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Decision details
Core Strategy Public Participation: Key Issues and Responses
Decision Maker: Cabinet.
Decision status: Recommendations Approved
Is Key decision?: Yes
Is subject to call in?: Yes
Purpose:
To consider the key issues arising from the representations made during public partcipation consultation on the draft Core Strategy, together with the Officers responses
Decision:
1. That, without prejudice to consideration of all representations prior to the approval of the Core Strategy for the next round of public consultation planned for December 2012 (regulation 19[1]), and the key issues arising from the 2011 public participation consultation on the draft Core Strategy, the officers’ responses be noted, and the following be agreed:
i)
Replace the 10,000 jobs target set out in policy CS1
with a specific employment floorspace
requirement expressed in square metres;
ii)
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;
iii)
Retain junction 7 of the M20 motorway as a medical
campus, and allocate land for development in the Core Strategy in
conjunction with the adjacent redevelopment of Newnham Court Shopping Village, to be guided by an
approved development brief;
iv)
Retain the housing target of 10,080 dwellings in a
dispersed pattern of development;
v)
Retain the two strategic housing development
locations to the north west and south east of the urban area, and
allocate land for development in the Core Strategy to be guided by
development briefs;
vi)
Update Maidstone’s 5-year housing land supply
and housing trajectory to a base date of 1 April 2012, and engage
with the development industry to achieve consensus over the methods
of calculating elements of land supply, including a 5% contingency
allowance;
vii)
Include housing targets in policy CS1 for each of
the rural service centres in accordance with those set out in the
Cabinet report of 9 February 2011, reproduced at paragraph 1.5.22
of the report of the Director of Change, Planning, and the
Environment;
viii)
Include reference to the early release of a
proportion of suitable greenfield sites
at the rural service centres in the Core Strategy in advance of the
adoption of the Development Delivery Local Plan where supported by
evidence of need;
ix)
Note that work is being undertaken on the viability
of Core Strategy policies, including affordable housing, and that a
subsequent report on this issue will be presented to
Cabinet;
x)
Retain the five rural service centres of
Harrietsham, Headcorn, Lenham, Marden and Staplehurst;
xi)
Note that the draft Integrated Transport Strategy,
which is the subject of a separate report attached to the agenda,
addresses the issues relating to improvements to highways and
public transport raised by respondents;
xii)
Rename green wedges as green and blue corridors,
transfer references to corridors in policy CS3 to policy CS1, and
amend the green wedges notations on the key diagram;
xiii) Reword the Gypsy and Traveller accommodation policy (CS12) to provide clarity and to include a landscaping criterion; and
xiv) That the work that is ongoing to provide for a suitable public site(s) for Gypsy and Traveller accommodation be noted
.
Reasons for the decision:
The
Core Strategy Local Plan is the key document of the local planning
policy framework. It sets out the
Council’s spatial vision and objectives over a 20 year period
from 2006 to 2026, and it contains a number of spatial policies
that explain how much development will be provided over the plan
period, where this will be located and (equally important) where it
will be resisted. The Core Strategy
also contains a number of core policies that focus on delivering
the strategy and setting criteria against which development
applications can be determined.
The
public participation consultation on the draft Core Strategy
commenced on 2 September 2011 and ran for 6 weeks. This stage in the plan making process was formerly
known as regulation 25 consultation, but it equates to regulation
18 under new legislation[1].
The consultation was widely publicised through advertisement, the
website, leaflet drops to householders and a newsletter to all
those listed on the Council’s local plans
database. A number of events were
organised, including roadshows at key
locations across the borough and a permanently staffed exhibition
at the Town Hall throughout the consultation period. Presentations were made to all parish
councils, the business community, and hard-to-reach resident
groups.
A total
of 585 individuals and organisations responded to the consultation,
submitting nearly 2,800 comments, which is a reflection of the
success of the consultation. A
breakdown of the 585 respondents is set out below.
· 436 members of the public (74%)
· 75 from the development industry (13%)
· 27 from parish councils (5%)
· 27 other organisations (such as Kent Wildlife Trust, Arriva, Southern Water) (5%)
· 17 Maidstone Borough Councillors (3%)
· Kent County Council
· Tonbridge & Malling Borough Council
·
Medway Council.
Since
the initial consultation the Council has spent a considerable
amount of time investigating and reviewing the issues that arose
from the representations, including the production of new evidence
and re-engagement with some of the stakeholders and infrastructure
providers, in order to fully respond to the comments made and to
provide a robust evidence base.
Legislative changes have also taken place including the government
publishing the National Planning Policy Framework (NPPF) and
Planning Policy for Traveller Sites in March 2012. This caused
further delay to the programme while the impacts of new national
policies on the Core Strategy were assessed.
The key
issues raised by these representations are the background to this
decision. In moving forward, it is
vital that any significant changes to the strategy are agreed by
Cabinet. A further report will be
presented to Cabinet later this year, which will include a summary
schedule of all of the representations made during the public
participation consultation on the Core Strategy last autumn
(including minor proposals) as well as representations submitted
during the public consultation on strategic housing and employment
sites to be undertaken this summer. The
schedule will summarise the individual comments received, together
with officers’ responses and recommendations for
each.
The
full schedule of representations and recommended responses has not
been completed at this point due to the Cabinet decision on 16 May
2012 to undertake public consultation on strategic housing and
employment site allocations, which resulted in amendments to the
Core Strategy work programme. Cabinet
is requested to give preliminary consideration to the key issues
together with officers’ responses set out below, but without
prejudice to Cabinet’s final decisions on the Core Strategy
that will be made in November 2012.
Cabinet will then be able to review all of the representations and
officer recommendations in advance of preparing for public
consultation on the Core Strategy in December 2012 (new regulation
19).
Employment Targets and the Distribution of Development
(CS1)
Representations
Twelve
respondents (2% of the total comments on this policy) have
challenged the jobs target. Some say
the target is too high and others too low. Objectors are concerned that there is not enough
evidence to explain where 10,000 new jobs will come from, and also
raise concerns that commuting to out-of-town employment locations
is not acceptable. Respondents would
prefer the Core Strategy to focus on providing high quality
employment only, objecting to the prioritisation of warehousing
because it is considered that such jobs are low skilled.
Some
respondents seek a more flexible approach to changes of use where
an existing employment site does not meet modern business
requirements, and are looking for flexibility in policies to allow
for additional office development outside of the town
centre. There is also a call for a
wider distribution or a dispersal pattern of employment sites, in
line with the distribution of housing sites.
There
is 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
are also suggestions that this location could accommodate housing
or mixed use development for housing and employment. There is a high level of opposition to development
at junction 8 from local residents (254 respondents or 52%), who
object 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
are proposed at Detling Airfield Estate, Park Wood and Hermitage
Lane. Apart from a subsidiary part of
Detling Airfield, none of these sites are being promoted by the
landowners. Undeveloped land to the
west of Detling Estate has been put forward by the
landowner.
There
is support for medical research facilities at junction 7, provided
development has adequate links to the motorway. There is also a minority view that reference to
medical research in the policy is unnecessarily specific, and those
developers are seeking general employment or mixed use development
(including housing and retail) in this location. Objections to development at junction 7 are based
on concerns about the impact of development on the landscape, in
particular the setting of the Area of Outstanding Natural Beauty,
and traffic congestion. There is a
suggestion that any proposals for research and development should
be located at Maidstone Hospital or at Detling Showground, but not
by the landowners of those sites.
Officers’ response
The
workforce for the 10,000 additional jobs will come, in
part, from the increase in resident labour supply resulting from
the completion of 10,080 new dwellings.
This target provides for an additional resident labour supply of
5,000 workers[2]. The balance of jobs
will be provided by reducing out-commuting and increasing
in-commuting, with a particular focus on the delivery of a
proportion of employment development that attracts well paid
jobs. This objective underpins the
Economic Development Strategy 2008 (EDS) and the land requirements
set out in the Employment Land Review Partial Update 2011
(ELR). Development, such as the medical
campus proposed at junction 7 of the M20 motorway and premium
offices at junction 8, is likely to attract residents currently
commuting out of the borough, including to London. Further objectives of the EDS include an
overall increase in economic activity rates in the borough as well
the promotion of higher and further education,
thereby expanding the pool of local skilled labour
available to match the jobs supply.
While it is important to reduce out-commuting, the borough should
be providing for a balance of jobs. The
Council cannot of course control the number of jobs created, only
the hectarage or square metres of
floorspace of employment allocations to
encourage employers to locate in the borough.
While
the Core Strategy will allocate land for employment development,
wider promotional initiatives will play a key role in achieving
economic prosperity and attracting employers to assist in achieving
the right balance of jobs and reduce out-commuting. Thus it is more appropriate for the Core Strategy
to reflect the demand for employment floorspace and the Council’s aspirations in
terms of land use and, consequently, it is recommended that the
10,000 jobs target set out in policy CS1 of the draft Core Strategy
2011 be replaced with a specific employment floorspace requirement expressed in square metres,
which is easier to monitor.
The ELR
sets out the m2 and hectarage demand for each of the B use classes
based on 2009/10 data. Although this
data will be updated (with the amount of employment floorspace granted planning permission in the
intervening period) prior to the next round of public consultation
on the Core Strategy (regulation 19[3]) in December 2012, the need
to provide for a range of employment uses persists. The Council’s targets will be redefined in
policy CS1 to support the employment needs for the borough,
including identified demand and the Council’s aspirations to
provide for advanced manufacturing and industrial uses.
Office
development must be directed towards the town centre in accordance
with the National Planning Policy Framework 2012 (NPPF) and the
application of the sequential test. The
borough’s quantitative office needs can be provided for in
its town centre. To meet qualitative
demand, further office development is provided at Eclipse Park to
deliver some flexibility and choice for the market, and demand will
also be met through a quantum of research and development
facilities proposed at the medical campus and premium office
development at junction 8. It has been
demonstrated[4] that the borough’s
industrial/warehousing employment needs cannot be met through a
dispersed pattern of development.
With
regard to the strategic employment location at junction 8 of the
M20 motorway, officers have undertaken an assessment of the
alternative sites proposed by respondents to the 2011 public
consultation event, despite not having any current evidence of
their availability for redevelopment.
The
suitability of the Parkwood Industrial
Estate for significant intensification and expansion is limited by
highway constraints. Existing vacant
floorspace at the industrial estate has
already been accounted for in demand calculations. The loss of existing floorspace as a result of redevelopment would need
to be taken into account, so any net gain would not be enough to
meet requirements for additional industrial/ warehouse
development.
Detling
Airfield Estate is located within the nationally designated Area of
Outstanding Natural Beauty (AONB). The
site has limited capacity and the existing employment floorspace on the estate lost through redevelopment
would have to be offset against gains.
Traffic would be directed via junction 7 of the M20 motorway which
does not have the capacity of junction 8, and development would
require transport infrastructure (such as a large roundabout on the
A249) which it could not fund. The
undeveloped land between the estate and the County Showground has
been promoted by the landowner for development. The same transport concerns raised for the
redevelopment of the estate would apply, and the landscape concerns
of development on a greenfield site
within a nationally designated AONB would be even more
acute.
Key
constraints to industrial and warehouse development in the broad
location of Hermitage Lane at Allington
is the lack of capacity at junction 5 of the M20 motorway and the
A20/Hermitage Lane junction to cope with additional HGV movements,
as well as the proximity of such uses to residential properties and
the Maidstone Hospital. A critical mass
of employment uses could not be delivered in this
location.
Maidstone’s employment needs cannot be met through a dispersed pattern of development. Junction 8 is the best location for a critical mass of employment uses, including premier office development, industry and warehouse uses, which will provide for a qualitative scheme in a parkland setting to help mitigate the impact of development on the landscape. Junction 8 has transport capacity, and studies demonstrate that the impacts on local roads, including HGV movements, are within reasonable limits. Development will be guided by a development brief approved by the Borough Council and undertaken in consultation with local stakeholders. The preferred site in this location will be subject to public consultation, and is discussed in a separate report on strategic site allocations.
Junction 7 of the M20 motorway is identified as a strategic location on the draft Core Strategy 2011 key diagram for a medical hub. Following progress on the construction of the Kent Institute of Medicine and Surgery (KIMS) clinic in this location and the identification of further opportunities for medical facilities in association with the clinic, the site is considered as part of the strategic site allocations report.
A
medical campus provides an opportunity for Maidstone to become a
centre for medical excellence. It
supports the Council’s objectives for economic prosperity and
the allocation will deliver a well designed and sustainably
constructed development that will attract a skilled workforce and
assist in balancing the jobs market.
There are no alternative sites suitable for this type of
development in the borough because of the nature of demand for
these facilities, and the proximity of the campus to the KIMS
clinic and motorway junction.
Development will have an impact on the landscape so mitigation
measures will be critical to the site’s
development. Development will be guided
by a development brief approved by the Borough Council, which will
include a range of mitigation measures, including highway and
public transport improvements.
General
employment or mixed use development including housing is not an
appropriate use for this site, and such uses have been provided for
elsewhere. The site has been identified
as a unique opportunity for a medical campus to provide specialist
medical facilities, research and development and medical
teaching.
The
medical campus is adjacent to Newnham
Court Shopping Village, and the owners of the Village are currently
seeking to make improvements to existing retail
facilities. The redevelopment of the
shopping village together with the medical campus will attract the
investment funding required to facilitate highway improvements
necessary to serve the development.
Extending the development brief for the medical campus to
incorporate the shopping village will provide an opportunity to
secure a well planned, well designed and comprehensive development
at an important gateway into Maidstone.
The impact of replacement retail facilities on the town centre will
be addressed through the requirement for retail impact assessments
and policy restrictions.
Housing
Targets and the Distribution of Development (CS1)
Representations
There
are mixed responses to the Council’s 10,080 dwelling target
whereby some respondents support the target (22 respondents or 5%)
while others believe it is too high or too low (42 respondents or
9%). A proportion of the development
industry is proposing a higher target, while residents are seeking
a reduction. There are also objections
to the housing target on grounds that it is not in conformity with
the South East Plan target of 11,080 dwellings.
A few developers feel there is a lack of testing of
alternative options for delivering housing development.
There
are a number of challenges from the development industry to the
Council’s housing land supply (19 respondents or 4%), and
some objectors are seeking a 20% contingency allowance for the non
implementation of planning permissions when undertaking 5-year
housing land supply calculations.
There
is a consensus of support from both the development industry and
residents for a dispersed pattern of development that delivers
housing at the urban fringe and at rural service centres, although
a minority of respondents do object in part or as a
whole.
There
is support for the principle of identifying a strategic housing
development location to the north west of the urban area in the
vicinity of Allington, although some
objections focus on reducing the amount of housing
proposed. A number of residents and the
adjoining local authority unconditionally object to development in
this location (47 respondents or 10%) on the grounds of increased
traffic congestion, the impact on the landscape, and maintenance of
the strategic gap between conurbations.
There
is general support for the south east strategic housing development
location around Park Wood and Otham (6 respondents or
1%). In the main, objections are from a
minority section of the development industry which is objecting to
a move away from a strategic development area that would
accommodate 3,000 or 5,000 dwellings supported by a strategic link
road.
One
objector from the development industry has suggested that a north
Maidstone corridor should be identified more firmly as a suitable
mixed use business location that would have housing potential to
support the employment uses.
With
regard to the distribution of development at rural service centres,
there is a call for the inclusion of specific targets for the
villages in the Core Strategy, as opposed to a single target to be
distributed amongst the 5 villages (27 respondents or
6%). Additionally, developers have
referred to the importance of the 9 February 2011 Cabinet report,
which discussed the potential to release a limited amount of
appropriate development sites at rural service centres in advance
of land allocation documents, provided there is firm evidence of
local need. The development industry
would like to see this reference included in the Core
Strategy.
Some
landowners, developers and/or agents have focused their comments on
the strategy and the proposed distribution of development, and have
not used the consultation as a vehicle to promote their
sites. Others have promoted individual
sites and used their availability as part of the argument in
support of the Core Strategy or as a tool for seeking an
amendment. There is a call from part of
the development industry for the Core Strategy to include detailed
strategic development site allocations, as opposed to the strategic
development locations identified on the key diagram of the draft
Core Strategy.
Officers’ response
On 16
May 2012 Cabinet approved the inclusion of strategic site
allocationswithin the strategic development locations identified on
the key diagram of the draft Core Strategy 2011. This decision was made in the context of a review
of the Local Development Scheme and in response to representations
made during public participation consultation (2 September to 14
October 2011). There were a number of
benefits to this approach set out in the May report, not least good
planning practice and the certainty it gives to the public and the
development industry about the quantity and location of
development. The recommended strategic
housing and employment site allocations, which will be the focus of
a partial public consultation on the Core Strategy (regulation 18),
are the subject of a separate report. Following consultation on strategic housing
and employment site allocations, the draft Core Strategy as a whole
(as amended by both regulation 18 consultations) will be approved
for Publication consultation (regulation 19) in December
2012.
The
Council has been through an extensive exercise to determine how
much development (with supporting infrastructure) the borough can
accommodate, and has also tested distribution patterns of growth
against a number of different factors. During the preparation
of its Core Strategy, the Council approved a methodology to test 5
development options using 3 potential housing targets and 2
distribution patterns of development (concentrated and
dispersed)[5]. The 3 dwelling
targets were based on:
· 8,200 representing natural growth and the draft South East Plan 2006 target
· 10,080 representing Growth Point submissions and the South East Plan EiP Panel[6] recommendations
· 11,000 in line (approximately) with the adopted South East Plan 2009 target of 11,080 imposed by the Secretary of State (contrary to the EiP Panel’s recommendations)
The
option testing focused on the Council’s priorities for
Maidstone to have a growing economy and to be a decent place to
live, but also took into consideration infrastructure capacity,
environmental and ecological capacity, place shaping and
deliverability. The Council's evidence base was expanded to
include demographic and labour supply forecasts; transport
modelling; a Strategic Housing Land Availability Assessment; a
Strategic Housing Market Assessment; a Water Cycle Strategy; and
studies on employment, retail and the town centre.
Furthermore, the infrastructure and service providers were
consulted on the options for developing the housing strategy.
All of these elements contributed to the decision making
process.
The
methodology was objectively assessed by the Council’s
Business Transformation team and, following a report on the results
of the exercise[7], Cabinet approved a target
of 10,080 dwellings for public consultation. A full assessment of the options is also included
in the Sustainability Appraisal that will support the strategic
site allocations during public consultation and the Core Strategy
through its various stages of production.
In
brief, the option of 8,200 could only be tested in a dispersed
pattern of development and was rejected because the cost of
infrastructure required to support this option was considerably in
excess of the funds that could be secured through
development. The remaining four options
of 10,080 and 11,000 dwellings in dispersed or concentrated
development distribution patterns had contrasting strengths due to
the broad differences in distribution.
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 strategy or better
balanced urban and rural development. Development could fund
the infrastructure required to deliver the remaining four options,
including transportation measures, but could not finance a
strategic link road to required standards. However, unlike
the higher housing target tested, 10,080 dwellings could be
delivered without relying on SHLAA[8] sites that proved difficult
to develop[9].
A local
housing target of 10,080 dwellings for the plan period, to be
provided in a dispersed pattern of development, was the best option
to ensure the Core Strategy is affordable and deliverable, offering
choice and flexibility. This option took 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. The range of policies contained in
the former South East Plan and the emerging draft Core Strategy
were taken into account when developing the housing target and
development distribution, a number of which aim to protect the
environment and manage traffic congestion.
It is
accepted that Maidstone borough has performed well in the housing
market over the past 5 years and has delivered its targets[10]. However, past high
building rates are a reflection of the completion of high density
flatted development on a number of brownfield sites that became available in the
town. The strong relationships internally between planning
and housing and externally with the registered providers of
affordable housing, together with external funding from the Homes
and Communities Agency, have also contributed to a strong market
performance. Given the current economic
climate, changes in government funding for housing and borrowing
rates, these development rates will not continue, particularly when
new site allocations are adopted and lower density greenfield sites are released. Not all SHLAA sites will be suitable for
development once further appraisals are undertaken. Past development rates alone cannot be relied on
to extrapolate future housing targets.
Local housing targets should be based on evidence and engagement
with the community.
A
target of 10,080 dwellings delivered in a dispersed pattern of
development remains the most sustainable for Maidstone
borough. This approach strikes a good balance between growth
and environmental capacity; and a balance between securing economic
prosperity and decent affordable housing with protecting the
environment and minimising the impact of development on traffic
congestion. The strategy delivers the Council's spatial
vision and there does not appear to be any compelling evidence to
suggest a move away from a target of 10,080 dwellings.
The
National Planning Policy Framework (NPPF) was published in March
2012. It makes clear that regional
strategies form part of the development plan until such time as
they are abolished by Order using the powers of the Localism Act
(2011). The NPPF also confirms that local planning authorities can
continue to draw on evidence that informed the preparation of
regional strategies to support local plan policies (paragraph
218). The Core Strategy must be in
general conformity with all policies of the NPPF and the South East
Plan, including those that seek to protect the environment and
relieve traffic congestion. It is
considered that the strategy meets these requirements and the
dwelling target of 10,080 units is therefore in general conformity
with both documents, and is based on evidence submitted to the
South East Plan EiP.
Several
respondents challenge Maidstone’s 5-year housing land
supply. Annual housing land surveys are
undertaken, and supply is calculated using tried and tested
methods. There can be disagreement over
the phasing of sites that have outstanding planning permissions,
which is a more subjective part of the assessment, but each year
officers contact all applicants with sites of 10 units or more to
check the delivery of their sites.
Nevertheless, this is an important year because the data as at 1
April 2012 will form part of the evidence base to support the Core
Strategy at examination, and it would be prudent to try to identify
and resolve areas of disagreement with the development
industry. Consequently, officers will
hold round table sessions with representatives of the development
industry with a view to gaining a consensus on the methodology for
calculating 5-year housing land supply and other elements of supply
that contribute to the 20-year housing trajectory. These sessions will be held over the summer, in
advance of updating the 5-year supply data for Maidstone’s
Annual Monitoring Report and the 20-year housing trajectory that
will support the Core Strategy at Publication, Submission and
Examination stages.
The
adopted NPPF requires local authorities to build in an additional
5% buffer when calculating their 5-year housing land supply
(rolling forward on an annual basis).
The buffer is only increased to 20% for those authorities who have
poor past delivery rates of their housing targets. This is certainly not the case in
Maidstone.
In
developing its strategy, the Council has moved away from an urban
extension (Option 7C) for good reasons set out in this
report. The strategic site allocations
report examines the capacity of sites in the strategic locations
identified on the draft Core Strategy 2011 key diagram, and looks
at the impact of development on the landscape, the environment and
the transport network among other issues. Development will be guided by a development brief
for each site, and policies will set out the mitigation measures
necessary for development to proceed.
The public will have an opportunity to comment on specific site
allocations in August/September before the Core Strategy is amended
for public consultation in December.
The
Council is proposing to meet specific development needs by
releasing prime location sites at junction 7 for a medical campus
and junction 8 for premium offices, industrial and warehouse
development. Both sites will be
contained by structural and internal landscaping and there are no
proposals for future expansion. These
are not appropriate locations for housing or general business use,
and to reduce employment capacity at junctions 7 and/or 8 to
accommodate residential development would affect the
Council’s ability to meet its employment needs. Housing development in addition to the employment
proposed at junction 8 would compromise the setting of the
AONB. There is no firm evidence to
support the identification of a north Maidstone corridor for
employment and/or housing development, and there is no
justification for moving away from a sustainable housing strategy
locating new housing in and at the edges of the urban periphery and
at the rural service centres.
Policy
CS1 of the draft Core Strategy 2011 sets an overall target of 1,130
dwellings to be accommodated on new greenfield sites at the five rural service centres
of Harrietsham, Headcorn, Lenham, Marden and
Staplehurst. The Strategic Housing Land
Availability Assessment 2009 and the Strategic Sites Assessment
2009 demonstrated an adequate choice of sites to meet this
target. The distribution of this target
(used for testing purposes) was illustrated in the Cabinet report
of 9 February 2011. Given the need for
neighbourhood plans to be in conformity with development plan
policies, and to provide clarity for the public and the development
industry, it is appropriate to include the targets for each
village:
· Harrietsham |
315 dwellings |
· Headcorn |
190 dwellings |
· Lenham |
110 dwellings |
· Marden |
320 dwellings |
· Staplehurst |
195 dwellings |
With
regard to the early release of suitable greenfield sites at the rural service centres,
paragraph 1.2.7 of the 9 February 2011 report stated:
“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, 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.”
Although this paragraph did not form part of the formal
recommendation, it was part of the justification in setting a local
housing target of 10,080 dwellings and seeking Cabinet approval for
the target. Statistical analysis of
2009/10 housing land data demonstrated that 15% of all dwellings
completed between 2006 and 2010 and in the pipeline at 2010 were on
rural sites. The Core Strategy seeks to
direct 20% of all development over the plan period (2006 to 2026)
to the rural area through land allocation documents.
It is
acknowledged that the majority of residential development in recent
years (and therefore the provision of affordable housing) has been
located on brownfield sites within the
urban area. Potential development sites
located at the rural service centres are too small to meet the
criteria for strategic site allocations in the Core Strategy, so
land at these locations will not be allocated until the Development
Delivery Local Plan is adopted in 2015.
Thus it is important to focus a proportion of appropriate
development at rural service centres where there is firm evidence
of need that cannot be met through an exceptions site (ref
MA/11/0592 Hook Lane Harrietsham). This
approach will also assist the parish councils with the preparation
of their neighbourhood plans. It is
recommended that the Core Strategy is amended to acknowledge this
need.
Affordable Housing (CS10)
Representations
A
number of respondents unconditionally support the Core Strategy
affordable housing and local needs housing policies (38 respondents
or 24%), but opinions on the flexibility of the affordable housing
policy are split. The main concerns
relate to the part of the policy which states that affordable
housing provision could be reduced where viability is affected as
the level of reduction is not defined.
Residents feel the policy is too flexible while the development
industry has an opposing view.
Developers believe the tenure split is too prescriptive and should
be left to market forces. With one or
two exceptions, respondents feel there should be no specifically
identified affordable housing contribution towards Gypsy and
Traveller accommodation in the affordable housing policy (11
respondents or 7%). A number of
respondents, including developers and parish councils, have
suggested the 40% target should be adjusted according to
location. There is a cross section of
developer comments proposing variable targets for affordable
housing and calling for appropriate viability testing of such
options.
Officers’ response
The
NPPF confirms that local planning authorities should use their
evidence base to ensure objectively assessed needs for market and
affordable housing are met. Policies
should seek to provide for affordable housing on-site, unless there
is robust evidence for off-site provision or contributions, and
policies should be sufficiently flexible to respond to changing
market conditions over time. The NPPF
also makes clear that all policies, including those for affordable
housing, should be deliverable and viable. The Core Strategy provides for a mix of market and
affordable housing, but also for a mix of tenures to reflect the
prospect that future generations may only be able to afford part
ownership in a property.
Affordable housing is a policy burden for developers, and their
ability to provide this accommodation is influenced by the
availability of grant funding. Advice
contained in the newly published Viability Testing Local Plans
(June 2012), jointly prepared by the Local Government Association
and Home Builders Federation, will assist in ensuring Core Strategy
policies are sound. The prioritisation
of the infrastructure needed to deliver the Core Strategy is
discussed in the strategic site allocations report.
In
partnership with Swale Borough Council, Maidstone Borough Council
has recently appointed consultants (Peter Brett Associates) to
undertake a joint viability assessment of both councils’
local plans/ core strategies, with the intention of this work
feeding into the Community Infrastructure Levy Charging
Schedule. The studies will consider
different aspects of viability, including affordable housing
contributions, site specific considerations, and wider
infrastructure impacts. The work will
address options for varying the percentage of affordable housing by
area. It is acknowledged by officers
that a blanket 40% affordable housing target cannot be applied
without a viability study because it would not provide certainty
about delivery to the development industry and the
public.
Clarity
is needed to reassure respondents that the affordable housing
contribution towards Gypsy and Traveller accommodation will be part
of the total affordable housing requirement set in the policy, and
it is not in addition to the target (as the wording of the policy
currently implies). So whatever overall
affordable housing percentage is ultimately set in the policy, a
proportion of that target will provide for public Gypsy and
Traveller pitches.
The
affordable housing percentage requirement and tenure breakdown will
be tested through public consultation on strategic site allocations
in August/September 2012. A review of
the affordable housing policy will be undertaken once viability
evidence has been completed, in time for the December public
consultation (regulation 19) on the Core Strategy. A further report will be presented to Cabinet in
November.
Rural
Service Centres (CS4)
Representations
A
number of respondents are unconvinced that Harrietsham should be
designated a rural service centre (8 respondents or
7%). Concerns surround the lack of
village facilities without a clear village centre, and its
proximity to facilities in Lenham.
Conversely, respondents argue that Coxheath offers a wide range of
services, including a district centre, consistent with the role of
a rural centre (2 respondents or 2%).
Officers’ response
The
criteria and justification for designating rural service centres
was set out in detail in Policy Evolution (Appendix 3 to the draft
Core Strategy 2011). Following
engagement with a number of parish councils through a workshop in
2009, the designation of Harrietsham was influenced by its
infrastructure capacity to accommodate development, including
employment, school facilities and sewage capacity, together with
its good public transport connections to Maidstone town centre and
local retail and employment facilities.
Coxheath was not designated a rural service centre because of
its proximity to Maidstone’s urban edge with good bus links
to the town centre. Coxheath had also
absorbed a significant amount of housing development in recent
years, particularly with the redevelopment of Linton Hospital, and
was adjusting to the increase in population. Local aspirations pointed to a need for local
needs housing and small employment sites to support population
growth, rather than the need for targeted growth.
No
objections to the designation of Harrietsham as a rural service
centre, or to the exclusion of Coxheath, were received from the
parish councils during the public participation consultation on the
Core Strategy in 2011.
Transport Infrastructure (CS7)
Representations
Respondents are highlighting the need to improve the bus
services and/or the park & ride services throughout the
borough, and improve rail links and services, particularly to
London (32 respondents or 23%). There is a call for the Core Strategy to give a higher priority
to walking and cycling, to achieve this objective by redesigning
the borough’s roads (19 respondents or 12%).
Respondents have raised concerns over inadequate access routes
for HGVs, which will be made worse by
employment development proposals at junction 8 (14 respondents or
10%). HGVs
need to be diverted away from the town centre and rural service
centres. Objectors are particularly
worried about the highway capacity to the north west of the
borough, and have expressed concerns over increased congestion
(which forms part of the overall objections to the strategic
development location in the vicinity of Allington). Some
respondents are seeking the construction of a ring road or bypass
to the south of the urban area in order to improve access from the
south by relieving congestion (17 respondents or 12%). There are mixed views on town centre parking
provision: there is a perceived lack of parking for the public and
businesses, or views that parking should be constrained in order to
encourage more sustainable forms of transport.
Officers’ response
The
Integrated Transport Strategy (ITS) is the subject of a separate
report which addresses these concerns.
Public consultation on the draft ITS will be undertaken in tandem
with the partial public consultation (regulation 18) on draft Core
Strategy strategic site allocations in August/September
2012.
Green
Wedges/Green and Blue Corridors (CS3)
Representations
It is
clear from the comments received about green wedges, which are
shown on the draft Core Strategy 2011 key diagram and referred to
in policy CS3 for the urban area, that there is some confusion over
their role and function (30 respondents or 20%). Additionally respondents have pointed out that,
while policy CS3 refers to the urban area, green wedges are also
identified in the countryside, so there should be policy cross
referencing. As a result of this
confusion, some respondents are interpreting the green wedges as a
landscape layer which is seen as a restriction to
development. Hence there are calls for
extensions or reductions to the green wedges shown on the key
diagram.
Officers’ response
To
avoid confusion, green wedges should be referred to as green and
blue corridors. The corridors form part
of the strategy for the spatial distribution of development, so
references to the corridors should be transferred from policy CS3
to policy CS1.
The green and blue corridors are not intended as a protection of the countryside for its own sake, and nor are they an additional layer of landscape protection. A characteristic of Maidstone is the way in which tracts of rural and semi-rural land penetrate into the urban area, giving the urban area its unique stellar shape and its population access to the countryside. Green and blue corridors have two prime purposes:
· As a specific local anti-coalescence function by maintaining open land between areas of development spreading out from the town; and
·
To focus attention on opportunities for public
access from the town to the countryside.
The
corridors have helped to develop the Core Strategy strategic
development locations, and strategic site allocations for housing
and employment[11] have had regard to the
corridors. It is recognised that some
of the green and blue corridors do contain local landscape features
and areas of ecological interest, which should not be compromised
where development is proposed to be allocated. These features will be explored in more depth
through the preparation of a Green and Blue Infrastructure
Strategy.
The
green wedge notations on the Core Strategy key diagram need to be
amended to better reflect their purpose in supporting the
Council’s spatial strategy.
Gypsy,
Traveller and Travelling Showpeople
Accommodation
Representations
There
is general support for this policy (29 respondents or 28%) but
respondents are seeking further clarity. The main issue is around the robustness of the
2005/06 Gypsy and Traveller Accommodation Assessment and a call for
the pitch target to cover the whole Core Strategy period to
2026. Respondents are seeking the early
identification of Gypsy and Traveller sites to aid the integration
of the Traveller community and to allow for appropriate enforcement
(8 respondents or 8%). There are
concerns that some parts of the borough have high concentrations of
Gypsy and Traveller sites, and a feeling that the spread across the
borough should be more even.
Officers’ response
The
Gypsy and Traveller Accommodation Assessment was updated in
2012[12] in order to set an
up-to-date pitch target in the Core Strategy from 2010 to
2026. Cabinet approved a revised target
of 157 pitches on 14 March 2012 and this target will be included in
the December consultation draft of the Core Strategy. The policy will be reviewed in the context of new
national guidance published in 2012[13] and, prior to the December
consultation, will be reworded to provide the clarification sought
by respondents and the addition of a landscaping
criterion.
Private
pitches will be allocated in the Development Delivery Local Plan
but, in the interim, the Council has secured funding for a public
site[14] and work to provide a
suitable site(s) is ongoing.
The Council cannot restrict the concentration of Gypsy and Traveller sites or control the spread of sites through Core Strategy policies, but it can refuse planning applications that cumulatively have an adverse impact on the landscape.
The Cabinet were informed that the Regeneration and Economic Development Overview and Scrutiny Committee were recommending the following:-
1. Consultation with neighbouring districts be undertaken as per the legislation and that Cabinet put in place a methodology for public consultation. (Site allocations and ITS)
2. Approximate figures for jobs are provided in the document alongside employment square footage. (Site Allocations)
3. The option to install a bus lane on the A274 be re-assessed (ITS)
4. That recommendation 2 of the public participation report be amended to say:
Reject Junction 8 of the M20 motorway as a Strategic Development Site location for industrial and warehouse development, together with premium office development and do not allocate land for development in the Core Strategy to be guided by an approved development brief.
The Cabinet were also informed that the Spatial Planning Strategy Advisory Group were recommending the following:-
All the recommendations set out in the report were agreed subject to the following amendment:-
a) Recommendation (ii) re Junction 8 was agreed but in addition the following resolution was also agreed.
That in respect of the proposals relating to Junction 8 on the M20 motorway and the Woodcut Farm site the 7ha site to the north west of the site would be given over to a landscaped area should come into public ownership either through the Council or a Charitable Trust and that the proposal is communicated to the community setting out the Council’s intention through this proposal to protect the land to the north west of this area as open countryside.
b) Recommendation (iii) be reworded as follows:
“Retain Junction 7 of the M20 motorway as a medical campus and that the Cabinet give further consideration to the allocation for land as development in the Core Strategy in conjunction with the adjacent redevelopment of Newnham Court Shopping Centre which would have been guided by an approved Development Brief”.
c) Recommendation (xii) be reworded as follows:
“Rename Green wedges as Green and Blue corridors, transfer references to corridors in policies CS3 to policy CS1 and amend the Green wedges notations on the Key diagram but that in so doing these changes are cross referenced to the NPPF”.
d) New recommendation (xv) be inserted in the following terms:
“That the Cabinet give consideration to the Maidstone Town Centre being allocated a strategic site or highlighted in policy in a way that has the same effect as that of a strategic site allocation.
[1] Town and Country Planning Act (Local Planning) (England) Regulations 2012
[2] Demographic and labour supply forecasts 2010
[3] Town and Country Planning (local Planning) (England) Regulations 2012
[4] Cabinet 9 February 2011
[5] Cabinet 29 September 2010
[6] South East Plan Examination in Public Panel Report (2007)
[7] Cabinet 9 February 2011
[8] Strategic Housing Land Availability Assessment 2009
[9] Strategic Sites Assessment 2009
[10] Annual Monitoring Report 2010/11
[11] Cabinet report on Core Strategy Strategic Site Allocations 25 July 2012
[12] Gypsy and Traveller and Travelling Showpeople Accommodation Assessment 2012
[13] Planning Policy for Traveller Sites March 2012
[14] Cabinet decision 8 June 2011
Alternative options considered:
Alternative options are contained within the reasons above.
Reason Key: Significant Impact on two or more wards;
Wards Affected: (All Wards);
Details of the Committee: None
Representations should be made by: 13 June 2012
Other reasons / organisations consulted
Draft Core Strategy was subject to full public
consultation (Regulation 18, formerly Regulation 25)
Consultees
Residents, businesses, infrastructure
providers, development industry, parish councils, ward members,
adjacent authorities, etc.
Contact: Rob Jarman, Head of Development Management Email: Robjarman@maidstone.gov.uk.
Report author: Sue Whiteside
Publication date: 27/07/2012
Date of decision: 25/07/2012
Decided: 25/07/2012 - Cabinet.
Effective from: 04/08/2012
Accompanying Documents: