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MAIDSTONE BOROUGH COUNCIL
PLANNING, TRANSPORT AND DEVELOPMENT OVERVIEW AND SCRUTINY COMMITTEE
TUESDAY 18 FEBRUARY 2014
REPORT OF HEAD OF PLANNING AND DEVELOPMENT
Report prepared by Sue Whiteside
1. Maidstone Borough Local Plan Public Consultation Draft (Regulation 18)
1.1 Issue for Decision
1.1.1 To
consider the draft Maidstone Borough Local Plan (attached at Appendix A). This
report brings together all of the policies Members have given consideration to
in the past year. New parts of the document include the spatial strategy and
site allocation policies. The report considers the borough’s objectively
assessed needs, and explains the processes undertaken in the selection of
recommended sites for development.
1.1.2 To consider land at Junction 8 of the M20 motorway as a strategic location for employment use. The full consideration of this site was deferred until further work on employment needs had been completed.
1.2 Recommendation of Head of Planning and Development
1.2.1 That Planning, Transport and Development Overview and Scrutiny Committee recommends that Cabinet:
i. Approves the draft Maidstone Borough Local Plan for public consultation (Regulation 18) attached at Appendix A;
ii. Rejects
the designation of land at Junction 8 of the M20 motorway as a strategic
location for employment use; and
iii. Approves
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.
1.3.1 This
report is seeking approval of the preparation draft of the Maidstone Borough
Local Plan for public consultation (Regulation 18 consultation). It is 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).
1.3.2 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 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.
1.3.3 This
Committee and Cabinet have given consideration to several groups of local plan
policies over the past year. This report brings those policies together in a
single document.
1.3.4 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.
1.3.5 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 was available. These proposed site allocations are now included as part of the draft Local Plan appended to this report. The recommendation on the designation of settlements is unaltered from previous reports; it is 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.
1.3.6 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.
1.3.7 There
are also a number of appendices that contain 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 include 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.
1.4 Housing
needs and the Strategic Housing Land Availability Assessment (SHLAA)
1.4.1 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.
1.4.2 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, via this Committee) was used to build consistency
into the process[2].
1.4.3 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.
1.4.4 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.
1.4.5 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.
1.4.6 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.
1.4.7 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.
1.5 Future locations
for housing growth
1.5.1 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.
1.5.2 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.
1.5.3 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
1.5.4 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.
1.5.5 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
1.5.6 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 is considered to have
the potential to deliver in the order of 200 additional homes.
Lenham Rural Service Centre
1.5.7 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.
1.5.8 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
neighboring Harrietsham.
1.6
Unmet
housing need
1.6.1 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.
1.6.2 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.
1.6.3 It is 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.
1.6.4 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 is 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.
1.6.5 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 |
1.7
Employment
land needs and Junction 8
Background
1.7.1 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.
1.7.2 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.
1.7.3 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.
1.7.4 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.
1.7.5 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.
1.7.6 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.
1.7.7 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
1.7.8 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.
1.7.9 This forecast has 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 is a specific proposal which will provide a wider catalyst to
growth.
1.7.10
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).
1.7.11
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)
1.7.12 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]
1.7.13
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)
1.7.14
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.
1.7.15
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).
1.7.16
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 is 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.
1.7.17
Either of the two
sites submitted at the Junction 8 location could accommodate the full
requirement for industrial and warehousing floorspace.
1.7.18
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.
1.7.19 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.
1.7.20
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.
1.7.21
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.
1.7.22
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.
1.7.23
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
1.7.24
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.
1.7.25 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 Transport 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.
1.7.26 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.
1.7.27 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.
1.7.28 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.
1.7.29 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.
1.7.30 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.
1.7.31
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
1.7.32 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.
1.7.33 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
1.7.34
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).
1.7.35
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.
1.7.36
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).
1.7.37
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.
1.7.38
Additionally,
the ancillary office space provided as part of industrial/warehousing
development will contribute to the identified requirement.
1.8
The
Spatial Strategy (Policy SS1) and Sustainability Appraisal
1.8.1 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.
1.8.2 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.
1.8.3 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.
1.8.4 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 |
1.8.5 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.
1.8.6 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.
1.8.7 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)
|
1.8.8 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.
1.8.9 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.
1.8.10
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.
1.8.11
The
SA concluded that, on balance, alternative B (the local plan strategy) has
fewer impacts on congestion, countryside and heritage
1.8.12
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 alterative B, but mitigation measures can be
implemented to avoid negative impacts.
1.8.13
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.
1.8.14
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.
1.9
Affordable
Housing (Policy DM24)
1.9.1 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.
1.9.2 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%.
1.9.3 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.
1.9.4 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.
1.9.5 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.
1.9.6 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
1.10 Countryside (Policy SP5)
1.10.1 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.
1.11 Alternative Action and why not Recommended
1.11.1 Alternative courses of action are discussed throughout the report.
1.12 Impact on Corporate Objectives
1.12.1 The Maidstone Borough Local Plan supports the delivery of the spatial objectives of the Maidstone Community Strategy and the Strategic Plan. It also has regard to objectives set out in other corporate documents, in particular the Housing Strategy. The local plan supports the council’s priorities for Maidstone to have a growing economy and to be a decent place to live, and the consultation processes will strive to meet corporate and customer excellence.
1.13 Risk
Management
1.13.1
The council still
has a local planning policy framework that comprises adopted development plan
documents and supplementary planning documents, endorsed guidance, and saved
policies from the Maidstone Borough Wide Local Plan 2000. These policies are
still relevant and carry weight in the decision making processes provided there
is no conflict with the National Planning Policy Framework (NPPF). However,
the council has a duty to maintain an up-to-date policy framework, and current
policies are increasingly becoming outdated or are in conflict with the NPPF.
It is important to maintain the momentum for the preparation of the Maidstone
Borough Local Plan and to reach a consensus that the local plan is fit for
public consultation.
1.13.2 The retention of legal and professional services to guide the local plan through its preparation stages, and the production of up-to-date robust technical evidence will ensure the Maidstone Borough Local Plan is found sound at examination.
1.14 Other Implications
1.14.1
1. Financial
|
X |
2. Staffing
|
X |
3. Legal
|
X |
4. Equality Impact Needs Assessment
|
X |
5. Environmental/Sustainable Development
|
X |
6. Community Safety
|
|
7. Human Rights Act
|
|
8. Procurement
|
X |
9. Asset Management
|
|
1.14.2
Financial:
A dedicated budget has been identified to undertake the work relating to the
preparation of the local plan. The costs of public consultation can be
accommodated within that budget.
1.14.3 Staffing: The public consultation on the Maidstone Borough Local Plan can be managed within existing staff resources.
1.14.4
Legal: Legal
services have been retained to offer advice on document content and processes
to ensure the Maidstone Borough Local Plan is found sound at examination. A
number of meetings have been held with Counsel and the Head of Legal Services.
These services can be managed within the existing budget for local plan
production.
1.14.5 Equalities Impact Assessment: the consultation process will engage with all individuals and communities in accordance with the equalities legislation and the council’s equalities policy.
1.14.6 Procurement: Although additional evidence base work has been prepared in-house where possible, it is necessary to employ consultants on short term contracts to undertake specialist pieces of work. Appointments are in accordance with the Council’s procurement procedures and the costs can be managed within the existing budget for local plan production.
1.14.7 Environmental/sustainable development: A sustainability appraisal, incorporating a strategic environmental assessment, is required for all local plan policies including site allocations. Consultants have been appointed to undertake this technical exercise, and costs can be managed within the existing budget for local plan production. The sustainability appraisal is an iterative process, and the draft Maidstone Borough Local Plan has undergone initial appraisal.
1.15 Relevant
Documents
Maidstone Borough Local Plan 2014 evidence base http://www.maidstone.gov.uk/residents/planning/local-plan
1.15.1
Appendices
Appendix A: Maidstone Borough Local Plan – Preparation (Regulation 18) 2014
1.15.2
Background
Documents
None
IS THIS A KEY DECISION REPORT? THIS BOX MUST BE COMPLETED
Yes No
If yes, this is a Key Decision because: The report affects local plan policies, plans and strategies
Wards/Parishes affected: All wards and parishes
|
[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.