1.  That a local housing target of 10,080 dwellings and a development distribution for new housing as set out in Appendix C of the report of the Director of Change, Planning and the Environment be agreed for the period 2006 to 2026 as the basis for the initial Core Strategy consultation document; and

2.  That a decision on the distribution of employment land be deferred to enable officers to:

 

a)  undertake further work on updating employment data to a base date of 2010;

 

b)  investigate opportunities for alternative potential employment sites that can support a dispersed pattern of development better suited to the housing locations to replace a critical mass of employment land of 11 hectares at J8 of the M20 motorway

 

and report back to Cabinet in April when the draft Core Strategy will be considered for publication consultation.

 

3.  That the revised Core Strategy programme, as set out below, be agreed:-

 

 

Core Strategy Stage	Dates
Joint Local Development Document Advisory Group and Leisure and Prosperity Overview and Scrutiny Committee	21st February 2011
Cabinet approval of draft Core Strategy	13th April 2011
Public consultation ( 6 weeks)	28th April to 17th June 2011
Cabinet approval of Publication version	10th August 2011
Publication consultation (6 weeks)	26th August to 10th October
Council approval of Submission version	14th December 2011
Submission	December 2011
Examination	April 2012
Receipt of Inspector’s Report	July 2012
Council adoption of Core Strategy	September 2012

 

The Core Strategy Development Plan Document (DPD) will set out the spatial vision and strategy for the future development of Maidstone borough to 2026.  Part of its new role is to identify a local dwelling target for the period 2006 to 2026, and to demonstrate how that target will be delivered.  Significant work has been undertaken to assess the borough’s priorities, identify the relevant factors and gather a wide range of information and evidence, and to inform both the target and distribution.

It was noted that saved local plan policy H1, which includes the currently frozen greenfield housing land allocations, will be superseded by the Core Strategy and these sites will be reviewed together with other potential development sites when allocating land for development in subsequent development plan documents and area action plans.  Public consultation on site specific land allocations will commence once the Core Strategy is adopted in the autumn of 2012, and site allocations are expected to be adopted by 2014.  A further report will be presented to Cabinet on 13th April 2011 to approve the draft Core Strategy for public consultation, which will include a new timetable for the preparation of all LDF documents.  The timetable set out in the report of the Director of Change, Planning and the Environment focuses on the Core Strategy programme. 

However, the Core Strategy will need to be flexible and deliverable.  The majority of development in recent years has been located on brownfield sites within the urban area, so it is important to focus a proportion of development at Rural Service Centres to support the continuing viability aspirations of these settlements.  Therefore, in where there is firm evidence to demonstrate a local need at a Rural Service Centre that cannot be met through a local needs housing site, a proportion of suitable greenfield housing development may be permitted before 2014, in advance of allocating specific sites in site allocations documents that will follow the Core Strategy.  Any such proposals will need to cater for the physical and social infrastructure needed in the Rural Service Centre area.

The Council has commissioned a number of studies that examine the borough’s supply of retail and employment land and the potential for increased demand for new development.  Office development will be directed towards the town centre in accordance with the sequential test[1], as will the majority of new retail development although it is recognised that some small-scale retail development will be provided as part of new housing developments at the urban fringe and at the Rural Service Centres.  The report of the Director of Change, Planning and the Environment therefore focused on the need to provide new land to accommodate employment development (other than retail and offices) outside of the urban area.

An outline development strategy is required for all land uses before the Core Strategy’s spatial policies can be completed and the document published for the next round of public consultation.  The purpose of this current report of the Director of Change, Planning and the Environment is to consider the identification of a target number and strategy for distributing new housing and employment (excluding retail and offices), although the draft Core Strategy will include a strategy for all land uses.

 

Following detailed analysis, a range of formal and informal Council meetings and a number of initial discussions with a wide range of infrastructure providers, it was recommended that the development strategy adopted for the purposes of consultation comprises a housing target of 10,080 (3,320 dwellings net of completions and supply) and an employment target of 22.5ha (that results in the need for 17ha of new employment land, other than retail and offices, net of completions and supply) with a dispersed spatial distribution of development as illustrated in Appendix C of the report of the Director of Change, Planning and the Environment.

Historical Background

The development plan for Maidstone comprises a number of local and strategic documents: adopted development plan documents (Affordable Housing DPD and Open Space DPD), saved policies from the Maidstone Borough-Wide Local Plan, and saved policies from the Kent Minerals and Waste Local Plans that are prepared by Kent County Council.  The South East Plan, which is the regional spatial strategy for the south east, also currently forms part of the development plan.

Following public response to the former issues and options stage of the Core Strategy in 2006, the Council appraised 11 draft spatial objectives before publishing a Preferred Option (also known as Option 7C) for public consultation in 2007.  Option 7C was an edge of centre and urban regeneration led approach that included a dwelling target of 10,080 houses for the plan period between 2006 and 2026. At that point, a total of 3,000 dwellings had been built or were in the pipeline; the focus of development was in a single strategic development area of 5,000 dwellings together with a strategic link road to serve it; and the balance of housing was located within and adjacent to the urban area and larger villages.  To balance housing growth with employment opportunities and to increase prosperity, the Preferred Option also identified a need to provide for at least 10,000 new jobs in a range of sectors and locations.

Option 7C was developed within the context of an emerging South East Plan, an adopted Kent and Medway Structure Plan and national policy that focused on the redevelopment of brownfield sites at high densities.  The Preferred Option would have superseded certain policies in the adopted Maidstone Borough-wide Local Plan (2000); the remaining policies falling away as further LDF documents were produced.  The Preferred Option was subject to public consultation and was supported by 56% of respondents to the consultation.

What the Council needs to achieve through the Core Strategy

 

The following paragraphs set the context within which the housing and employment targets and distribution of development have been considered, including the Council’s vision and objectives that are published in other documents as well as other key factors.  The tests of soundness set out in PPS12 and other national guidance have been borne in mind as the strategy has been developed, and the methodology for determining a development target/distribution pattern has included an analysis of the various development options against a number of elements, including Council aspirations for prosperity and regeneration[2] and sustainability factors.

 

The Sustainable Community Strategy

 

The Core Strategy is the spatial expression of the Sustainable Community Strategy for Maidstone Borough Council, which was adopted in 2009 and runs to 2020.  The overall vision is “We want Maidstone Borough to be a vibrant, prosperous 21st century urban and rural community at the heart of Kent, where its distinctive character is enhanced to create a safe, healthy, excellent environment with high quality education and employment where all people can realise their aspirations”.

 

This is underpinned by a range of vision related objectives which include:-

 

·  Develop a vibrant economy, create prosperity and opportunities for all;

·  To develop an efficient, sustainable, integrated transport system;

·  Make Maidstone Borough a place where people of all ages - children, young people and families - can achieve their aspirations;

·  Develop Maidstone Borough’s urban and rural communities as models for 21st Century quality and sustainable living; and

·  Retain and enhance Maidstone Borough’s distinctive history, landscape and character.

 

A number of partners from the LSP have contributed to the initial infrastructure assessments for the Core Strategy.

 

The Council’s Strategic Plan

 

The Council’s draft Strategic Plan (2011-15) has been developed with three main priorities, all of which have relevance to the Core Strategy, these include:-

 

1.  For Maidstone Borough to have a growing economy

 

·  With a range of employment and business opportunities;

·  A transport network that supports the local economy; and

·  Rising employment, catering for a range of skill sets to meet the demands of the local economy.

 

2.  For Maidstone Borough to be a decent place to live

 

·  To continue to be a clean, attractive and well designed and built environment;

·  A place where people want to live;

·  Decent, affordable housing in the right places across a range of

tenures; and

•   A clean and attractive environment for people who live in and visit the Borough.

 

3.  Corporate and Customer Excellence

 

·  We will continue to support our most vulnerable residents and seek to reduce deprivation across the Borough;

·  Residents are not disadvantaged because of where they live or who they are, vulnerable people are assisted and the level of deprivation is reduced; and

·  The Council will continue to have value for money services that residents are satisfied with.

 

Whilst the Council’s strategic priorities and strategic outcomes focus on the period to 2015, the Core Strategy will be important in taking the priorities of Maidstone Borough forward to 2026 and beyond into the 2030’s.  Particularly, the objectives of having a growing economy and being a decent place to live.

 

The Strategic Plan is also underpinned by a range of cross cutting strategies which include the Economic Development Strategy and the Housing Strategy. The Economic Development Strategy seeks to create a model 21^st century County town, and concluded that a target of 10,000 new jobs between 2006 and 2026 represented the right balance between an aspiration for growth and deliverability.

In addition there are links to several County Plans to consider and work with, including the Vision for Kent, Unlocking Kent’s Potential (regeneration strategy), and Growth Without Gridlock (transport strategy).
 

The Core Strategy Vision

 

The Core Strategy will need to contain the vision statement of how the Council sees the borough developing into the mid 2020s.  An initial draft of the vision was considered by the Local Development Document Advisory Group[3] (“LDDAG”) and amended as follows, although it has not been formally approved by the Cabinet:

 

“By 2026 Maidstone will be a vibrant, prosperous and sustainable community benefiting from an exceptional and unique urban and rural environment.

 

The Core Strategy will help in delivering sustainable growth and regeneration while protecting and enhancing the borough’s built and natural assets. Regeneration will be prioritised and delivered at the urban area of the county town first to make best use of brownfield land, so the release of greenfield sites, well related to existing urban areas, will be phased after 2016.  Development will be led by a sustainable and integrated transport strategy, together with necessary strategic and local infrastructure.

 

The establishment of a multi-functional green and blue network of open spaces, rivers and water courses will safeguard biodiversity and define the urban character of Maidstone while offering access to the countryside, which will be valued in its own right. The character and identity of all rural settlements will be maintained by directing suitable development and supporting infrastructure to the rural service centres of Harrietsham, Headcorn, Lenham, Marden and Staplehurst.

 

Employment skills will be expanded to meet an improved and varied range of local jobs, and there will be a better balanced housing market to meet the community’s needs. Development will be of high quality design, and constructed in a sustainable manner to respond to climate change and protect the environment and biodiversity.”

The vision will be refined and incorporated into the draft Core Strategy and presented to Cabinet for approval for public consultation in April 2011.  There will be a further opportunity for Members to consider the spatial vision at a joint meeting of LDDAG and Leisure & Prosperity Overview & Scrutiny committee on 21^st February 2011.

Regeneration

The Council’s aspirations for regeneration are set out in its Regeneration Statement[4].  The Statement includes objectives to address economic, social, physical decay and decline areas where market forces will not do this without support from the Council and its partners, including areas of deprivation in the town centre; and to ensure the needs of local residents and businesses drive regeneration.

The Council has also identified the need to prepare an Area Action Plan (AAP) for the Regeneration of the Town Centre[5] to follow the adoption of the Core Strategy.  This document will define urban regeneration areas in the town centre to provide a policy framework and implementation plan for the revival of the defined areas in accordance with the Core Strategy.  The Town Centre Study[6] which is part of the Core Strategy evidence base will be used to inform the AAP.

Changes since the Preferred Option 2007: the need for review

Since 2007 there have been a number of significant changes that must be considered.

Following consultation on the preferred option in 2007, the Core Strategy programme was delayed while the Council gathered a considerable amount of evidence to respond to a representation (and subsequent planning application) seeking the allocation of land for a strategic rail freight interchange.  The Council rejected the representation and the Core Strategy programme restarted in June 2009[7].  The planning application was subsequently dismissed at appeal.

Meanwhile, the revision of Planning Policy Statement 12 (2008) (creating strong safe and prosperous communities through Local Spatial Planning) and the publication of guidance on the tests of soundness by the Planning Inspectorate placed a greater emphasis on ensuring the Core Strategy is deliverable.  New plan making regulations were also introduced that led to the need for a further round of public consultation on the Core Strategy, which is the next stage for the Council prior to formal consultation at a Publication stage.

New national guidance has also been published.  PPS3: Housing (June 2010) deletes references to the national indicative minimum density of 30 dwellings per hectare and removes private residential gardens from the definition of previously developed land.  Local authorities can now set a range of densities across the plan area for residential development, rather than one broad density range.

The adoption of the Regional Spatial Strategy (South East Plan) in May 2009 imposed an increase in the housing target from 10,080 to 11,080 for Maidstone borough, and in June 2009 Cabinet agreed to proceed with developing and testing a draft Core Strategy on this basis.

 

However, on 6 July 2010 the Secretary of State attempted to revoke Regional Strategies and the imposed housing targets and stated that planning policy guidance would be defined by national and local policies only. Housing targets should be set at the local level to meet local housing need. National policy does not include a methodology for identifying housing targets; consequently there has been the opportunity for local planning authorities to develop appropriate and professionally sound methodology.

The Core Strategy programme was therefore delayed so the Council could develop a methodology for setting a local housing target.

 

The action to revoke regional strategies was subsequently challenged and, following a judicial review, the Secretary of State’s decision of the 6 July was quashed on the 10 November 2010.  Therefore for the present the South East Plan remains part of the development plan.

The revocation of regional strategies is now being pursued through the Localism Bill.  It is likely that regional strategies will be abolished when the Localism Bill is enacted in summer/autumn 2011 and therefore before Maidstone Borough Council’s Core Strategy is submitted to the Secretary of State and prior to an independent examination.  Consequently, although there is a risk that this part of the Localism Bill may be amended or fall, the government’s intention is clear and therefore it is reasonable for the Council to proceed with its Core Strategy on the assumption that the South East Plan will be revoked.

Waiting until new legislation is in place before proceeding with the Core Strategy (or a new type of local plan) is not thought appropriate because this would impact on the Council’s ability to adopt an up-to-date sustainable development planning framework and could affect its ability to demonstrate an adequate supply of housing land resulting in planning by appeal.

Since 2007, there have been changes to the economic climate and, in particular, to the market for residential development which affects the availability of money for capital investment in both the public and private sectors and, in turn, the deliverability of housing and the associated infrastructure needed to support new development.  There has already been significant change affecting the housing market as a result of the restructuring of the economy arising from the “credit crunch”, and there is significant further change on the horizon for the public sector with a reduction in resources for a considerable period ahead and consequent changes in government policy on how investment for affordable housing and supporting infrastructure will be generated.

There are also uncertainties regarding future employment growth, particularly in the light of significant reductions in public sector employment (representing 33.3% of the labour force in Maidstone at 2008).  The borough is potentially vulnerable to job losses and/or to shifts in the structure of its employment base, which may affect journey to work patterns as well as the broader issue of economic growth.  However, the Core Strategy is a long term plan that runs to 2026 so there must be a focus on positive spatial planning policies to support the achievement of the Council’s vision and objectives and to ensure that land use planning does not obstruct the accomplishment of targets over the next 15 years.

The changes in how new development and supporting infrastructure can be funded, coupled with the fact that development that has been built or received planning consent since 2006 cannot contribute towards new infrastructure, casts doubt on the delivery of the 2007 Preferred Option.  Dwelling completions and consents have risen from 3,000 units in 2007 to 5,800 in 2010 and there is further potential for 1,770 units comprising identified brownfield sites and a windfall allowance, leaving (after building in contingency) the need to find greenfield land for 3,230 units.  By contrast, greenfield sites for 7,000 dwellings were required in 2007: 5,000 dwellings were to be focused in a single development area supported by a strategic link road, the balance of 2,000 units distributed around the urban area and at the larger villages.  Development in a strategic development area would not commence until the latter part of the Core Strategy and, given expected build rates, only about 2,600 homes could now be built to 2026 (as opposed to 5,000 previously).

Consequently, within the context of the total need for infrastructure to support new housing, employment and other development as identified through the emerging Infrastructure Delivery Plan, a strategic link road of an acceptable design (alignment and length) could not be paid for by tariff contributions, the New Homes Bonus and committed 106 Agreements by 2026.  In order to advance the road scheme, there would be a need for an agency such as the Borough Council to ‘bank roll’ the project – paying in advance for the road and hoping to recoup the funding over a period up to and beyond 2026. This would represent a high risk for the Borough Council during a period of financial restraint and is therefore not thought appropriate.

Additionally, initial survey material emerging from work being undertaken on the Maidstone Landscape Character Assessment and the Kent Habitat Survey indicates that a single large strategic development area to the south east of the urban area would have a negative impact upon the historic and wildlife-rich landscape persisting in this vicinity.  Both reports will be published in the first half of 2011.

When the Core Strategy programme restarted in 2009, a potential risk of a dip in the Council’s rolling 5-year housing land supply was identified whereby the majority of known brownfield sites could be completed before greenfield sites came on stream.  Housing land supply data (2009/10) demonstrates this is no longer the case, so there is no requirement to consider allocating strategic housing sites in the Core Strategy, only to identify strategic development locations.  Land allocations will be made in subsequent LDF documents in accordance with an adopted Core Strategy.

 

Still mindful of the need to balance housing and employment, the Council has therefore developed a new approach to setting a local housing target and development distribution in the Core Strategy that is evidence based, reflects the community and borough priorities and takes into account a wide range of factors.

Other Key Factors

 

There have also been several other key factors that have particularly shaped the initial thinking on the Core Strategy and its housing and employment development strategy and these are highlighted below:-

 

·  The background evidence base has had to be updated; it has also been expanded and includes updated local resident population and workforce estimates and projections.

 

·  The Council has continued to support housing in recent years with investment through the capital programme and being proactive in working with developers, the Housing Corporation and more recently the Homes and Communities Agency. As a result the level of housing completions has been higher than originally expected between 2006 and 2010 (the vast majority on urban brownfield redevelopment sites) and when combined with consents to 2015 this totals 5,800 dwellings.

 

·  The Strategic Housing Market Assessment identified a need for 1,081 affordable homes per annum over 5 years; addressing an acute need of 340 affordable homes per annum would require a total annual build rate of 850 dwellings under current affordable housing policy (which seeks 40% affordable housing on all sites of 15 units or above or 0.5ha or greater).  The imposed target of 11,080 can only deliver a total of 554 dwellings p.a.; and a 10,080 target 504 dwellings p.a.  Local needs housing in rural areas and the right size, type and tenure of dwellings are important factors too.

 

·  The Strategic Housing Land Availability Assessment (SHLAA) assembled a list of housing sites offered by developers and land owners.  These sites have been evaluated and, as a consequence, a number of sites have been rejected because of their adverse impact on the environment.  The SHLAA identifies a potential land supply of accepted sites that could accommodate about 10,700 dwellings within the plan period to 2026 (additional to known sites on frozen land allocations, or in the development pipeline).  Those sites that were accepted after the initial filtering process will require further assessment and not all will ultimately be suitable for development.

·  The recession has had a major impact on development in the short to medium term, particularly in funding new development and infrastructure; and changes in the public and private finances at both a national and regional level will put pressure on the infrastructure funding. Although new funding instruments are emerging it has been assessed that to provide the required quality of a strategic link road within the lifetime of this Core Strategy is not going to be possible; although this may be a key element for any future strategy, and the Leeds/Langley bypass remains an outstanding County highway scheme.  Since a strategic link road to serve new development formed part of the 2007 Preferred Option approach (for 5,000 dwellings), this option is no longer deliverable and is therefore not sound.

 

In conclusion, the Council is likely to be one of the first authorities to produce a Core Strategy and set a housing target in this transition period. The Council’s proposals will be subject to consultation and an independent public inquiry but it is unlikely that there will be any prescriptive guidance from government on developing the Core Strategy or targets. There will continue to be a requirement that it be based on robust evidence and a sound methodology.

The Methodology for determining a Local Housing Target and Distribution for Development

 

Significant work has been undertaken to identify the important factors in determining the housing target and distribution in the borough. This was initially based on several key factors that were identified with Members in June 2010. These were used as a starting point for developing the model and were as follows:-

 

·  Meeting Housing Need;

·  Prosperity;

·  Housing Figures and Trends;

·  Past Policy Targets;

·  Commitments and Completions;

·  Environmental Capacity;

·  Land Availability;

·  Infrastructure Capacity (including transportation);

·  Place Making;

·  Sustainability;

·  Risks; and

·  Localism.

These were further refined into factors, objectives and reality checks, and are summarised in the flow diagram illustrating the methodology in Appendix A to the report of the Director of Change, Planning and the Environment.

The core strategy must be accompanied by a sustainability appraisal, to consider the impact of policies on the economy, the community and the environment.  The Sustainability Appraisal Scoping Report (2009)[8] established a framework for assessing Maidstone's Core Strategy policies, so the council has been able to minimise the adverse impacts from the strategy and maximise the positive impacts.

 

The key factors set out above have been checked against the objectives of the Scoping Report and have been assessed as a reasonable match, so the sustainability appraisal of options has been built into the process.  The Scoping Report must be been borne in mind when developing the strategy and policies for the Development Plan Document.  An interim sustainability appraisal will support the public consultation version of the Core Strategy and a full sustainability appraisal will accompany the Publication version.

 

An informal Core Strategy Working Group was also established which included the Leader, Leader of the Opposition, spokespersons from the Planning Committee, the Chairman of the Local Development Document Advisory Group and the Chairman of the Leisure and Prosperity Overview and Scrutiny Committee. As a result of detailed discussions 30 detailed themes (or elements) were identified.

 

These 30 themes were then used to explore some of the key issues further and try and develop an approach that considered all the themes at once.  A further Members’ workshop was held on 25 October 2010, with 38 out of the 55 Council Members taking part in the prioritisation process.  The results of this exercise are set out in Appendix B to the report of the Director of Change, Planning and the Environment.

 

Members received a number of short presentations from senior officers who gave their professional perspectives on some of the implications of the various options. All elements received between 4 and 25 votes and Members’ top 5 priorities in determining a local housing target were:

·  Physical and social regeneration of the urban area;

·  Attracting investment in higher and further education/training;

·  Delivering additional transport infrastructure;

·  Expanding the roles of the rural service centres; and

·  Priority given to impact on water resources.

 

The reasoning behind the prioritisations have been collated, will remain non-attributable but will be included as part of the supporting evidence for the final consultation document.

Options Appraisal

 

The key drivers that have influenced the development of Maidstone borough’s housing target for the period 2006 to 2026 at various points are summarised in Appendix D to the report of the Director of Change, Planning and the Environment.  This table demonstrates the chronological steps the Council has taken to reach its preferred development option.  Following the Cabinet decision on 29^th September 2010 to test a number of development scenarios, steps 7 to 11 of Appendix D of the report of the Director of Change, Planning and the Environment have been undertaken in accordance with the process for identifying a development target, as set out in Appendix A to the report of the Director of Change, Planning and the Environment.

 

On 29 September 2010, the Cabinet agreed five spatial options for testing purposes, this followed discussion at an informal member workshop in August which was attended by 33 Members (60%), Overview and Scrutiny and the Local Development Document Advisory Group, these options were:

 

·  8,200 dwellings with a dispersed pattern;

·  10,080 dwellings with a dispersed pattern;

·  10,080 dwellings including a strategic development area;

·  11,000 dwellings with a dispersed pattern; and

·  11,000 dwellings including a strategic development area

 

It is important to stress that after adding a contingency allowance for sites that will not ultimately be built, taking account of dwellings already built since the base date of the Core Strategy (2006), and deducting a sum for dwellings with outstanding planning permission, there will only be a balance to find for the remainder of the plan period. Then, after deducting identified urban brownfield potential and building in a windfall allowance for unidentified sites, this figure is reduced further.

The accompanying report highlighted that the authority was developing a totally new approach and that this may have to be refined or other options may emerge as there was now no prescription from central government over the target setting. 

 

Lead officers from a number of Council departments have been involved in developing the approach to the Core Strategy and working with Members to assess each of the 30 key elements and patterns of development.  Officers considered groups of elements according to their expertise, and commented on the relative strengths and weaknesses of each of the five options. When the comments were collated it became clear that for a number of reasons the dispersed model was too dispersed and the strategic development area was too centralised – as well as having serious concerns over the associated infrastructure requirements for the various options, particularly the viability of the road network.

Initial calculations revealed that the cost of infrastructure required to support an option of 8,200 dwellings in a dispersed pattern was considerably in excess of the funds that could be secured through development, so there is a very high risk that this option could not be delivered.  Furthermore, this option did not support the Council’s objectives and aspirations.  Development could most likely fund the remaining four options, together with transportation measures, but could not finance an appropriate quality of strategic link road.

The remaining four options had contrasting strengths due to the broad differences in the development distribution patterns. Some options better met the housing need and prosperity aspirations of the Council while others minimised the impact of development on environmental and ecological capacity.  Certain options were better at delivering infrastructure and place making, while others built more flexibility and choice into the Plan or better balanced urban and rural development.

Consequently, the development distribution pattern recommended for public consultation (set out in Appendix C of the report of the Director of Change, Planning and the Environment) sought to balance these strengths.  This was achieved through a technical evaluation by officers and by local knowledge input from Members; and by ensuring the strategy is affordable and deliverable.  It takes account of the demand for new and affordable housing, the availability of suitable development sites, and the need for new infrastructure required to support new development.

A target of 10,080 dwellings was recommended as the optimal target. 

The Council has commissioned updated demographic and labour supply forecasts[9].  The study concludes that, to meet the needs of the borough’s existing population between 2006 and 2026, at least 7,900 new dwellings will be required.  Additional provision above this figure implies continuing net in-migration.  If the Council aimed to meet all affordable housing need identified in the Strategic Housing Market within a 5-year period (at 1,081 units p.a.), it would be necessary to set a target of 19,300 dwellings.  A balance must be struck.

The 10,080 dwelling target was originally derived from regional planning guidance (RPG9), with a 20% increase to qualify for new growth point funding.  In submitting its bid, the Council’s technical research included a number of studies on the local economy and employment, inward investment, housing needs and urban capacity, as well as the High Street Ward feasibility study.  The bid explained that an increased target of 10,080 dwellings from 2006 to 2026, as opposed to a draft regional strategy target of 8,200 dwellings, would represent a modest increase of 94 dwellings p.a.  Given the borough’s known housing supply, together with potential identified through the urban capacity study, the Council was confident it could meet this challenge provided growth point infrastructure investment was available to free up the operation of the town and to support urban renaissance.

The 10,080 dwelling target was appraised against the following criteria: the need for affordable housing, synergy with the Kent growth areas, the achievement of sustainable development, the focus of new development at the existing urban area, supporting transport infrastructure, impact of development on the environment, and the impact on water supply and flooding.  This target was supported by SEERA and the Secretary of State, and by Maidstone Borough Council prior to an additional 1,000 dwellings being imposed through the South East Plan. 

The South East Plan examination Panel agreed a 10,080 dwelling target for Maidstone borough.  The Secretary of State’s justification for applying an additional 1,000 dwellings was that, as a regional hub and growth point, the borough had a need and the capacity to accommodate more housing, and that a 10,080 target did not adequately meet the need and demand for housing.  The Secretary of State considered this view to be supported by substantially higher levels of completions achieved in recent years and the significantly high housing trajectory for the borough.  The Council challenged the increased target, referring to evidence submitted as part of the growth point bid that supported a target of 10,080 dwellings for the plan period.  The Council highlighted the borough’s water supply constraints and a lack of evidence to support assertions of local need/demand.  The high levels of dwelling completions at that time reflected unique opportunities for large urban redevelopment sites built at the height of the economic cycle that could not be sustained.  The Council also refuted the statement that its housing trajectory was high – the 20-year target to 2026 would only be exceeded by 18 units at that time.  Full details are set out in the report to Cabinet of 8^th October 2008[10].

Since 2008, the Council has produced further evidence that impacts on development capacity for the borough, including the Strategic Housing Land Availability Assessment, Water Cycle Strategy, and studies on population, employment, retail and the town centre.  The high levels of dwelling completions have not been sustained[11] and the latest available housing trajectory does not demonstrate a surplus of housing land[12].

Unlike the higher target tested, 10,080 dwellings can be delivered without relying on SHLAA sites that are difficult to develop.  Initial findings are that the infrastructure required to deliver 10,080 dwellings with this distribution model can be funded and, at this point, there is no compelling evidence to suggest a move away from this target.

After accounting for completed and known dwelling supply, there is a balance to find of 5,010 dwellings for the remainder of the Plan period; and after deducting identified urban brownfield potential and building in a windfall allowance for unidentified sites, subsequent land allocation documents will need to allocate greenfield sites in accordance with the strategy to accommodate an additional 3,230 dwellings to 2026.

In broad terms, the balance of a housing development target of 10,080 units (3,230 units) is distributed at a number of greenfield development locations adjacent to the urban area and at the rural service centres.

Using a target of 10,080 dwellings, the Council has 6.4 years of housing land supply (including non-implemented planning consents and saved brownfield local plan allocations; but excluding frozen greenfield allocations, identified potential in the Strategic Housing Land Availability Assessment and windfall sites).  The current land supply largely comprises brownfield sites and, given the lead in time to develop sites allocated in land allocation documents that follow the Core Strategy, the plan making process is likely to result in the development of greenfield sites from around 2015/16, therefore naturally phasing the development of brownfield sites first.  Previously developed land will continue to materialise throughout the plan period but the high percentage of brownfield development experienced in the recent past will not be able to be sustained.

The Methodology for determining a Local Employment Target and Distribution for Development

Whilst the Council has focused on the methodology for determining a local housing target and the distribution of development, equally important are other land uses, including employment.

In contrast to the need to establish a new method of setting a local housing target in-house, there are tried and tested methodologies for undertaking employment land reviews.  The consultants who published the Employment Land Review (2009) set out in detail the forecasting methodology used.

The Economic Development Strategy seeks to achieve reduced out-commuting; increased economic activity, town centre office activity and employment density; creation of 10,000 new jobs; and a focus on high quality jobs.  Research undertaken demonstrates a link between the number of homes built and the number of jobs created: the more homes developed, the greater the labour supply.

The Employment Land Review (2009) identifies a number of assumptions that will need to be met in addition to overall development targets and distribution, including a shift in the balance of business class and non-business class employment, and increased employment in “knowledge based” activities.  Both these factors need to be achieved in order to broaden the range of employment available which, in turn, should assist in improving the level of self-containment (i.e. those living and working in the borough, reducing out-commuting from around 38% to 20%), and increasing economic activity and employment density (as well as increasing the amount of office activity in the town centre).

A large proportion of employment in the borough is currently public sector based, so changes in the economy and reduced central government funding mean that the Council will need to provide attractive opportunities for private sector development if a 10,000 jobs target is to be achieved.

Based on a high growth scenario to meet Council aspirations for employment growth, the Employment Land Review (2009) identifies a need for approximately 30.3 ha of land for employment use.  Office development will be directed to the town centre and, taking into account existing stock, vacant floorspace and planned development, the balance of new employment land required (excluding offices and retail) for the period 2011 to 2026 is 17.05ha.  New employment land is only one element of labour supply that will assist in achieving the Council’s target of 10,000 jobs.  A number of jobs will already have been provided in Maidstone since the base date of the plan, and there will be an additional yield from new office, retail, tourism and leisure development, as well as contributions from the education and health sectors.  Furthermore, balancing qualitative and quantitative employment and residential land will assist in reducing out-commuting thus adding to the borough’s labour supply.

 

It was recommended that the requirement for additional economic development (excluding offices and retail) be located at junction 8 of the M20 motorway.  The Employment Land Review identifies demand for new employment uses (excluding retail and offices) that require good access to motorways and A-roads.  An assessment of junctions 6 and 7 of the M20 motorway demonstrates that capacity at these junctions is constrained and the availability of development land is restricted for this type of use.  Junction 8 has capacity and the available land that would allow this employment use to come forward.  A large site offers the opportunity to create a strategic employment site with the benefit of being a high profile site in Kent, and would aid viability in terms of servicing costs and quality landscaping.  A critical mass of employment land together with additional good quality local and strategic landscaping and open space in this vicinity can deliver the infrastructure required to support 11ha of employment (excluding retail and offices). 

To offer choice and flexibility of sites, smaller opportunities for employment growth are identified around the urban fringe and at rural service centres.  Further potential employment sites may come forward as a result of public consultation on the Core Strategy.

At this time of economic recession there should be no intention to phase the development of business sites.  There is an intention to balance housing and employment opportunities, so it would be inappropriate to restrict the supply of employment or housing sites beyond that implied in the plan making process.

 

However, the Cabinet felt that development around Junction 8 would not be sustainable and is not in line with the core strategy which is to look at business and housing development in close proximity with each other.  Therefore, the Cabinet agreed to not set the employment target at this time and asked Officers to update employment data and to look for alternative potential employment sites that can support a dispersed pattern of development, better suited to the housing locations and report back to the Cabinet Meeting in April when the draft Core Strategy will be considered for public consultation.

Balancing Housing and Employment

The recommended distribution of housing and employment development at Appendix C of the report of the Director of Change, Planning and the Environment balances the need to achieve prosperity and regeneration and to meet housing need with minimising the impact of development on the environment.  The optimal development strategy also addresses concerns that a single strategic development area would overwhelm and engulf historic settlements located to the south east of the urban area.  The strategy will maintain the unique pattern of Maidstone’s urban area, giving residents access to the countryside.  There is an adequate number of suitable SHLAA sites to demonstrate delivery of the strategy without the need to release highly constrained or environmentally sensitive sites.

Information supplied by the infrastructure providers, together with the results of transport modelling, indicate the strategy can be delivered, and this data will be refined through the Infrastructure Delivery Plan that will accompany the Core Strategy throughout its consultation stages.  The infrastructure delivery planprovides an overview of where and when the strategic and local infrastructure that is required to support new development will be provided, and who will deliver and fund it.  A report to explain the progress of the infrastructure delivery plan will be presented to Members at a joint LDDAG/Leisure and Prosperity Overview and Scrutiny committee meeting on 21^st February 2011.  Although the data that supports this option will require some finishing touches before publishing the Core Strategy for public consultation, the information gathered to date is sufficient to demonstrate that the optimal strategy is deliverable.

Demographic and labour supply forecasts demonstrate that none of the three housing scenarios (8,200, 10,080 or 11,000) would generate enough resident labour supply to meet a target of 10,000 jobs.  Nevertheless, the study concludes that there is potential for Maidstone borough to claw back a proportion of residents who commute to London thus providing additional local labour, although this is dependent on providing the right type of jobs.  The provision of qualitative jobs to reduce out-commuting must be part of the Council’s strategy to provide the right balance of employment opportunities with new housing development.

From the analysis of options, the distribution pattern of housing development (set out in Appendix C of the report of the Director of Change, Planning and the Environment ) makes best use of existing transport infrastructure capacity (road and rail) along the A20/M20 corridor; and sewerage capacity to the northwest of the urban area and at the rural service centres.

Following consultation with the parish councils[13], the distribution pattern supports the need for some development at the rural service centres where there is sufficient infrastructure capacity.

The recommended housing development strategy achieves flexibility in the Plan by spreading the risk of sites not being developed across a number of development clusters rather than in a single location.

This approach could be further refined following public consultation and prior to the next round of formal public consultation on the Publication version of the Core Strategy.

 

The Core Strategy Preferred Option 2011

 

The assessment of evidence supports a housing target of 10,080 dwellings to meet locally arising need and wider planning objectives, as well as an employment target of 30.3ha.

 

The draft distribution strategy seeks to blend the best elements from each of the five options that were considered and is set out in the diagram at Appendix C of the report of the Director of Change, Planning and the Environment.  In setting out this draft distribution, figures have also been included for the development to date in each of the locations to provide the most complete picture.  As highlighted previously, the numbers and locations are only for illustrative purposes at this stage; at all general locations options exist for the delivery of these numbers and the decisions made subsequently on site allocations will determine which sites are suitable for allocation for development.

Furthermore, a master planning approach will be followed and development briefs required for all major land allocations (including significant groups of sites) that are adopted through subsequent land allocation development plan documents.

 

The appraisal of various development scenarios was sufficient to have recommended a preferred dwelling and employment target and distribution pattern to take forward in the draft Core Strategy for public consultation, although the Cabinet agreed to defer the decision on an employment target.  Further refinement of the analysis will be completed before the Core Strategy is presented to Cabinet in April.  The report of the Director of Change, Planning and the Environment focused on setting housing and employment targets and development distribution for the borough.  The April report will draw together all other aspects of the spatial plan, including employment, green infrastructure and open space, regeneration, retail, a transport strategy, infrastructure delivery, and water management.

 

In arriving at this optimal position on the housing and employment targets and the distribution of development, there were a number of critical factors that were taken into account and these are set out below:-

 

·  Maximising the use of existing infrastructure ;

·  A focus on physical and social regeneration of brownfield sites and Maidstone urban area (including the town centre) first;

·  Additional development to the rural service centres to accommodate new housing (including affordable);

·  Deliverability (the range and choice of development locations and deliverable infrastructure);

·  Continuing economic prosperity and attracting investment in higher and further education/training ;

·  Balancing housing and employment opportunities;

·  Protecting the best landscape and habitats, and minimising the impact on the landscape and habitats;

·  Meeting locally arising need; and

·  Ensuring a good supply of housing that is affordable rather than just social housing and widely distributed by location, type and tenure.

 

The picture of the total number of dwellings that will be completed throughout the plan period is of an urban/rural split of approximately 79% to 21%.  In accordance with national policy and acknowledging the roles of the rural service centres, the Council’s strategy will be to regenerate the urban area (including the town centre) by developing known brownfield sites in the early part of the plan period before greenfield sites are ultimately allocated and developed together with currently unidentified brownfield sites in the latter half.

 

Localism and the views of stakeholders and residents

 

Whilst any housing and employment target and development distribution pattern must be supported by sound evidence, the views of residents and businesses are also very important.  Public consultation on the Core Strategy will be one means of engaging the public in the preparation of the document, and this builds on recent exercises to draw together local views through the production of various documents, such as the Sustainable Community Strategy, the Strategic Plan, the Economic Development Strategy, and other documents that comprise the Core Strategy evidence base.

 

It is anticipated that some of the issues for residents may include:-

 

·  How the potential for congestion is going to be addressed;

·  The availability of school places;

·  The provision of affordable homes;

·  The potential impact on local communities;

·  Providing adequate infrastructure for new development;

·  The protection of landscape and wildlife and provision of open space;

·  The variety of housing and provision for the elderly; and

·  How the employment opportunities may affect them.

 

These issues have been considered when developing a local dwelling target and the distribution pattern of new housing.  A range of ways will be used to obtain the resident and stakeholder views and these will be set out in further detail in the consultation document.

Service providers have also contributed to the testing of the development options, and Members (as the elected representatives of the public) have input to the process through the informal workshops and formal decision making processes.

Given the implications of each option for the long term costs and delivery of County services, discussions have also been held with Kent County Council.  The County supports a dwelling target of 10,080 over 20 years, but it has strong reservations about a commitment to a major urban extension for a number of reasons:

·  The uncertainty whether new employment, shopping and other facilities, combined with transport measures, would achieve the necessary reduction in car journeys;

·  The unclear consequences for transport congestion and investment of the completed development, post 2026;

·  The substantial impacts of traffic on roads in the surrounding area for which mitigation measures have not been resolved; and

·  The greater costs for school and community provision.

 

The uncertainty for funding transport and other investment in KCC services from developer contributions or other sources is also a concern and the Council will continue to work closely with the County Council particularly on the transport issues and the measures that will be required.

A further Members workshop to discuss the draft development strategy was held on 6^th January 2011 to consider the evolution of the draft strategy option and the analysis to date.

 

The feedback from the 23 members attending was generally supportive and came mainly in the form of questions of how the Core Strategy documents would ensure a number of matters were addressed, notably:

 

·  How will regeneration/renewal of the urban area be achieved/ensure brownfield comes forward first;

·  Rural affordable housing –the optimal option gives opportunity for more housing at RSCs than the original options;

·  Transport/air quality implications on some of the major roads need to be addressed

·  Further questioning of Southern Water re Marden/Headcorn;

·  The need to consider employment allocations at Harrietsham/ Headcorn/ Lenham to combine this with housing

·  The development of effective policies to deliver enhancement and protection of identified biodiversity opportunity areas within the borough.

 

Assessment against the Tests of Soundness

The following section looks at the tests of soundness in further detail and how the Council has used these to ensure that both the new methodology for identifying a proposed housing target, setting an employment target, and the Core Strategy as a whole meet the required standards.  The draft Core Strategy must meet the tests of soundness. This will be assessed by an independent Inspector appointed by the Secretary of State.

 

To be “sound” a core strategy should be justified, effective and consistent with national policy.

 

“Justified” means that the strategy must be:

 

•   founded on a robust and credible evidence base; and

•   the most appropriate strategy when considered against the reasonable alternatives

 

“Effective” means that the document must be:

 

•   deliverable;

•   flexible; and

•   able to be monitored

 

In terms of looking at each of these elements the Council has sought to bring together a range of perspectives, in doing so this does not lead to a perfect proposal but one in which a wide range of priorities are balanced and an optimum solution reached. Although these tests of soundness may alter in the future, the principles have been viewed as a useful starting point. Each of the elements is taken individually in the sections below.

 

A robust and credible evidence base

 

The Council has drawn on a range of evidence and analysis. This has included at a strategic level considering a range of data from housing, economic development, regeneration, development management and spatial policy. In terms of information on the borough itself population estimates and projections, transport data and scenario modelling, infrastructure provider information as well as drawing on data that has been provided through recent land assessments. 

 

However, at this stage there is still further information to gather through public consultation and for example the Strategic Housing Land Availability Assessment will also be refreshed prior to production of the Land Allocations Development Plan Document.  However this need not delay the process because the Core Strategy is setting the higher tier policy framework for the LDF - the policy detail will be set out in other LDF documents (DPD/AAP/SPD) that follow the Core Strategy.

Comparing reasonable alternatives

 

A range of alternatives have been considered and these have included the overall number of houses to be built and the pattern of dispersal. A range of information was used to look at the planned number of houses; this included previous trends, government submissions and existing Council strategies. After discussion with officers and members these were whittled down to three levels, 8,200, 10,080 and 11,000[14]. 

 

In terms of the dispersal factors this was based on previous patterns that had been considered, namely a widely dispersed model making use of a range of previously identified sites across the borough and a further scenario based on a strategic development area (urban extension) being partly developed to 2,300 in the Plan period with the remainder of housing to be dispersed.

 

These combinations provided for 6 possible alternatives, although, following discussion with Members, the 8,200 dispersed was ruled out as given the level of development already and the required infrastructure this was not a viable option.

Each alternative housing option involved an assessment of land that could potentially provide for new employment.

 

Deliverability

 

In considering the deliverability of the Core Strategy recommendations the Council has looked in particular at trends over the last nineteen years by way of trend analysis. The link between housing and employment has also been tested to ensure the housing and employment targets and development distribution can be delivered but, as highlighted previously, this strategy encompasses many factors, including green infrastructure and open space, protection of the environment, retail development and the provision of supporting infrastructure.

 

There is no presumption that the Strategic Housing Land Availability Assessment sites (or any other sites) used for testing and modelling the development scenarios will ultimately be allocated for development in the Local Development Framework documents; the purpose of the Strategic Housing Land Availability Assessment is to confirm that there is an adequate supply of sites from which to make allocations in accordance with the development strategy set by the Core Strategy.  The Strategic Housing Land Availability Assessment will be refreshed through a new “call for sites” exercise before the Land Allocations Development Plan Document or other planning allocation documents prepared under any new regulatory regime are produced.

 

What neighbouring boroughs are proposing for housing development has also been a key factor in determining the housing distribution pattern along with a desire to make the most of existing brownfield sites before greenfield sites are developed.

 

A good working relationship has been established with the various infrastructure providers which has also enabled the additional costs associated with various scenarios to be tested.  Albeit further refinement work will be required once the outline for the consultation has been agreed.

Flexibility

 

In addition the Council has sought to identify development sites at various locations wherever possible. This has enabled the deliverability to be tested but also retained some flexibility. The distribution will also provide some flexibility for the localism agenda where sites can be brought forward by the community under new provisions in the Localism Bill.

It is crucial for the Council to demonstrate a deliverable and flexible Plan in the current downturn of the housing market and the reduction in investment available for new development and infrastructure.

Ability to monitor

 

The Council has robust monitoring arrangements in place and has previously been rated as an Excellent Authority under the Comprehensive Performance Assessment and scored a top marks on the Use of Resources Assessment as well as Data Quality. The authority is not complacent but hopefully this provides an indication of the overall approach to monitoring in the organisation.

 

In this specific area the Council’s Annual Monitoring Report monitors a range of national and local indicators, including the delivery of housing and employment targets.  The Core Strategy will contain appropriate indicators to monitor policies through the Annual Monitoring Report and other Council documents and strategies. 

 

These areas were only briefly covered in the report of the Director of Change, Planning and the Environment but will be expanded in the consultation document.

Consistent with national policy

The Core Strategy and its policies must accord with government planning policy guidelines set out in national Planning Policy Statements (PPS) and Planning Policy Guidance (PPG).  Otherwise the Core Strategy will be found unsound at Examination.  The proposed development strategy accords with the national planning policy framework. The Core Strategy will include frequent cross references to national guidance and policy to demonstrate that its local policies are also in conformity with national policy requirements.

Conclusions

Five development scenarios have been tested, however, one of the key observations was that future development cannot fund the necessary infrastructure to deliver an option of 8,200 dwellings and this option also does not meet the Council’s vision for the borough.

Following stakeholder consultations and Member/officer discussions and workshops, the remaining four options have been refined to produce an optimal strategy for delivering a 10,080 dwelling target and a 22.5ha employment target.  The distribution of new housing and employment land is illustrated on the map attached to Appendix C of the report of the Director of Change, Planning and the Environment.  This approach will underpin the draft Core Strategy that will be prepared for the next round of public consultation in spring (prior to a final Publication consultation stage in the autumn).

 

The Core Strategy Programme

The approach taken in preparing the report of the Director of Change, Planning and the Environment has differed somewhat from previously. All the previous reports were initially considered by the Local Development Document Advisory Group (LDDAG), and sometimes Overview and Scrutiny, to offer advice and to make recommendations to Cabinet or Leader of the Council as the portfolio holder with responsibility for the Local Development Framework. 

 

This approach has been adapted for this stage of plan making and instead has been considered informally by a cross-party group of Members that comprise the Core Strategy Members Working Group (CSMWG).

 

This approach has proved to be expedient and sound.  However, it is agreed that a presentation be made to both the Local Development Document Advisory Group and Overview and Scrutiny in advance of the draft Core Strategy going out for public consultation.

The recommended programme for each stage of the Core Strategy is set out below:-

Core Strategy Stage	Dates
Joint Local Development Document Advisory Group and Leisure and Prosperity Overview and Scrutiny Committee	21st February 2011
Cabinet approval of draft Core Strategy	13th April 2011
Public consultation ( 6 weeks)	28th April to 17th June 2011
Cabinet approval of Publication version	10th August 2011
Publication consultation (6 weeks)	26th August to 10th October
Council approval of Submission version	14th December 2011
Submission	December 2011
Examination	April 2012
Receipt of Inspector’s Report	July 2012
Council adoption of Core Strategy	September 2012

 

 

The housing target of 10,080 dwellings has been assessed against two alternatives (8,200 and 11,000), weighted and compared. Five development scenarios in all were tested and the delivery of employment land was appraised alongside these tests.  A further draft development distribution strategy has been evolved, which meets the Council’s objectives and takes account of stakeholder participation.

Cabinet could decide to put forward one of the other scenarios for consultation. However, at this stage the option set out above is agreed for the first phase of public consultation.  An alternative distribution of development may be considered following the consultation process.