic town. The new NPPF is more accommodating of development outside settlement boundaries where housing need hasn’t been met. Highways isn’t objecting. Southern Water says the foul network can take the proposed flow. The NHS has identified a financial mitigation package.

But the other half of the story doesn’t vanish because housing is needed.

This remains an agricultural field principally in defended Flood Zone 3a, outside CSD8’s identified broad housing location, within a locally important landscape, with evidence of best and most versatile farmland and a parish planning document which had envisaged something very different for further housing growth.

And tucked inside that enormous planning file are questions which don’t require anybody to take sides.

Is the site inside the St Mary in the Marsh Neighbourhood Plan area or outside it?

Is it allocated or isn’t it?

If smaller lower-risk sites can be combined under the national Sequential Test guidance, where’s the exercise showing whether realistic combinations were considered?

Why is mainly Flood Zone 1 land at Church Lane, promoted for around 100 homes, not a realistic alternative — and is CSD8 really a sound reason for rejecting it when Cockreed Lane isn’t inside CSD8’s broad location either?

And how much Grade 2 and Grade 3a farmland would actually disappear beneath roads, gardens and houses?

Those are the bits FHDC has to nail down before the planning balance begins.

Because once 110 homes are built on this field, the argument about where New Romney ends is over. The new houses become the edge — and the next field becomes the countryside.

The Shepwayvox Team

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