Fourteen Affordable Homes Became Two — Now KCC Says Don’t Decide Folkestone’s Stoneleigh House Plan Yet

Folkestone & Hythe District Council has been told not to determine plans for 14 flats on Tram Road until the developer provides something currently missing from the application: a complete surface-water drainage strategy.

The warning comes from Kent County Council, the statutory Lead Local Flood Authority.

“Unfortunately no surface water drainage strategy has been provided,” KCC says. Its recommendation is equally clear: “the application is not determined until a complete surface water drainage strategy has been provided for review.” KCC wants, among other things, the drainage layout, attenuation volumes, flow controls, supporting calculations and assumptions before Folkestone & Hythe District Council decides application 26/1358/FH.

That would be significant on any major housing application.

At Stoneleigh House (pictured below) it is particularly interesting.

Beneath the site lies the Principal Folkestone Aquifer. When FHDC previously granted permission for flats here, the decision notice specifically warned that deep-bore soakaways might not be acceptable. The current applicant nevertheless argues that suitable surface-water management can be secured later by planning condition.

And drainage isn’t the only thing that has changed.

Stoneleigh House has been here before.

In October 2018, FHDC granted permission under Y16/0333/SH to demolish the building and erect an apartment block containing 14 affordable housing residential units. That consent was never implemented and expired.

The new application also proposes 14 flats.

But fourteen affordable homes have become two.

The 2026 application comprises 12 market flats and two affordable rented flats. Yet Credo Planning’s Planning Statement describes the scheme as “effectively a resubmission” and says in one section that the “only change” is the addition of balconies and private amenity areas. Elsewhere it calls those additions the “main change”.

That doesn’t make the affordable-housing provision contrary to today’s policy. FHDC’s adopted Core Strategy Policy CSD1 says developments of 11 to 14 dwellings should provide two affordable dwellings on site, with tenure on these smaller schemes dealt with site by site. In numerical terms, two affordable homes meets that requirement.

What it does mean is that this isn’t simply the old proposal with balconies bolted on.

There is also unfinished business from the old permission. FHDC’s 2018 decision says that consent was conditional upon a Section 106 Planning Agreement and expressly records: “The Agreement runs with the land and not with any particular person having an interest therein.” The complete agreement isn’t in the new application bundle, so its wording, triggers and any release provisions need examining before anyone can safely say what legal obligations, if any, still affect the land.

The site’s recent history adds another layer.

Stoneleigh House was subsequently offered for sale on the instructions of administrators. Clive Emson records the freehold as sold for £378,000, after an auction on 26 March 2026. The auction particulars themselves highlighted the lapsed permission for 14 affordable homes.

By then, a new company already existed.

Zanchi House Ltd, was incorporated on 10 February 2026. Companies House records it as an active private company whose business is “Development of building projects”. Its first accounts, made up to 28 February 2027, aren’t due until 10 November 2027, so there is presently no filed balance sheet or profit-and-loss history from which the company’s financial position can be assessed.

Its incorporation filing recorded just £100 of share capital. Paul Berardo became a director on incorporation. Lee Korkis joined on 20 May 2026. Companies House then received a confirmation statement “with updates” on 3 June, followed on 31 July by notification of Korkis as a person with significant control (PSC) and a change to Berardo’s PSC details, both effective from 20 May.

Companies House today shows two active PSCs: Paul Berardo and Lee Korkis.

Both are recorded as owning more than 25% but not more than 50% of the shares, and the same band of voting rights. That does not prove an exact 50:50 split; Companies House reports the interests in statutory percentage bands. Both men are also listed as active directors and both have completed Companies House identity verification.

They have crossed corporate paths before.

Companies House records Berardo and Korkis as having been appointed on the same day, 14 October 2020, as directors of B&K Projects Ltd, now European Pet Travel Ltd. Both resigned on 29 September 2021. The PSC register for that company also records each man during that period with more than 25% but no more than 50% of the shares and voting rights.

Berardo’s Companies House appointment history is longer. It currently records directorships at Zanchi House Ltd, FPD Folkestone Ltd, Folkestone Property Developments Ltd and Premiere Taxis Ltd, together with two former appointments. Those corporate connections explain something about the people behind the applicant; they are not themselves planning reasons to approve or refuse development.

The planning application form names Zanchi House Ltd at 29 Wear Bay Road, Folkestone, whereas Companies House gives its registered office as 1-2 Rhodium Point, Spindle Close, Hawkinge. There is nothing inherently improper in a planning applicant using a correspondence address different from its statutory registered office, but it is another detail in the paperwork worth accurately recording.

The freehold was sold for £378,000 following Clive Emson’s 26 March 2026 auction, with the administrators’ later records showing completion on 6 May. By the time the planning application was signed on 18 August, agent Andrew Jolly also completed Certificate A, declaring that Zanchi House Ltd was sole owner of all the land covered by the application and had been so for more than 21 days.

None of this means the principle of 14 flats at Stoneleigh House is weak.

Quite the opposite.

The site is previously developed land within Folkestone’s urban area. The adopted development plan remains FHDC’s Core Strategy Review 2022 and Places and Policies Local Plan 2020. A completely revised National Planning Policy Framework was published on 17 August 2026, one day before this application was signed.

That new Framework gives the applicant considerable support. Policy S4 says development within settlements “should be approved unless the benefits of doing so would be substantially outweighed by any adverse effects”. Policy HO7 says “substantial weight” should be given to homes meeting evidenced accommodation needs, while L2 also gives substantial weight to making better use of vacant and underused land and buildings.

Credo also says FHDC can demonstrate only about 3.1 years of housing supply and that the latest Housing Delivery Test records 1,120 homes delivered against 1,979 required — 57%. Those figures add real weight to additional homes on an urban brownfield site. They do not, however, make drainage, contamination, highways or neighbour amenity disappear.

And contamination produces one of the stranger contradictions in this submission.

On the application form, “No” is selected for land known to be contaminated, land where contamination is suspected and a proposed use particularly vulnerable to contamination. Yet the applicant’s own Planning Statement later says investigations “will be required”. The previous permission imposed a detailed contamination condition requiring a desk study and, if necessary, intrusive investigation, remediation and verification.

That matters because FHDC’s Policy NE7 says that where there is reason to believe contamination may exist, assessment should begin with a Phase 1 desk study and specifically requires measures to prevent contamination of an aquifer. The current NPPF is similarly clear: Policy P2 says adequate site-assessment information prepared by a competent person should be available when contamination may be relevant.

Curiously, Credo’s Planning Statement lists numerous adopted policies but omits both NE7, Contaminated Land, and CC3, Sustainable Drainage Systems. CC3 is hardly peripheral when the statutory flood authority has now said the application shouldn’t yet be determined without a drainage strategy.

KCC Highways has found another contradiction.

It says the dimensions of the proposed cycle store differ between drawings E26-69-05 and E26-69-04, and wants the applicant to demonstrate that the promised 39 cycles will actually fit. It also says EV charging should be provided for the residential parking spaces under current requirements. Pt 1(1)

Other elements are considerably harder to challenge. The development proposes 11 parking spaces for the 14 new flats and another eight for George Stone House. The apartments are shown at about 52 square metres for the one-bedroom units and roughly 67.5 to 68 square metres for the two-bedroom units, with balconies or patios. The applicant’s broad case on parking, internal space and private amenity therefore has substantial support from the adopted policies. Pt 1(1)

The site is also small enough for the new mandatory Biodiversity Net Gain exemption to be potentially relevant: the application gives a red-line area of 1,350 square metres, or 0.135 hectares, and says the development falls within the 0.2-hectare-or-below exemption. That does not remove other ecological duties, but the size threshold itself appears to be met on the submitted figure.

Then there is daylight.

Rather than commission a new assessment, the applicant relies substantially on the old evidence. It says bedrooms in Randolph House were previously calculated to fall from an Average Daylight Factor of about 1.45% to 1.04%, while northern living rooms moved from around 0.92% to 0.90%. FHDC accepted those effects previously. But balconies are now part of the scheme, meaning the Council still has to decide whether evidence prepared for the earlier proposal remains adequate for the application before it today.

So this is not a story about whether flats can ever be built at Stoneleigh House.

FHDC has already accepted that principle once, and today’s national policy is, if anything, more supportive of urban housing and brownfield redevelopment.

The question is narrower.

A company incorporated in February is seeking permission for a scheme which turns the site’s previously approved 14 affordable homes into two affordable and 12 market homes. Its planning case has genuine strengths. But its paperwork also contains contradictory cycle-store drawings, unresolved contamination questions and no surface-water drainage strategy — while the statutory flood authority has explicitly told FHDC that the application should not yet be determined.

The Shepway Vox Team

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