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MAIDSTONE BOROUGH COUNCIL
RECORD OF DECISION OF THE Cabinet
|
Decision Made: |
24 February 2014 |
MAIDSTONE BOROUGH LOCAL PLAN PUBLIC CONSULTATION DRAFT (REGULATION 18)
Issue for Decision
To seek approval to undertake public consultation (Regulation 18) on the draft Maidstone Borough Local Plan.
Decision Made
a)
That the draft Maidstone Borough Local Plan, as attached at Appendix A
to the report of the Head of Planning and Development, be approved for public
consultation (Regulation 18) subject to:-
i) The deletion of the following housing sites:-
H1(18) Cross Keys, Bearsted
H1(19) Fant Farm, Maidstone
H1(51) Cripple Street, Loose
H1(58) Ware Street, Thurnham
ii) That Yalding and Coxheath be reclassified as larger villages;
iii) That paragraph 14.10 be revised to reflect the top priority for
Community
Infrastructure Levy (CIL) resources being
transport;
iv) That paragraph 1 of SP5 be amended to read “Provided proposals do not harm the character…..”;
v) That under H1(7) paragraph 13, v. be amended to read “widening Gore Court Road to a suitable width to accommodate contra-flow traffic and a footway on the eastern side of the carriageway between White Horse Lane and the access into the north of Sutton Road site” and this be repeated in each of the site allocation policies for the South East sites, as well as the removal of paragraph 11 from H1(7);
vi) That H1(17) be amended to include a landscaping and buffer zone to protect the amenity of residents to the South and to retain the character of the lane itself as a country lane; and
vii) That
paragraph 11 of Key Local Issues (top of Page 9 of the Local Plan) be amended
to read:-
“Ensuring that applications for development adequately address:-
(a) the impact of climate change;
(b) the issues of flooding and water supply; and
(c) ensure dependable infrastructure is included for the removal
of
sewage and waste water”
b)
That further transport modelling will be undertaken in the near future
be noted;
c)
That the designation of land at Junction 8 of the M20 motorway as a
strategic location for employment use be rejected;
d) That
a further call for housing sites and sites for Gypsy and Traveller pitches, as
part of the public consultation on the Maidstone Borough Local Plan, a review
of the currently rejected housing sites and further consideration of additional
housing in the town centre, be agreed;
e)
That the recommendations set out in the Urgent Update circulated at the
meeting be agreed; and
a) That the responses to the SCRAIP (attached as Appendix A) be agreed.
Reasons for Decision
The report of the Head of Planning and Development was considered by the Planning, Transport and Development Overview & Scrutiny Committee on 18 February 2014 and their recommendations were considered by Cabinet and responses were agreed and are set out in Appendix A to this decision.
The Cabinet considered the report of the Head of Planning
and Development seeking approval of the preparation draft of the Maidstone
Borough Local Plan for public consultation (Regulation 18 consultation),
together with the Urgent Update circulated at the meeting. It was not seeking
approval of all of the policies and site allocations in the plan, but an
agreement that the local plan is fit for purpose so that the community’s views
on the plan can be sought to assist officers and Members in shaping the
publication draft of the local plan for subsequent consultation (Regulation
19).
The consultation is due to commence on Friday 21 March 2014
and close on Wednesday 7 May 2014 at 5pm. A number of events are being planned
in accordance with the consultation strategy (agreed by this Committee and the
Cabinet Member[1])
to encourage as many people as possible to tell the council their views on the
document. Comments submitted during previous public consultations on the core
strategy in 2011 and 2012 have helped to develop the policies in this draft
local plan and, in the same way, all representations made during this new
consultation will be considered and appropriate amendments to the local plan
will be recommended.
Cabinet has given consideration to several groups of local
plan policies over the past year. The report of the Head of Planning and
Development brought those policies together in a single document.
New to Members are:
· updated introductory chapters to the plan which reflect the passing of time;
· an amended Maidstone Borough Spatial Strategy (policy SS1) that rolls forward the plan period to 2011-2031 and sets development targets that are based on an updated evidence base. The policy also confirms the distribution strategy for site allocations;
· the balance of land allocations for housing, in addition to the core strategy strategic site allocations (policy H1 and Appendix A in the draft Local Plan document);
· Identification of broad locations for new housing for the latter period of the Local Plan (policy H3 and Appendix F in the draft Local Plan document);
· site allocations for Gypsy and Traveller pitches (policy GT1; Appendix D in the draft Local Plan document); and
·
economic development land allocations for offices, industry and
warehousing and mixed use allocations (policies EMP1 and RMX1; Appendices B and
C in the draft Local Plan document). The strategic location for medical and
retail use at Junction 7 of the M20 and the retail/residential allocation at
Maidstone East Station and the Royal Mail sorting office was reviewed by this
Committee and Cabinet in December 2013.
At its meeting on 27th January Cabinet decided to defer the consideration of policies SP3 (Rural Services Centres) and SP4 (larger settlements) until information on the proposed housing allocations were available. These proposed site allocations are now included as part of the draft Local Plan. The recommendation on the designation of settlements were unaltered from previous reports; it was advised that Yalding and Coxheath be designated as two of the seven Rural Services Centres and that Boughton Monchelsea, Sutton Valence and Eyehorne Street (Hollingbourne) be designated as Larger Settlements. However, Cabinet felt that it was not appropriate for Yalding and Coxheath to be designated Rural Service Centres (RSCs) as their facilities/services were not in line with other RSCs.
The consultation draft Maidstone Borough Local Plan contains:
·
Introductory chapters that highlight the documents that have
helped to inform the local plan, identify key local issues which the plan needs
to address, and set out the council’s spatial vision and objectives for the
plan period;
·
The borough wide spatial strategy which sets development targets
and explains the factors that influence the distribution of development;
·
Spatial policies that focus on the town centre, Maidstone urban
area, rural services centres, larger settlements and the countryside;
·
Site allocation policies that list the site specific allocations
for housing (including future locations growth), retail and mixed use,
employment, Gypsy and Traveller pitches, and park and ride;
·
Development management policies that apply across the borough,
within the town centre and in the countryside focus on delivering the spatial
strategy and set criteria against which planning applications for development
are determined;
·
Infrastructure delivery policies which explain what
infrastructure is required to support new development; and
·
The housing trajectory which demonstrates how the council will
deliver its housing provisions.
There were a number of appendices that contained individual
policies for site allocations and future locations for growth, which clearly
set out the infrastructure requirements and mitigation measures that are
crucial for each site’s development. Other appendices included information on
monitoring, and matrices showing how plan policies will deliver the priorities
of the Maidstone Community Strategy and the objectives of the Maidstone Borough
Local Plan.
Housing needs and the Strategic Housing Land Availability
Assessment (SHLAA)
The Strategic Housing Market Assessment 2014 confirmed the
objectively assessed housing need for the borough as 19,600 dwellings (980
dwellings per annum). The Committee and Cabinet agreed this figure in January
2014. The next step for the council is to determine whether this need can be
fully met, which is a requirement of the National Planning Policy Framework
(NPPF) unless any adverse impacts of doing so would significantly and
demonstrably outweigh the benefits when assessed against the policies in the
NPPF taken as a whole, or specific policies in the NPPF indicate development
should be restricted.
The Strategic Housing Land Availability Assessment (SHLAA)
process commenced with a widely advertised call for sites on 7 December 2012.
The call for sites period was initially scheduled to conclude on 25 January
2013, but the deadline was extended to 31 March 2013 because of the number of
sites that were submitted after the initial closing date. The call for sites
invited the development industry, landowners and members of the public to
submit sites to be considered for allocation in the local plan. An important
consideration at the outset of the process was how to assess all submitted
sites for housing in a consistent manner. A detailed pro forma (approved by
the Cabinet Member for Planning, Transport and Development) was used to build
consistency into the process[2].
As part of the SHLAA assessments, site visits were
undertaken and key stakeholders and service providers were consulted on all
sites. The results were fed into the pro forma, and officers engaged with
parish councils, landowners and the development industry to gather further
information on the submissions. The pro forma incorporated a broad range of
criteria against which sites were assessed, and included detailed comments on
topics such as planning history, landscape, flood risk, highways and ecology.
The assessment process allowed officers to draw initial
conclusions on the potential development of sites in an open and consistent
manner, examining the availability, locational suitability, achievability, and
viability of each site. Locational suitability has influenced the recommended
selection of sites: brownfield sites were prioritised first, and then
recommended sites were selected for allocation in accordance with the borough’s
settlement hierarchy. Those sites situated in the urban area, edge of urban
area[3]
or at rural settlements forming part of the council’s settlement hierarchy were
considered more suitable and sustainable than those removed from settlements
and essentially in the open countryside. The exception to this rule is Syngenta,
which is a large brownfield development site in Yalding parish.
Completed site pro forma were the subject of an independent
sustainability appraisal (SA) by the expert consultants appointed to undertake
the SA on the local plan. The sustainability of each site was appraised against
a selection of key assessment criteria and advised on issues to be addressed
and potential mitigation and enhancement measures. The SA also assessed the
cumulative impact of the draft allocated sites on their immediate locations and
at a strategic level.
As part of the SHLAA process, the site assessment exercise
has assisted with the selection of recommended site allocations for the draft
local plan (54 housing sites in total, out of 190 sites submitted), but it has
also informed site allocation policies. For example, consultation with
statutory undertakers and infrastructure providers has highlighted on-site and
off-site constraints, and the need for additional surveys to fully understand
the mitigation measures required to make development acceptable. This has
resulted in the inclusion of criteria for mitigation measures in a number of
the site allocation policies. The mitigation measures are wide ranging but in
a number of cases include structural landscaping, junction improvements and the
identification of site areas where development will be restricted.
The SHLAA process has ensured that the proposed site
allocation policies are robust, and SHLAA sites will contribute approximately
10,000 dwellings[4]
towards the borough’s objectively assessed housing need over the plan period.
The pro forma for accepted and rejected sites will be available (as part of the
council’s evidence base) to support the published SHLAA during public
consultation.
Future locations for housing growth
The council does not need to allocate land to meet all of the
borough’s objectively assessed need of 19,600 dwellings because approximately
4,100 homes have already been built since 2011 or have been granted planning
permission on sites that are not yet completed, resulting in a net need for
15,500 homes. The land allocations that are the subject of this consultation
total a further 10,000 dwellings, leaving a balance to find of 5,500 dwellings.
The NPPF directs local authorities to identify deliverable[5] housing sites for the first 5 years (it is implied this starts from the date of adoption of a local plan). For years 6 to 10 and, where possible, years 11 to 15 following adoption (i.e. the last 10 years of the Maidstone Borough Local Plan period), sites should be developable[6]. The greater the number of dwellings on sites that are specifically identified as deliverable/developable, the more robust the local plan will be. However, the NPPF also allows for the identification of broad locations for housing in this latter period.
Recommendations received from the Planning, Transport and Development Overview & Scrutiny Committee included the removal of some of these site allocations. Cabinet felt it was appropriate to remove the following sites from the Local Plan:-
H1(18) Cross Keys, Bearsted
H1(19) Fant Farm, Maidstone
H1(51) Cripple Street, Loose
H1(58) Ware Street, Thurnham
Three broad development locations yielding a potential 3,000 dwellings have
been identified and included in the consultation draft for the latter years of
the local plan period. This will offer the opportunity to review the locations
in detail at the first point of regular review of the local plan in 2026.
Invicta Park Barracks
Invicta Park Barracks covers a substantial area (41 ha) to
the north of the town centre. It comprises a range of military buildings,
including army accommodation, set within expansive parkland. The site is
currently home to the 36 Engineer Regiment. The MoD
has categorised the site as a ‘retained’ site in its most recent estates review
(2013); there are no immediate plans to vacate this site. The MoD keeps its
property portfolio under regular review. It has been confirmed that, in the
longer term, there could be some prospect that the site may
be declared surplus and so become available for alternative uses.
In recognition of this potential, and the need to plan
positively for it, the draft Local Plan identifies Invicta Park Barracks as a
broad location for future housing growth for towards the end of the Local Plan
period (post 2026). The Barracks site covers is an extensive area and includes
expansive undeveloped open and wooded areas. Development will need to be
planned to reflect the site’s arcadian nature and the role it could have in
providing additional accessible green space in the urban area. Primarily
focused on the redevelopment of existing developed areas, the site has the
potential to deliver in the order of 1,300 new homes.
Town Centre
It is acknowledged in the local plan evidence base that there is an oversupply of poorer quality office stock in the town centre which is no longer fit for purpose. This has the effect of suppressing the town centre office market and thereby inhibiting new development which could better meet modern business needs. A route to tackle this is to rationalise the supply of the poorest stock through conversion to alternative uses. Over the timeframe of the plan it is expected that the value of the lowest quality office stock, in terms of rents, will fall further making redevelopment for alternative uses increasingly viable. With a corresponding uplift in the market for town centre apartments, this trend could see the delivery of significant new housing in and around the town centre. In view of the market shifts needed, delivery is likely to be phased towards the end of the plan period. The town centre broad location was originally considered to have the potential to deliver in the order of 200 additional homes. However, due to emerging proposals for The Mall, which would see substantial new residential development coming forward as part of a comprehensive redevelopment of the shopping centre, it was felt appropriate to increase this number to 600.
Lenham Rural Service Centre
Lenham is a compact settlement surrounded by flat, arable
land. The village benefits from a good range of infrastructure and facilities,
including a primary school, secondary school, train station, village hall,
local shops, and a medical centre. The village has access to employment
opportunities locally, and good rail and bus links to Maidstone and Ashford
towns. The village has easy access to the A20 which leads to Junction 8 of the
M20 motorway.
There is potential for the village to expand. There are no
known major constraints to the provision of additional housing development,
although further studies are likely to be required to assess the impact of
development on the environment and to identify the mitigation measures
necessary for any proposals to proceed. Impacts on the setting of the AONB
will need careful assessment. There are no known flooding issues in the
location. Land is available to the east and west of the village that has
potential to deliver in the region of 1,500 dwellings recognising the need to
avoid the coalescence of the village with neighbouring Harrietsham.
Unmet housing need
The borough’s objectively assessed housing need is 19,600
dwellings. Since 2011, approximately 4,100 units have been built or are in the
pipeline. The recommended housing land allocations in the draft local plan
yield a further 10,000 homes, and broad locations 3,000 dwellings. The balance
of unmet need is therefore in the region of 2,500 dwellings.
At examination, the council will have to demonstrate why its
full housing need cannot be met. Constraints to development will have to be
robustly defended[7]
and evidence produced to demonstrate what measures have been taken to address
unmet need.
It was recommended that a further call for sites be
undertaken as part of the public consultation exercise, to establish whether
there are additional sites suitable for development that have not yet been
subject to the SHLAA process. At the time of the deadline for the Call for
Sites, the agreed ‘working’ housing target was some 14,800 dwellings (2011-31)[8],
appreciably below the 19,600 objectively assessed needs figure now in place. A
further call for sites exercise will ensure that sites are submitted in full
knowledge of the up to date evidence-based needs figure. Alongside this exercise,
an appraisal of reasons why SHLAA sites were rejected should be undertaken to
establish whether additional mitigation measures could release rejected sites
for development.
Ultimately, if objectively assessed need is not met, then a
strong case of constraints, substantiated with evidence (for example of
infrastructure capacity) must be made and, under the duty to cooperate, the
council must demonstrate whether unmet need can be satisfied by neighbouring
authorities. It was important to note that some adjoining authorities are
likely to be more constrained than Maidstone, particularly by national
designations such as the AONB and Green Belt. Also, to be aware that those
authorities may in fact look to Maidstone to accommodate their unmet housing need.
A similar position arises with the provision of sites to
accommodate Gypsy and Traveller pitches and Travelling Showpeople plots.
Allocations are proposed for some 23 Gypsy and Traveller pitches in the draft
Local Plan. With the addition of the 57 pitches granted permanent consent since
October 2011, and the potential 15 pitches which the Homes and Communities
Agency-funded new public site would deliver, there is a shortfall of some 92
pitches against the total requirement for 187 pitches (2011-31). A further call
for sites to address the needs of these communities should be undertaken in
tandem with a call for market housing sites.
|
Need |
Supply |
Unmet need |
Gypsy & Traveller pitches |
187 |
95 |
92 |
Travelling Showpeople plots |
11 |
0 |
11 |
Employment land needs and Junction 8
Background
The draft Core Strategy (2011) published for public
consultation in September 2011 identified Junction 8 of the M20 motorway as a
strategic location for employment. At that time, based on the scale of
employment land requirements (Employment Land Review Partial Update 2011) it
was considered that land at Junction 8 would be required in addition to a
dispersed pattern of smaller sites to accommodate industrial and warehousing
floorspace.
In July 2012 Cabinet considered the main issues raised in
the public consultation on the Core Strategy. As reported at the time, there
was support from the public and the development industry for the identification
of Junction 8 of the M20 motorway as an employment location (22 respondents or
5%). There were also suggestions that this location could accommodate housing
or mixed use development for housing and employment. There was a high level of
opposition to development at Junction 8 from local residents (254 respondents
or 52%), who objected on the grounds of the KIG appeal decision, the impact on
the landscape, the loss of Special Landscape Area protection, increased traffic
congestion, and the provision of low skilled jobs in this location. Alternative
employment sites were proposed by respondents (but not the landowners) at
Detling Airfield Estate, Park Wood and Hermitage Lane.
The same Cabinet report concluded that Junction 8 would be
the best location for a critical mass of employment uses, including premier
office development, industry and warehouse uses, of a quantity that would
enable the delivery of the necessary supporting infrastructure whilst also
providing for a qualitative scheme in a parkland setting to help mitigate the
impact of development on the landscape. The location also has transport
capacity.
Cabinet resolved to retain Junction 8 of the M20 motorway as
a strategic location for economic development to address qualitative and
quantitative employment needs and the aspirations of the Council (as set out in
the Economic Development Strategy 2008), pending further consultation as part
of the Strategic Site Allocations consultation in August/September 2012, to
enable a more informed decision to be made on the allocation of strategic
site(s) at this location.
In March 2013 the outcomes of the strategic sites public
consultation were reported to Cabinet. The issues raised in connection with
Junction 8 were wide ranging and, to a large extent, focused on public
opposition to the principle of development in this location. The main issues
raised included the questioning of the need for the development, the
availability of alternative sites within and outside the borough, impact on the
AONB, impact on the highway network, the loss of countryside, the
sustainability (or otherwise) of the location, precedent and concerns over the
quality of jobs which would be generated.
In the same report Cabinet was presented with an update of
the borough’s employment land demand (based on delivering interim housing
provisions of 14,800 dwellings up to 2031). The updated evidence pointed to a
more modest requirement for employment land overall than previously, with a
particular emphasis on office uses. Based on this updated evidence, the
justification to release employment land at Junction 8 became less clear cut
than it had been previously.
Cabinet took the decision to retain Junction 8 as a
strategic development location for employment until such time as the work
identifying employment land demand (employment land forecasting) and supply
(the Strategic Economic Development Land Availability Assessment) was
completed.
Employment land requirements
As reported to Cabinet on 27 January 2014, a further
employment land forecast has been undertaken to cover the plan period
(2011-31). As well as the basis for employment land forecasting, this work was
also the starting point for the ‘economic-led’ housing projection in the SHMA,
enabling consistency across the Council’s evidence base.
This forecast was stemmed from a sectoral analysis of the
economy, critically analysing which sectors are likely to grow and which are
contracting. The analysis specifically tries to identify sectors where the
potential for growth at above a ‘business as usual’ level. In this respect the
forecast is ambitious. The analysis also allows for the direct and indirect
jobs that will be created as a result of the specific Kent Institute of
Medicine and Surgery and Maidstone Medical Campus development. This was a
specific proposal which will provide a wider catalyst to growth.
The analysis looks across all the sectors in the local
economy. This growth is then translated into an employment land demand figure
for just those sectors which will require office, industrial/manufacturing and
warehouse/distribution premises in the future (i.e. B use classes).
The total floorspace demand figure for the whole Local Plan
period is shown in the first line of the table below. Whilst the greatest
amount of floorspace will be needed for distribution/warehousing uses, these
are land hungry uses. Office based development will actually be far more
significant in terms of the number of the new jobs generated.
2011-2031 |
Offices |
Industrial |
Warehousing |
TOTAL |
Total floorspace requirement (m2) |
39,830 |
20,290 |
49,911 |
110,030 |
Jobs |
3,053 |
226 |
453 |
3,733 |
% B class jobs |
82% |
6% |
12% |
100% |
Table: Total floorspace requirements and jobs (excluding KIMS/Medical Campus)
This requirement is for the full 20 year period of the Local Plan. The net requirement to be addressed in the Local Plan results when the following supply factors are deducted:
· Completions achieved in 11/12 and 12/13
· Sites with planning permission[9]
·
Vacant premises[10]
The net floorspace/land forecast is set out in the bottom
row of the table below. This requirement is additional to the land already identified
and granted permission for the KIMS/Maidstone medical Campus proposals.
|
Office
|
Industrial |
Warehousing |
Total floorspace Requirement (m2) 2011-31 |
39,830 |
20,290 |
49,911 |
Supply (m2) |
24,247[11] |
16,595 |
36,964 |
Net floorspace requirement (m2) 2013-31 |
15,583 |
3,695 |
12,947 |
Table: Net employment land requirement 2013-2031
Strategic Economic Development Land Availability Assessment (SEDLAA)
The SEDLAA has been undertaken in parallel with the SHLAA.
Some 37 sites were assessed for their potential for employment, retail or mixed
use. The submitted sites included two sites at Junction 8: land at Woodcut Farm
and Waterside Park.
The sites were assessed following the agreed criteria in the
SEDLAA assessment pro forma[12].
As for the SHLAA, the expert input of key statutory consultees was sought (Kent
Highways; EA; KCC ecology; KCC archaeology).
Based on the SEDLAA assessment, the new industrial and
warehousing floorspace required could be delivered in a dispersed pattern of
new employment allocations. This would include the expansion of the existing
successful industrial estates at Pattenden Lane, Marden and at Barradale Farm,
near Headcorn. Mixed employment and residential allocations would be made at
Syngenta, Yalding, helping to bring forward a brownfield site previously in
employment use, and at Clockhouse Farm, Coxheath. This dispersed selection of
sites would meet and indeed exceed the floorspace needs for industrial and
warehousing space in the borough across a number of locations, providing some
flexibility and choice and enabling the local expansion of firms. Further, the
sites at Marden for example could be used for manufacturing type uses or
distribution and it would be appropriate to allocate such sites for either use,
again to allow for flexibility. It was recommended that all these sites are
appropriate for allocation in the draft Maidstone Borough Local Plan, with
necessary mitigation measures set out in the site specific allocation policies.
Either of the two sites submitted at the Junction 8 location
could accommodate the full requirement for industrial and warehousing
floorspace.
Junction 8 is currently a countryside location, removed from
the built up area of Maidstone. Development of either of these candidate sites
would substantially alter their established character. The existing urban
influence in the vicinity of the Woodcut Farm site is slightly greater,
provided by the residential and small commercial development along the A20 and
the road interchange itself. However its development would significantly alter
the immediate rural character of the site and the inherent attractiveness that
these fields have as an area of undeveloped countryside located on key routes
into, and past, Maidstone.
The vicinity of the Waterside Park site is more rural in character. The site appears as a component of the rolling countryside to the south, particularly in views from the south and from the public right of way which crosses it.
The Woodcut Farm site forms part of the setting of the Kent
Downs Area of Outstanding Natural Beauty (AONB) and represents a continuation
of the landform of the North Downs. It is also visible, at a distance, from
points in the AONB. Development would have an adverse effect on the setting of
the AONB. Views from the AONB of Waterside Park are comparatively more limited
whilst, in views from the south, the site is clearly seen as part of the
foreground to the scarp slope of the AONB.
Officers have previously advised that the size and
characteristics of the Woodcut Farm site do offer an opportunity for the
landscape impacts of development to be mitigated[13]. This could be achieved by
ensuring the existing topography of the site is respected through minimal site
levelling, through significant additional structural landscaping and through
careful design in terms of the buildings’ scale, siting, orientation and
materials. The context for this advice was a substantive and over-riding need
for additional industrial and warehousing development which could not be met on
alternative sites.
To develop the Waterside Park site would require extensive
excavation which would be a substantial and unavoidable alteration to the
prevailing form of the landscape. There is significantly less opportunity on
this site to soften the impacts of development through enhanced landscaping.
Development of either site would cause substantial landscape harm. Further, Junction 8 is removed from the existing built up area from Maidstone. The sites are in a relatively unsustainable rural location. An allocation here would create a new employment destination in a location poorly served by public transport and relatively removed from centres of population and the attendant workforce. These sites are within walking and cycling distance of few residential areas and development of either is likely to particularly attract car-borne workers.
Qualitative need and market considerations
The NPPF directs that local planning authorities need to
assess both the qualitative as well as the quantitative need for employment
land when drawing up their Local Plans (para 161). Qualitative considerations
are set out below.
Connections to the strategic road network: The Junction 8 location clearly has very close access to M20 and thereafter the wider strategic road network. This is an attractive factor for businesses for business efficiency reasons, and HGV movements on local roads would be more limited. The dispersed selection of sites are located at a distance from the strategic road network. Their development is likely to result in more/longer HGV movements on local roads although it is of note that KCC Highways has not objected to their potential allocation. Key routes to the M20 from Marden (A229) and Headcorn (A274) require HGVs to pass through Maidstone town centre which is a constraint. The Syngenta site has a more direct connection to J4 of the M20 via the A228. Experimental Traffic Regulation Orders have been made around Marden and Yalding with the aim of directing lorries in excess of 7.5 tonnes away from this area and on to the main road network. The Joint Transportation Board has recently recommended that this order be retained[14]. If made permanent, this risks reducing the attractiveness of the area for businesses as it increases journey times and adds fuel and driver time costs for some deliveries and exports.
Price: Premises at Junction 8 will be more expensive to purchase/let because of their motorway location. In contrast with a dispersed pattern of development, sites are likely to be more affordable for a wider range of firms.
Range of sites: A site at Junction 8 will be in a single ownership but could be delivered in phases to help stagger supply. The dispersed pattern offers a choice of sites in different locations. It offers a wider geographical spread of potential sites, in different ownerships which could come forward at different times over the plan period in response to demand.
Site capacity: A site at Junction 8 will be capable of meeting larger scale needs, as well as smaller scale requirements. The dispersed sites are less likely to be able to accommodate a single, large end user.
Market Interest: there is clear, current market interest to deliver and occupy new employment floorspace at Junction 8. The site is likely to be more attractive to inward investors than the dispersed sites. Market demand analysis in the Employment Land Review (2013) however suggests that demand for both industrial and warehousing is more likely to be locally generated (existing firms expanding) or of a sub-regional nature.
Existing/new business locations: Development at Junction 8 would create a brand new business location and could provide a prestigious, business park form of development and a new business ‘offer’ for the borough. The dispersed pattern provides for the localised expansion of existing successful business locations. It could better enable the expansion of firms in situ, and potentially better serve established, local firms.
Promotion of the borough as a business location: A single large site at Junction 8 (in addition to Junction 7) will bring a significant marketing opportunity to promote the borough as a business location. A diversity of smaller sites is likely to be much less marketable.
Conclusion
Junction 8 as a location for new employment floorspace has some has significant, qualitative advantages. Key is its location immediately adjacent to the strategic road network. This helps to drive its market attractiveness and will serve to control HGV movements on local roads. It is the case that a site at Junction 8 is much more likely to be attractive to an inward investor and would be a more prestigious site for the promotion of the borough. This is a significant consideration; one of the council’s three key objectives is for Maidstone to have a growing economy.
However, it is considered that the harm caused by development in the location of Junction 8 would be substantial, in particular in terms of impacts on the AONB and the wider landscape. Local Planning Authorities have a duty to have regard to the conservation and enhancement of the natural beauty of AONB landscapes. This duty equally applies to development proposals outside the boundary of an AONB but which may impact on the designated qualities of the AONB[15]. Coupled with the relative unsustainability of Junction 8 as a new employment location, the harm caused by development here is not considered to be over-ridden by the acknowledged qualitative benefits.
Office requirements
There is a net requirement for some 15,583m2 of
new office space over the plan period. The NPPF directs a town centre first
approach to new office development. There has been no significant new office
development delivered in or close to the town centre since the County Gate
scheme in the late 1990s, despite planning permissions being granted. In
contrast there is over-supply of poorer quality stock. In the first instance
this oversupply needs to be rationalised through the conversion of offices to
alternative uses. To this end the draft Local Plan seeks to protect only the
better quality office locations as ‘economic development areas’ (Policy DM18).
There is the opportunity to allocate land at Mote Road,
Maidstone to provide substantive new town centre offices over the timescale of
the Plan. Clockhouse Farm at Coxheath can also provide for an element of office
space as part of its mixed use allocation.
With these allocations confirmed, there is a shortfall in of
some 5,483m2 on measured requirements (equating to 14% of the total
requirement or 39% of the net requirement).
As set out, there is a lack of current demand for
speculative office development. As and when market demand returns, there is
considerable immediate capacity at Eclipse Park (some 7,071m2
permitted plus 3,500m2 additional capacity). Some general office space
(24,750m2) will also be delivered as part of the Maidstone Medical
Campus which has outline permission. The market analysis in the Employment
Land Review (2013) highlights that as demand picks up sites such as Eclipse
Park, coupled with the rationalisation of the town centre stock, will be able
to deliver new flexible, modern floorspace. There is therefore considerable
short term (pipeline) and future planned supply of new, modern office space.
Additionally, the ancillary office space provided as part of
industrial/warehousing development will contribute to the identified
requirement.
The Spatial Strategy (Policy SS1) and Sustainability
Appraisal
There have been a number of iterations of the Sustainability
Appraisal as the local plan has developed. These iterations have produced
recommendations which have, in turn, helped to shape the local plan policies.
The following examples show some instances where this has been the case:
·
Policy DM2 (sustainable design standards) was amended following a
recommendation from the SA that the wording could be strengthened in relation
to the Code for Sustainable Homes, BREEAM and stress on water resources;
·
Policy DM4 (principles of good design) was amended following a
recommendation from the SA that the policy would be enhanced through explicitly
identifying the need for development proposals to be designed to ensure that
the borough’s biodiversity and geodiversity features are protected and
enhanced; and
·
The SA highlighted the fact that that a number of employment
sites fell within flood zone 3b, and recommended that policies be amended to
emphasise the need to avoid new development within areas at risk from flooding,
or to mitigate any potential impacts of new development within areas at risk
from flooding.
The local plan sets out a clear settlement hierarchy for
determining which locations are the most sustainable for allocating new
development sites. Following the redevelopment of brownfield sites within
settlement boundaries, the most sustainable location for greenfield development
is adjacent to the currently defined[16]
urban boundary, where access to services is greatest and best use can be made
of existing infrastructure. Rural service centres are the most sustainable
villages and form the second tier in the settlement hierarchy because they act
as a focal point for trade and services for wider communities, providing a
concentration of public transport, employment and community facilities. Larger
settlements form the third tier of the settlement hierarchy and can accommodate
limited development, where appropriate, having a smaller range of services than
rural service centres, but still meeting the day-to-day needs of local
communities.
Within this settlement hierarchy there are options for the
distribution of development, and alternative strategies must be considered as
part of the local plan process.
The emerging sustainability appraisal (SA) has appraised
various housing options that follow the settlement hierarchy, but has also
assessed the impact of the Golding Homes’ proposal for a new settlement[17], which was
submitted during the call for sites. The SA appraised three targets for
housing: 19,600 dwellings (objectively assessed need), 17,100 dwellings (draft
capacity to date including broad locations for development), and 14,100
dwellings (draft capacity to date excluding broad locations for development).
The targets were assessed against the various distribution options for
development: a dispersed pattern of development, with and without broad
locations for development and/or the new settlement. This compares the local
plan strategy of development dispersal with an alternative of a new settlement
together with a reduced dispersal of development. These options were tested
against their ability to deliver the objectively assessed need for housing, but
were balanced by sustainability indicators including flooding, health, poverty,
education, congestion, climate change, biodiversity, countryside, heritage,
waste, energy and economy.
Table 3: Sustainability Appraisal of housing development options |
||
1 |
19,600 |
Dispersed and broad locations |
2 |
19,600 |
Dispersed, broad locations and a new settlement |
3 |
17,100 |
Dispersed and broad locations |
4 |
17,100 |
Dispersed and new settlement |
5 |
14,100 |
Dispersed only |
6 |
14,100 |
Dispersed and a new settlement |
The emerging results show that, on balance, alternatives 5
and 6 would fail to meet the housing need for the borough, leading to negative
impacts on the economy, health and wellbeing in the longer term. Alternatives 1
and 2 would have a more pronounced positive impact on housing and economic
factors, but adverse impacts on levels of congestion would be more likely.
Options 1 and 2 could also lead to an oversupply of housing compared to the
level of jobs planned for. In combination, these factors could
have negative implications for the wider local economy, health and wellbeing.
Alternatives 3 and 4 may not quite meet the identified housing need, but would
be likely to have a less severe impact in terms of congestion and other environmental
impacts. These two options are also likely to be more suitably matched to the
number of projected jobs. However, due to the constraints and uncertainties
associated with the delivery of a new settlement, the SA concludes that
alternative 3 is more favourable than alternative 4.
Based on all known sites at this point, the SA supports the
local plan strategy of providing for 17,100 dwellings in a dispersed
distribution pattern of development supported by the identified broad locations
for future housing growth.
Additionally, the SA has examined two employment
distribution options: the local plan dispersed strategy and one of
concentration at Junction 8.
Table 4: Sustainability Appraisal of employment development options |
||
Option |
Employment provision (m2) |
Distribution pattern |
A |
Office – 39,830 Industrial – 20,290 Warehousing – 49,911 Medical – 98,000 |
Concentrated (town centre, J7 and J8) |
B |
Office – 39,830 Industrial – 20,290 Warehousing – 49,911 Medical – 98,000 |
Dispersed (town centre, J7 and RSCs)
|
The emerging results show that both alternatives would have
a significant positive impact by increasing the quantity and quality of
employment opportunities. There would also be benefits in terms of increased
opportunities to develop skills in the health sector in particular.
Both options would help to tackle deprivation by providing
jobs in close proximity to areas of need. This is particularly the case for
alternative A. However, there is a danger that increased movements into the
Maidstone urban area could exacerbate existing congestion and air quality
issues, having an effect on the wider local economy and health. These effects
would be less pronounced for alternative B, which would disperse an element of
employment to a number of settlements to the south of the urban area. This
dispersal strategy would also support the local economies in a number of
service centres, but might not attract high-profile development.
Alternative A could have a significant negative impact on
landscape character due to the location of the Junction 8 site in relation to
the Kent Downs AONB. Although alternative B could still lead to localised
impacts on character around a number of settlements, the impacts are considered
less significant. Both alternatives make little use of previously developed
land and would lead to the loss of grade 2 and 3 agricultural land.
The SA concluded that, on balance, alternative B (the local
plan strategy) has fewer impacts on congestion, countryside and heritage
The SA highlighted the fact that proposed mixed use
development at Syngenta, Yalding, is within areas at significant risk of
flooding. This has been recorded as a negative impact for alternative B, but
mitigation measures can be implemented to avoid negative impacts.
The spatial strategy (policy SS1) sets housing provisions of
17,100 dwellings, to be delivered in a dispersed distribution pattern of
development. Employment provisions are also met through a dispersed strategy.
Both options are supported by the interim sustainability appraisal, including
the balance of new jobs and homes.
The sustainability appraisal will continue to evolve with
the local plan, and the interim SA will be published as part of the evidence
base during public consultation.
Affordable Housing (Policy DM24)
The 2014 Strategic Housing Market Assessment (SHMA)
identifies the affordable housing need in the borough, for the period 2013 to
2031, as 322 per annum. It is important to note the reasons for the change in
affordable housing need arising from the new study compared to the need
identified in 2010.
The 2010 SHMA identified an annual affordable housing need
of 1,081 homes. This change in need can be attributed primarily to the
methodology used. The 2010 methodology sought to address affordable need in a
five year time period, rather than across the period of the local plan. Where
the need is significant, as was identified in the 2010 SHMA, this approach
causes difficulties in attempting to meet that need through policy targets. The
2010 SHMA did recognise this and offered an alternative approach that addressed
needs across the plan period – based on the then housing target of 11,080 [for
the period 2006-2026], it recommended a target of 38%.
In the four years between the studies, the baseline conditions
in the borough have also changed, each affecting the affordable need figure.
The 2011 Census showed that the population of the borough has increased further
than the Office for National Statistics had previously estimated. The list of
people on the housing register has changed, mainly through a change in the
housing allocation policy, which has restricted access to the register (April
2013). The amount of affordable housing stock has increased in the intervening
period as a result of development in the borough. Consequently, the 2014 SHMA
recommends that a 30% target across the borough would be appropriate to meet
affordable need.
The 2013 Local Plan Viability Testing identified that the following affordable housing targets were achievable in viability terms:
· Previously developed land (urban) – 15%
· Greenfield and private residential land (urban and urban periphery) – 30%
·
Countryside, rural service centres and larger villages – 40%
This viability information means that if the targets for
these areas were set higher, affordable housing could still only be delivered
at these rates.
Using this information in conjunction with capacity based potential development splits to these broad geographical areas, 4,144 affordable units could be expected to be delivered for the period 2013-2031. In addition to the 427 units in the pipeline, this equates to 254 units per annum, a shortfall of 68 units against the identified annual affordable need. It is reasonable to expect that this shortfall could be addressed by the private rented sector, based on current estimated lettings levels.
Drawing on the evidence in the 2014 SHMA, the proposed
tenure split in Policy DM24 has been amended, with agreement from the council’s
housing department, to seek not less that 65% affordable rented housing, social
rented housing, or a mixture of the two. The balance of up to 35% of affordable
dwellings delivered will be intermediate affordable housing (shared ownership
and/or intermediate rent
Countryside (Policy SP5)
Policy SP5 (Countryside) has been amended to include a map that identifies the borough’s landscapes of local importance, namely the Greensand Ridge, Medway Valley, Loose Valley and Len Valley. These landscapes were highlighted as areas of local importance by the public through previous consultation. The council will, where possible, protect its most sensitive landscapes that are in good condition, in accordance with the Landscape Character Assessment.
Alternatives considered and why rejected
Alternative courses of action have been included in the reasons above.
Background Papers
None
Should you be concerned about this decision and wish to call it in, please submit a call in form signed by any two Non-Executive Members to the Head of Policy and Communications by: 5 March 2014. |
[1] August 2013
[2] A similar pro forma was used in the assessment of potential Gypsy and Traveller sites, and for economic development sites, both of which were part of the call for sites.
[3] As defined in the Maidstone Borough Wide Local Plan 2000. Settlement boundaries will be amended to take account of new land allocations once the local plan is adopted.
[4] Including strategic site allocations to the north west and south east of the urban area.
[5] Deliverable sites must be available, offer a suitable location, be achievable (with a realistic prospect of being delivered within those 5 years), and be viable.
[6] Developable sites must be suitably located, and available and viable at the point of release.
[7] A section on development constraints was included in 27 January 2014 Cabinet report.
[8] Cabinet, 13th March 2013.
[9] This figure excludes two sites where the extant planning permissions for offices (= 23,150sqm) are unlikely to be implemented because of alternative proposals; the site at Eclipse with permission for Next and the site at Springfield which is proposed to be allocated in the draft Maidstone Borough Local Plan for housing
[10] Includes deduction of 5,000sqm for the poorest quality vacant town centre office stock
[11] Includes CIA adjustments at Eclipse Park
[12] Pro forma agreed by Cabinet Member for Planning, Transport and Development 22 March 2013
[13] Cabinet report 25 July 2012
[14] Maidstone Joint Transport Board 22nd January 2014
[15] Draft National Planning Practice Guidance (August 2013)
[16] Maidstone Borough Wide Local Plan 2000
[17] Proposal for a freestanding garden suburb, accommodating 3,000 to 5,000 new homes on greenfield sites located to the south east of the urban area.