Reconsideration of previously rejected Maidstone Borough Local Plan Regulation 18 Draft and 2014 SHLAA Housing Sites, 14/07/2015 Strategic Planning, Sustainability and Transportation Committee

Strategic Planning, Sustainability and Transport Committee			14 July 2015
Is the final decision on the recommendations in this report to be made at this meeting?				Yes

Reconsideration of previously rejected Maidstone Borough Local Plan Regulation 18 Draft and 2014 SHLAA Housing Sites

Final Decision-Maker	Strategic Planning, Sustainability & Transport� Committee
Lead Director or Head of Service	Rob Jarman, Head of Planning & Development
Lead Officer and Report Author	Steve Clarke, Principal Planning Officer (Spatial Policy)
Classification	Non-exempt
Wards affected	All

This report makes the following recommendations to the final decision-maker:
1:�� The following �re-assessed sites go forward to Regulation 19 Consultation as allocated housing sites but to include the revised site criteria attached at Appendix Two for site H1(10). H1(10) Land South of Sutton Road Langley with 10ha of natural/semi-natural open space. H1(31) Ham Lane Lenham H1(39) Ulcombe Road an Mill Bank Headcorn H1(40) Grigg Lane and Lenham Road Headcorn (part) H1(41) South of Grigg Lane Headcorn H1(42) Knaves Acre Headcorn 2 The following re-assessed sites go forward to Regulation 18 Consultation as potential housing site allocations H1(57) Former Astor of Hever School Farm Oakwood Road Maidstone H1(61) Land at Cross Keys Roundwell Bearsted with 2.3ha of natural/ semi-natural open space H1(64) Bell Farm North Harrietsham with 4.15ha of natural/semi-natural open space H1(65) Land at Lenham Road Headcorn H1(66) Land south of The Parsonage Goudhurst Road Marden H1(67) Land south of Marden Road Staplehurst H1(68) Land to the north of Henhurst Farm Staplehurst with 5.78ha of natural/semi-natural open space H1(69) Land at Lodge Road Staplehurst 3 The following sites go forward to Regulation 18 Consultation as newly considered potential housing site allocations Land at north of Heath Road (known as Older�s Field), Coxheath with 2.34ha of natural/semi-natural open space. 4 The following site goes forward to Regulation 19 consultation as an allocated housing site. H1(12) Haynes Ashford Road Maidstone

This report relates to the following corporate priorities:
Keeping Maidstone Borough an attractive place for all � Securing a successful economy for Maidstone Borough

Timetable
*Meeting*		*Date*
Policy and Resources Committee		N/A
Council		N/A
Other Committee		SPS&T Committee 14^th July 2015

Reconsideration of previously rejected Maidstone Borough Local Plan Regulation 18 Draft and 2014 SHLAA Housing Sites

1. PURPOSE OF REPORT AND EXECUTIVE SUMMARY

1.1 At its meetings on 2^nd and 4^th February 2015 and subsequently on 9^th March 2015 following a call-in of their earlier decisions, Cabinet made a series of decisions about housing sites included, or proposed to be included, in the draft emerging Maidstone Borough Local Plan (the Local Plan). An outcome of this decision making was that the draft Local Plan would provide for 2,201 fewer dwellings than would be required to meet the objectively assessed need figure of 18,600 homes (2011-31) in full. Cabinet also resolved that it wished to consider a further report which would set out the implications of this position for the production of a sound Local Plan.�

1.2 These implications were addressed in a report (Maidstone Borough Local Plan Housing Sites Update) considered at the meeting of this Committee on 9^th June 2015.

1.3 This report has arisen from the resolution of the Strategic Planning, Sustainability and Transport Committee on 9^th �June 2015 to adopt an amended version of �Option E� of the �Update Report�; which states:

1. Additional sites considered and excluded from the Local Plan during the January/February/March 2015 cycle of Cabinet meetings be re-considered (the sites deleted from the Regulation 18 version of the Plan (7 sites and 1 part site) and the allocation of more of the additional sites (15) resulting from the 2014 call for sites). Sites put forward by Ward Members with community support in Neighbourhood Plans during the further call for sites process and were borderline rejections from the SHLAA to also be re-considered.

2. Following sites are not to be re-considered:

� H1 (25) Tongs Meadow, West Street, Harrietsham

� H1 (60) Fant Farm, Maidstone

� H1 (48) Heath Road, Boughton Monchelsea

1.4 The first section of this report therefore re-assesses the Regulation 18 sites that were recommended for deletion and the reasons given for these recommendations by Cabinet. Maps of the sites are attached at Appendix One.

1.5 The second section of the report re-assesses the sites originally recommended for allocation but not accepted by Cabinet together with the reasons given for non-allocation. Maps of the sites and the proposed policy criteria are attached at Appendix Three.

1.6 The final section re-assesses sites that were on-balance rejected from the SHLAA call for sites exercises that have been undertaken including sites that were considered acceptable by Parish Councils/Ward Members as well as those which appear in neighbourhood plans. In this section, there is also some additional commentary on site H1 (12) Haynes, Ashford Road, Maidstone and H1(19) Bell Farm North Street Barming, �following additional information that has come to light since the decision taken by Cabinet. Maps of the sites are attached at Appendix Four

1.7 It is recommended that Councillors reinstate the following sites into the draft Plan for Regulation 19 Consultation or in the case of newly allocated sites, be subject to Regulation 18 Consultation.� In the case of Policy H1 (10) it is also recommended that Councillors approve the revised policy criteria included at Appendix 2.�

Sites in Maidstone Borough Local Plan Reg. 18 Consultation Draft 2014
Policy No.	Location		No. of units
H1 (10)	Land south of Sutton Road, Langley		850
H1 (31)	Ham Lane, Lenham		82
H1 (39)	Ulcombe Road and Mill Bank, Headcorn��		240
H1 (40)	Grigg Lane and Lenham Road, Headcorn (part)��		80
H1 (41)	South of Grigg Lane, Headcorn		55
H1 (42)	Knaves Acre, Headcorn��		5
		TOTAL	1312

Sites proposed to be allocated
H1 (57)	Former Astor of Hever School, Oakwood Rd.		60
H1 (61)	Land at Cross Keys, Roundwell, Bearsted		50
H1 (64)	Bell Farm North, East Street Harrietsham		80
H1 (65)	Land at Lenham Road Headcorn		50
H1 (66)	Land S of The Parsonage Marden		50
H1 (67)	Land S of Marden Road Staplehurst		100
H1 (68)	Land to the N of Henhurst Farm Staplehurst		60
H1 (69)	Land at Lodge Road Staplehurst		60
		TOTAL	510

1.8 Land at Older�s Field, Coxheath, should also be subject to Regulation 18 Consultation as a potential allocated housing site for up to 55 units. Site H1(12), Haynes, Ashford Road, Maidstone should be confirmed to go forward to Regulation 19 Consultation with an indicative yield of 200 units.

1.9 Councillors are also recommended to agree the revised site plan and site criteria for the site at Bell Farm, North Street, Barming; (Policy H1(19), that secure a minimum 5m set-back for development from the North Street frontage with a consequent extension of the site development area 5m further� westwards. �

2 INTRODUCTION AND BACKGROUND

2.1 At its meetings on 2^nd and 4^th February 2015, and subsequently on 9^th �March 2015, following a call-in of their earlier decisions, Cabinet made a series of decisions about housing sites included, or proposed to be included, in the draft emerging Maidstone Borough Local Plan (the Local Plan). An outcome of this decision making was that the draft Local Plan would provide for 2,201 fewer dwellings than would be required to meet the Objectively Assessed Need (OAN) figure of 18,600 homes (2011-31) in full. Cabinet also resolved that it wished to consider a further report which would set out the implications of this position for the production of a sound Local Plan.�

2.2 These implications were addressed in a report (Maidstone Borough Local Plan Housing Sites Update) considered at the meeting of this Committee on 9^th June 2015.

2.3 This report has arisen from the resolution of the Strategic Planning, Sustainability and Transport Committee on 9^th June 2015 to adopt an amended� �Option E� of the �Update Report�; which states:

2. Following sites are not to be re-considered:

� H1 (25) Tongs Meadow, West Street, Harrietsham

� H1 (60) Fant Farm, Maidstone

� H1 (48) Heath Road, Boughton Monchelsea

2.4 �Also at the meeting on 9^th June 2015, Councillors agreed a revised Objectively Assessed Need figure of 18,560 dwellings between 2011 and 2031.

2.5 The council�s housing land supply against objectively assessed need has been updated to reflect the latest information from the housing land survey at the snapshot date of 1 April 2015.� It is important to note that where a residential site allocation (with Cabinet approval) has gained a planning permission by 31 March 2015, the dwellings have been moved from �allocations� to �extant permissions�.� This is to avoid double counting sites.

	Dwellings	Totals
Objectively Assessed Need 2011 to 2031		18,560

Housing land supply:
Dwellings completed between 01.04.11 to 31.03.15	2,339
Extant planning permissions at 01.04.15	3,706
Yield from Cabinet approved allocations at 01.04.15	6193
Yield from Broad Locations (MBLP 2014 � Reg 18)	3,400
Windfall contribution 9 years at 114 dwellings p.a.	1,026
Total housing land supply	16,664	16,664

Unmet housing need (18,560 less 16,664)		1,896

Yield from further allocations proposed in the report		1,877

Regulation 18 Sites

2.5�� As can be seen from the details of the sites attached at Appendix One, Cabinet recommended that a total of eight sites be subject to a further Regulation 18 Consultation recommending their deletion from the Plan. The sites were as follows:

��

H1 (10)	Land south of Sutton Road, Langley
H1 (25)	Land at Tong�s Meadow West Street Harrietsham
H1 (31)	Ham Lane, Lenham
H1 (39)	Ulcombe Road and Mill Bank, Headcorn��
H1 (40)	Grigg Lane and Lenham Road, Headcorn (part)��
H1 (41)	South of Grigg Lane, Headcorn
H1 (42)	Knaves Acre, Headcorn��
H1 (48)	Heath Road Boughton Monchelsea

2.6 Cabinet gave reasons for their decision on each site as follows

��
H1 (10) Land south of Sutton Road

�� (as amended by Cabinet on 9 March 2015).

(a) in the opinion of the Cabinet the eastern boundary of site H1(5) forms a natural boundary to the edge of the urban area of Maidstone;

(b) there should be no further encroachment of residential development into the countryside which would result in the loss of green space and a leisure facility;

(c) there would be an unacceptable impact on conditions in the surrounding area where the environmental and amenity consequences for the community are unacceptable now.

H1 (25) Tongs Meadow West Street Harrietsham

(as agreed by Cabinet on 9 March 2015)

(a) in view of the recent advice from Natural England (NE) that they would be unlikely to consider issuing an EPS (European Protected Species) Development License given the fact that the site is a receptor site for a previous development,��

H1 (31) Ham Lane Lenham

(a) unacceptably adverse impact on the AONB and on the character of the village because it is peripheral to the settlement and beyond the open space occupied by Swadelands School playing field.

H1 (39) Ulcombe Road and Mill Bank Headcorn,

H1 (41) Land south of Grigg Lane Headcorn,

H1 (42) Knaves Acre Headcorn

(a) local infrastructure is insufficient, in particular for foul water sewerage, flood risk and highway congestion

H1 (40) Land at Grigg Lane and Lenham Road Headcorn (part),

(a) it has not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Headcorn and the unacceptable cumulative impact for the community and highways. In addition of community concerns that suitable highways access arrangements cannot be achieved at this point in time.

H1 (48) Heath Road Boughton Monchelsea

(a) as the site access is not within the control of the promoter of the site, the site cannot be considered as deliverable.

2.7 The reasons given for the recommended deletion of each site have been re-assessed in order to ascertain whether they are likely to be upheld under examination by an Inspector at the ultimate Independent Examination of the submitted Local Plan and also in light of decisions made by the Council�s Planning Committee in recent months. As resolved by this Committee on 9^th �June 2015, sites H1(25) Tongs Meadow, West Street, Harrietsham, H1(48) Heath Road Boughton Monchelsea, and H1(60) Fant Farm, have not been reassessed.

2.8 Turning to the sites in Headcorn, sites H1(39) to H1(42), Councillors will be aware that the Ulcombe Road/Mill Bank site (H1(39)), was the subject of an application, reference MA/14/505284/OUT. The applicants lodged an appeal against the failure of the Council to determine the application within the statutory time period. On 16^th April 2015, in accordance with appeal procedure, the Planning Committee resolved that had no appeal been lodged, they would have granted planning permission for the development.

2.9 In arriving at this resolution, Councillors were satisfied that a drainage solution for the development had been demonstrated that would not make the existing situation worse. New development cannot be used to solve existing problems. No objections were raised to the application from Southern Water or the Environment Agency the Statutory Consultees. In addition, whilst Cabinet were concerned that the local road network was not of a sufficient capacity, Kent Highway Services did not object to the application on highway capacity or safety grounds and were satisfied that appropriate mitigation could be put in place. Similarly, concerns regarding the capacity of Headcorn Primary School to expand to accommodate expected growth in pupil numbers were also unfounded as an appropriate solution to address this issue with a deliverable plan to extend the school and its grounds to meet the required standards for a 2-form entry school having been identified by the Kent County Council and discussed with officers and the applicants. On this basis, the Planning Committee resolved that, had it been in a position to do so, it would have granted permission for the development subject to appropriate s106 obligations and planning conditions.

2.10 The reasons given for the recommended deletion of site H1(39) were as follows:

�local infrastructure is insufficient, in particular for foul water sewerage, flood risk and highway congestion�

Councillors will be aware that an identical application (15/503325) has been submitted and this is to be reported to the Planning Committee on 9 July with a recommendation that planning permission be granted subject to the prior completion of a s106 agreement, there being no change in circumstances relating to the site since the earlier application was considered in April. It is considered that the reasons given by Cabinet for recommending the deletion of policy H1(39) are not sound and would not be upheld at an Independent Examination of the Local Plan.

2.11 Similarly, planning applications have been submitted on the part of site H1(40) (Grigg Lane and Lenham Road, Headcorn), that are not already subject to extant planning permissions. The reasons for recommending deletion of this site were very similar to sites H1(39), H1(41) and H1(42);

�it has not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Headcorn and the unacceptable cumulative impact for the community and highways. In addition of community concerns that suitable highways access arrangements cannot be achieved at this point in time.�

2.12 �Again, no objections have been raised to the submitted planning applications by relevant statutory consultees on flood risk or drainage grounds, highway impact or impact on local education provision. It is considered therefore that the reasons given by Cabinet for recommending the sites be deleted are not sound and would not be upheld at the Independent Examination of the Local Plan.��

2.13 By analogy with the above examples, it is considered that the reasons given for the recommended deletion of sites H1(41) South of Grigg Lane and H1(42) Knaves Acres (which were identical to the reasons for site H1(39)), are also unsound and would not be upheld at the Independent Examination.

2.14 It is recommended therefore that the sites should be retained in the plan and be subject to further Regulation 19 Consultation.�

2.15 �With regard to site H1(31); Ham Lane, Lenham, Cabinet recommended deletion of the site for the following reason:

(a) unacceptably adverse impact on the AONB and on the character of the village because it is peripheral to the settlement and beyond the open space occupied by Swadelands School playing field.

��

2.16� � At the Council�s Planning Committee on 26^th February 2015, planning application MA/14/502973 in relation to this site was refused planning permission on the following ground:

��

�� The development proposed would not constitute good design by reason of its layout (including inadequate space for structural landscaping) and scale. It would therefore be harmful to the character and appearance of the open countryside, including the setting of the Kent Downs Area of Outstanding Natural Beauty. The application is therefore contrary to the National Planning Policy Framework, in particular paragraphs 56, 57, 58 and 109, and �saved� policies ENV28 and ENV33 of the Maidstone Borough-Wide Local Plan 2000.�

2.17 The Planning Committee did not consider that the development as proposed was of a satisfactory design, layout and visual impact and that it would thus have an adverse impact on the setting of the Kent Downs AONB which lies on the north side of the A20 Ashford Road opposite the site.

2.18 Recommended to Cabinet as a result of the review of representations received from the Kent Downs AONB Unit and others at Regulation 18 consultation stage, were three new criteria as follows.

The development proposals are designed to take into account the results of a landscape and visual impact assessment undertaken in accordance with the principles of current guidance that particularly addresses the impact of development on the character and setting of the Kent Downs AONB

Development proposals shall incorporate substantial areas of internal landscaping within the site to provide an appropriate landscape framework for the site to protect the setting of the Kent Downs AONB

Development proposals will be of a high standard of design and sustainability reflecting the location of the site as part of the setting the Kent Downs AONB incorporating the use of vernacular materials and demonstrating compliance with the requirements of policies DM2, DM3 and DM4.

2.19 It is considered that these three criteria along with the existing criteria in the Regulation 18 draft Local Plan should ensure an appropriate form of development is secured.

2.20 Councillors will also note from the site plan attached as part of the site details in Appendix One, that there is already development on the west side of Ham Lane at Loder Close and the more recent development Westwood Close.

2.21 It is concluded that a development scheme that fully addresses the proposed and existing policy criteria, thus overcoming the ground of refusal for the previously submitted planning application, is potentially achievable on this site and that as a consequence, the site should not be recommended for deletion but should go forward to Regulation 19 Consultation as an allocated site.

2.22 The final regulation 18 site recommended for deletion by Cabinet was site H1(10); Land south of Sutton Road Langley. ��

2.23 The reasons given, which were amended at the Cabinet meeting on 9 March 2015 following call-in of the decision made on 2 and 4 February, are as follows;

a) in the opinion of the Cabinet the eastern boundary of site H1(5) forms a natural boundary to the edge of the urban area of Maidstone;

b) there should be no further encroachment of residential development into the countryside which would result in the loss of green space and a leisure facility;

c) there would be an unacceptable impact on conditions in the surrounding area where the environmental and amenity consequences for the community are unacceptable now.

2.24 For Councillors� information, a set of revised site development criteria were recommended to Cabinet at their original meetings on 2 and 4 February along with a revised indicative site yield of 850 units. The revised site criteria included the changes from the published Regulation 18 draft as well as an addition to criterion 19 (clause vii)), that was agreed at the meeting of Cabinet on 9 March are set out at Appendix Two;

2.25 It is necessary to re-assess each of the stated reasons for the recommended deletion of the allocation in-turn in considering whether the allocation should be retained.

2.26 Does the adjacent allocated housing site to the west (H1(5), Langley Park Farm, form a natural boundary to the edge of the urban area of Maidstone?� It is acknowledged that the site at Langley Park Farm has a well-defined eastern boundary and that there is some change in character of land to the east of this. However, development along Sutton Road does not stop at this point. On the northern side of the road in particular, there is an almost continuous ribbon of development which extends as far eastwards as Rumwood Green Farm which is host to a number of large and visually prominent packing and storage sheds that dominate the skyline in medium to long distance views.

2.27 The second reason for recommending the site not be allocated relates to the fact that there should be no further encroachment of development into the countryside, which would result in the loss of green space and a leisure facility.

2.28 Councillors should note that as of July 2014, the additionally allocated greenfield sites outside the boundaries in the 2000 Borough-wide Local Plan amounted to some 207.4ha. The total area of countryside in the Borough based on the same 2000 boundaries amounted to 35,879ha. This means that 0.58% of the countryside is being lost to greenfield allocations across the Borough.

2.29 It is acknowledged that development of site H1(10) would result in the loss of the existing golf-driving range. The facility is not included within the list of community facilities for which full justification for loss or replacement is required in the current or emerging local plan. There are also alternative driving ranges available at The Ridge Golf Club, Marriott Tudor Park Golf Course and Staplehurst Golf Centre. It is not considered therefore that the loss of the facility is an overriding factor that would lead to the non-allocation of the wider site.

2.30 The third ground put forward in support of the recommended deletion of the site �states that;

�� there would be an unacceptable impact on conditions in the surrounding area where the environmental and amenity consequences for the community are unacceptable now.�

Cabinet were clearly concerned about the cumulative impact of this development in an area where they considered existing conditions to be unacceptable. No detail as to their specific concerns was given however.

2.31 An additional and sizeable strategic area of publicly accessible open space (approx. 10ha in area) would be secured as part of the development. This would provide not only an appropriate setting to the development but would also ensure that such provision is provided on a comprehensive rather than spread in a piecemeal basis across the development. It is considered that cumulative impact on both the environment and amenity would be addressed through any development proposals. For Councillors� information, the Council has received a formal application seeking a Scoping Opinion for a potential Environmental Impact Assessment for proposed development on this site. (Application ref: 15/504183/EIASCO). If a planning application is submitted it would therefore be submitted with an Environmental Statement (ES). The ES would consider environmental issues as well as a range of other issues including the cumulative impact of the proposed development relative to other committed development in the vicinity.��

2.32 There have been no representations from statutory consultees on applications already submitted and/or approved advising that conditions in the area are such that new development cannot be accepted as it cannot be adequately mitigated.

2.33 It is therefore considered that the site should be retained as an allocation and go forward to Regulation 19 Consultation.��

��

Sites recommended for allocation but not accepted.��

2.34 The following new sites were recommended for allocation for development to Cabinet on 2 and 4 February 2015 but were not accepted by Cabinet.

H1 (57)	Former Astor of Hever School, Oakwood Rd.
H1 (60)	Fant Farm Maidstone
H1 (61)	Land at Cross Keys, Roundwell, Bearsted
H1 (64)	Bell Farm North, East Street Harrietsham
H1 (65)	Land at Lenham Road Headcorn
H1 (66)	Land S of The Parsonage Marden
H1 (67)	Land S of Marden Road Staplehurst
H1 (68)	Land to the N of Henhurst Farm Staplehurst
H1 (69)	Land at Lodge Road Staplehurst

2.35 Cabinet gave reasons for not recommending the allocation of these sites as follows;

H1 (57) � Land at former Astor of Hever Community School, Oakwood Road, Maidstone (60 units)

That this new site be rejected and not be taken forward to Regulation 18 consultation on the grounds that the site is retained for education use and development would be unacceptably compromised by the lack of adequate access.

H1 (60) � Fant Farm, Maidstone (225 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that the site is valuable for agriculture use, and would have an unacceptable impact on the landscape, including the overall shape of the urban area of Maidstone and the unacceptable highways impact for the local community.

H1 (61) � Land at Cross Keys, Roundwell, Bearsted (50 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that development of this site would have an unacceptable impact on hydrology and local flood risk.

H1 (64) � Bell Farm North, East Street, Harrietsham (80 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that the cumulative impact of development having a detrimental effect on the character, size and shape of the village and community due to the increase in size and footprint of the village and unacceptable cumulative impact for the community for education provision, transport and other community infrastructure.

H1 (65) � Land at Lenham Road, Headcorn (50 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that development is in reality impractical due to current water conditions and community perception of failure of infrastructure providers to deliver infrastructure identified as required in the past, local knowledge of flood risk and community concern about the cumulative impact on local education provision and highways.

�� H1 (66) � Land South of the Parsonage, Goudhurst Road, Marden (50 units)

That the recommendation of the Committee be rejected and that this new site not be taken forward to Regulation 18 consultation on the grounds that the site is too peripheral to Marden and on the grounds that the cumulative impact of sites already considered in the draft Local Plan would be unacceptable to the community in terms of highways and water infrastructure and social balance.

H1 (67) � Land to South of Marden Road, Staplehurst (100 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that it has not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Staplehurst and the unacceptable cumulative impact for the community and highways.

H1 (68) � Land to the North of Henhurst Farm, Staplehurst (60 units)

That this new site be rejected and not taken forward to Regulation 18 consultation on the grounds that it has not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Staplehurst and the unacceptable cumulative impact for the community and highways. In addition of community concerns that suitable highways access arrangements cannot be achieved at this point in time.

H1 (69) � Land at Lodge Road, Staplehurst (60 units)

That the recommendation of the Committee be rejected and that this new site should not be taken forward to Regulation 18 consultation on the grounds that the site should be retained for employment use given the economic upturn and that infrastructure must be improved to enable this to happen and the cumulative impact of residential development in Staplehurst on social balance.

2.36 The reasons given for the recommended deletion of each site have been re-assessed, to ascertain whether they are likely to be sustainable under examination and also in the light of decisions made by the Council�s Planning Committee in recent months. As resolved by this Committee on 9 June, site H1(60), Fant Farm, Maidstone has not been reassessed.

2.37 With regard to site H1(57), Land at the former Astor of Hever Community School Oakwood Road Maidstone, the stated reasons for not allocating the site were that the site should be retained for educational use and that development would be unacceptably compromised by the lack of adequate access.

2.38 This site was until 2008/2009 grazing land connected with the school farm attached to the Astor of Hever School. Around 2008/2009, the farm buildings were redeveloped and that part of the site is now occupied by the 21 houses at Astor Park. Since that time, the site has not been used for educational purposes but has remained in the ownership of the site�s promoter KCC.

2.39 The site is very well contained. It is adjoined to the north by a place of worship, to the east by the rear of properties fronting Bower Mount Road, to the south by the rear of properties in Astor Park and to the west by a treed and landscaped steep bank that separates this area of land from the larger playing fields to the west/north west that remain in use by the existing schools on the Oakwood Park campus. If development were to take place on this site given the site�s containment and topography, development would not extend beyond the site area submitted and proposed for allocation.�

2.40 �At first glance, there appear to be two apparently possible access points into the site. These are a strip of land (approximately 12m in width), situated between nos. 58 and 62 Bower Mount Road and secondly, across an open area on the east side of Astor Park.

2.41 The land on Bower Mount Road is not in the ownership of KCC, the site promoter and is also subject to TPO no.6 of 1993 which protects 6 individual pine trees located adjacent to Bower Mount Road and which would preclude construction of an access unless they were felled. The second potential access point would be across the open area east of no.21 Astor Park exiting onto Oakwood Road via the junction of Astor Park and Oakwood Road. KCC have retained rights of access across this land to the proposed site. The access point proposed is via the latter route and will provide a suitable and safe access on to the highway. No objections were raised by Kent Highway Services to the proposed use of this access point when the initial site assessment was undertaken. Any application would be accompanied by a transport assessment and this would indicate any necessary mitigation required to deliver the development. ��

2.42 It is concluded that the reasons given for the non-allocation of this site are not robust and Councillors are recommended to allocate the site for development with an indicative yield of 60 units.

2.43 The� proposed site at H1(61) Land at Cross Keys Roundwell, Bearsted was not allocated by Cabinet on the grounds that development of this site would have an unacceptable impact on hydrology and local flood risk. Councillors will be aware that planning application 14/504795 was reported to the Planning Committee on 16 April 2015. The Committee resolved to grant planning permission subject to the completion of a s106 legal agreement covering a number of obligations. In determining the application the Committee considered the views of Southern Water and the Environment Agency on flood risk. A detailed hydrological assessment had been undertaken by the applicants and submitted with the application. Neither Southern Water nor the Environment Agency raised objections to the development on the grounds of flood risk as the package of mitigation measures set out in the assessment were acceptable.��

2.44 It is therefore concluded that the reasons given for the non-allocation of this site are not robust and Councillors are recommended to allocate the site for development.

2.45 �Proposed site H1(64) related to land at Bell Farm North, East Street� Harrietsham and was not allocated on the grounds that;

�The cumulative impact of development having a detrimental effect on the character, size and shape of the village and community due to the increase in size and footprint of the village and unacceptable cumulative impact for the community for education provision, transport and other community infrastructure.�

2.46 Councillors will be aware that there were four sites proposed for development in the Regulation 18 consultation draft of the emerging Local Plan. One site, Tong�s Meadow is recommended for further Regulation 18 Consultation with a view to its deletion due to Natural England�s advice that they would not be likely to issue an EPS Development Licence, and the site has not been re-assessed as part of this current exercise. The remaining three sites H1 (26) South of Ashford Road, H1 (27) Mayfield Nursery Ashford Road and H1(28) Church Road Harrietsham, are all subject to planning applications that have been considered and approved by the Planning Committee subject to the prior completion of a s106 agreement securing appropriate obligations which include, inter-alia, safety and streetscape improvements to the A20 Ashford Road, healthcare contributions and education contributions.

2.47 It is clear from these decisions that have followed and taking into account consultation with statutory consultees on each application, that development within the settlement is not constrained by an inability to improve infrastructure to mitigate the impact of development.

2.48 Development on this site would not unacceptably extend the footprint of the village. It would, in the manner proposed, be immediately adjacent to the approved development on site H1(26). In addition, a significant area of approximately 4.15ha of open space would also be secured. This would not only maintain an appropriate setting to the East Street Conservation Area and the listed buildings within it, but also provide additional amenity space for the residents of the village living on the south side of the A20.

2.49 It is not considered therefore that the grounds for non-allocation of the site given by Cabinet are sound. The site should be subject to Regulation 18 consultation with a view to its allocation as a development site for 80 dwellings and open space provision.

2.50 Previously recommended site H1(65), relates to an area of land on the north side of Lenham Road Headcorn.� The site is subject to planning application 14/505162 that was considered by the Planning Committee at its meeting on 18 June 2015. It was resolved to grant planning permission subject to the completion of a s106 agreement.

2.51 Similarly, to the sites in the Regulation 18 consultation draft of the emerging Local Plan, appropriate mitigation for drainage, highways and local school provision was identified. It is considered therefore, that this site should be subject to Regulation 18 consultation with a view to its allocation as a development site.

��

2.52 Site H1(66); land to the south of The Parsonage, Goudhurst Road Marden, was not accepted by Cabinet for allocation as they considered that the site was too peripheral to Marden and also on the grounds that the cumulative impact of sites already considered in the draft local plan would be unacceptable to the community in terms of highways, water infrastructure and social balance.

2.53 It is acknowledged that the four allocated sites included in the Local Plan Regulation 18 consultation draft in Marden have all been subject to planning applications that have been considered and approved by the Council�s Planning Committee and that in addition a further site at the MAP Depot Goudhurst Road Marden has also been approved and is in fact under construction. On each of these approvals it has been demonstrated that appropriate mitigation for impact on highway and drainage as well as community facilities can be secured and that no objections were raised by statutory consultees to any of the developments on these grounds. It is considered therefore that given this history that the grounds for non-allocation would not stand-up to examination.

2.54 As to the site�s peripheral location this proposed site is immediately to the south of and would be linked to The Parsonage Goudhurst Road, site H1(34) that has outline planning permission. The site is considered to be very well-related to this proposed development and also sits behind the existing continuous ribbon of development �that fronts Goudhurst Road and is not considered peripheral to the village. The site should therefore be included for Regulation 18 Consultation seeking its allocation for development for 50 dwellings.��

2.55 Site H1(67); land to the South of Marden Road Staplehurst, was not accepted by Cabinet for allocation on the grounds that it has not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Staplehurst and the unacceptable cumulative impact for the community and highways.

2.56 Councillors should be advised that since this decision, application 14/502010 submitted in relation to the Local Plan Regulation 18 consultation draft site H1(36); Hen & Duckhurst Farm, Marden Road Staplehurst, has been considered by the Planning Committee at their meetings on 16 April and 18 June. That Committee resolved to grant outline planning permission for the development subject to appropriate s106 obligations. These obligations would secure appropriate highway mitigation works including at the junction of Marden Road and the A229 High Street and a requirement to safeguard a future possible link from the site through to Lodge Road, education contributions, healthcare contributions and also contributions towards other community facilities and open space facilities as well as a landscape and ecological management plan for the site itself. There were no objections to the proposed methods for foul and surface water drainage from statutory consultees. ��

2.57 �It is considered that in the light of this decision and the fact that no objections were raised on highway capacity or flood risk grounds to the development at Hen & Duckhurst Farm that could not be mitigated, the grounds given for the non-allocation of this site would not stand up to examination given the proposed criteria included within the draft site polices that safeguard the areas of concern. The site should therefore be included for Regulation 18 Consultation seeking its allocation for development for 100 dwellings.� ��

2.58 Site H1(68); land to the north of Henhurst Farm Staplehurst, was not accepted as a draft allocation by Cabinet on the grounds that it had not been demonstrated to the community�s satisfaction that current foul water problems can be resolved and these will be exacerbated by any further development in this part of Staplehurst and the unacceptable cumulative impact for the community and highways. In addition of community concerns that suitable highways access arrangements cannot be achieved at this point in time.

2.59 As set out above, the experience of the assessment of the application submitted at Hen & Duckhurst Farm would indicate that the stated concerns are unlikely to withstand examination given the proposed site criteria. Access to the site would be obtained via Oliver Road and the development currently under construction immediately to the north of this proposed site.

2.60 A key additional benefit of this site would be the securing of an undeveloped area to be used for open space and ecological mitigation and as proven necessary, allotments that would link to the already secured ecological/open space area provided for the Oliver Road development mentioned above. This area would extend to approximately 5.78ha and would provide natural and semi-natural open space for this part of Staplehurst for which there is an identified need. The site should therefore be included for Regulation 18 Consultation seeking its allocation for development for 60 units and the open space provision outlined above.

2.61 Site H1 (69); Land at Lodge Road Staplehurst was not allocated by Cabinet on the grounds that the site should be retained for employment use given the economic upturn and that infrastructure must be improved to enable this to happen and the cumulative impact of residential development in Staplehurst on social balance.

2.62 It is acknowledged that this site has an extant outline planning permission for employment use and is allocated for employment use in the current Maidstone Borough-wide Local Plan 2000. This permission was renewed in 2013 following earlier outline permissions granted in 2007 and 2009 and even earlier permissions in 1996 and 1999. The northern part of the site adjacent to the railway-line was also subject to an employment use permission approved in 2008. This area is also an allocated employment site in the MBWLP 2000. Whilst there has been no action to implement any of the past and current permissions on the two parcels of land, there would nevertheless be a net reduction in available employment land if a mixed-use development was to take place on this site. ��

2.63 However, the allocation of just the southern part of this site for housing would still deliver approximately 10,000m� of employment development on the remainder along with an area of open space centred on a retained existing pond. It is considered therefore that a balanced mixed-use of the site would result that would still allow for further employment related development to take place.

2.64 �Councillors are also referred to the commentary earlier in the report relating to the Hen & Duckhurst Farm site in Marden Road recently considered and approved by Planning Committee. Issues relating to drainage and highways are addressed in paragraph 2.56 and will to be repeated here. It is worth noting however that amongst the conditions to be imposed on the Hen & Duckhurst Farm permission when granted is a requirement for the reserved matters application(s) to safeguard a vehicle route from the site to Lodge Road. Such a route is not safeguarded in the existing employment permission on site H1(69) but would be if the site was allocated as now proposed, however any vehicular access through site H1(69) should be restricted to buses as well as allowing for pedestrian and cycle access rather than allowing use by private cars and HGV vehicles due to the likelihood of �rat-running� through the two new developments occurring. Given the above caveat, the site should therefore be included for Regulation 18 Consultation seeking its allocation for development for 60 dwellings and 10,000m� of employment space with an intervening area of open space/ecological mitigation.

Assessment of sites previously rejected ��on-balance� including sites supported by Parish Councils/Ward Members ��

2.65 This section of the report re-assesses sites which were �on-balance� rejected including those sites supported by Parish Councils/Ward Councillors.�

2.66 When the 2013 SHLAA call for sites exercise was undertaken, a �traffic light� system of assessment� was initially used (Red for rejected sites, Green for accepted sites and Amber for marginal sites). Prior to the consideration by Cabinet and �subsequently the publication of the Regulation 18 consultation draft of the Local Plan, the �Amber� sites were reconsidered and re-categorised. Those that were acceptable were included within the recommendation to Cabinet on 24 February 2014 and subsequently the published Regulation 18 consultation draft or rejected and not recommended to Cabinet.

2.67 The 2014 �call for sites� exercise assessed the sites as either acceptable or not acceptable. Site were recommended for allocation to Cabinet in February/March 2015 on this basis. Submitted as part of the process, an additional seven sites were submitted relating to sites in Lenham.

� HO3-195: Land rear of Loder Close

� HO3-202: Land off Old Ham Lane

� HO3-209: Allotment land between Robins Avenue and Hollywood Road

� HO3-219: Lenham Cricket Pitch Ham Lane

� HO3-221: Grove Paddock

� HO3-294: Land at Tanyard Farm, Old Ashford Road

� HO3-297: Land South of Tanyard Cottages, Old Ashford Road�

Of these, HO3-209 and HO3-219 were rejected due to the unacceptable loss of community facilities without direct replacements being secured.

2.68 The five remaining sites were considered potentially acceptable as development sites but were included within the identified broad location �of Lenham for �development in the latter part of the plan period, beyond 2026. As such, to avoid �double-counting�, none of the remaining sites were recommended for allocation to Cabinet in February 2015. The submitted sites did however, give a good indication of potentially available sites in support of the future broad location for development.

2.69 Councillors are also advised that� site HO3-221: Grove Paddock, is the subject of a current application (14/503411/FULL) for 23 dwellings.

2.70 It is not recommended that additional sites in Lenham are allocated. The broad location will be subject to review at the first review of the Local Plan following its adoption. ��

2.71 Collier Street Parish Council has expressed support for a 2014 SHLAA site that would see the redevelopment of Bentletts commercial vehicle scrapyard in Claygate Road, Laddingford (HO3-270). Clearly such a use could be considered to be non-conforming and at first glance may offer some environmental and visual benefits if it was removed as well as improving the setting of �The Pest House�, a Grade II listed building located at the entrance to the site. The site is currently well screened which also reduces its visual impact to an extent.

2.72 The site is however located in open countryside in an isolated location on a site that does not accord with the proposed settlement hierarchy set out in the draft Local Plan.

2.73 In terms of access to services and public transport the site is also not considered sustainable. The nearest railway stations are; Beltring 4.1km, Yalding 4.5km, Marden 6.2km and Paddock Wood 6.6km, all some distance away from the site. The site and Claygate Road is served by Nu-Venture route 23/26. However, it is a two-hourly service only operating on weekdays. The first bus to Maidstone is 07:10 (not Saturday) and the last bus to Maidstone is16:35. The last bus from Maidstone leaves at 17:40 or 18:20 (on demand after Yalding). As far as shops and community facilities the nearest shops/post office is at Yalding 3.2km away, where there is also a GP surgery. The primary school at Laddingford is 1.6km from the site and the school at Collier Street 2.3km. Claygate Road and the surroundings are unlit and have no pavements and therefore occupiers of the site are highly likely to be reliant on the use of the private car for day-to-day needs.

2.74 Whilst the site itself is not within flood zone 2 or 3 much of the surrounding land together with access roads to the site is. In their representations following the call for sites exercise, the Environment Agency advised that the Council should be aware the site will be isolated during flood conditions, making access and egress by potential occupiers and emergency services very difficult.

2.75 It is considered therefore that the site should not be subject to Regulation 18 consultation with a view to its allocation. Councillors should be aware that there is currently an undetermined planning application for residential development on the site. Clearly the future of the site will be decided through the application determination process.

2.76 The draft Coxheath Neighbourhood Plan includes a proposed housing site immediately to the west of the current village boundary on the north side of the B2163 Heath Road. It is known locally as Older�s Field. Submitted under the 2013 SHLAA/SEDLAA exercise as a mixed use employment and residential site and again in the 2014 SHLAA (HO3-256) exercise but purely for residential. The site was rejected due to the potential coalescence between Coxheath and the settlement in Dean Street and also due to the regenerating heathland growth occurring on the site and potential ecological impact.

2.77 A planning application (MA/13/1979) has been submitted in respect of the site seeking outline permission for the erection of up to 55 dwellings with a new access onto the B2163 and also the transfer/lease of parcels of land adjacent to the site to the Parish Council in accordance with the details in the draft Neighbourhood Plan. A further area of woodland to the north of the site is now subject to a separate planning permission for use as open space. The residential application was reported to the Planning Committee on 18 December 2014 with a recommendation that permission be refused. The Committee resolved however, to defer consideration of the application to

1: Seek additional details of surface water drainage (to address Environment Agency comments;

2: Seek 40% affordable housing with appropriate viability evidence to demonstrate if this is not achievable; and

3: Seek further ecological surveys of the site.

�� In reaching that decision, Councillors did not consider that the site should be refused in principle. This is a material consideration.

2.78 It is a key aim of the neighbourhood plan to provide a �green-necklace� around the village to enable circular walks and also to safeguard against coalescence with neighbouring settlements. The land associated with this application and the large area of land to the north that already has permission for use as open space would form part of the �necklace� on the western side of the village of Coxheath. Kent Highway Services have raised no objections to the development of the site in principle. The discussions with the applicant regarding the level of affordable housing provision are currently on-going but as with other sites the required 40% should be provided unless it can be demonstrated by means of an appropriate viability assessment that a reduced amount can only be provided. Further information regarding potential ecological impact has been submitted and is also being assessed. Any site development criteria would require any site layout to be guided by the results of surveys and could also require appropriate management plans to be put in place.

2.79 Given the support of the Parish Council and the site�s inclusion in the draft Coxheath neighbourhood plan it is now considered, on balance, that the site should be allocated for development and be subject to formal Regulation 18 consultation to that end. A suggested site policy with development criteria is attached at Appendix Five.

2.80 Boughton Monchelsea Parish Council have expressed their desire that a further site at Hubbards Lane (HO3-220), also a rejected 2014 SHLAA site, be allocated for development. The site is actually located within the Loose Parish boundary and is on the eastern side of Hubbards Lane, directly opposite the Cornwallis Academy at the southern end of a ribbon of houses on Hubbards Lane. These form part of the defined settlement of Loose in the current Borough-wide Local Plan 2000.

2.81 The site is part of a larger field in agricultural use (it is currently covered in polytunnels) and is currently bounded by an imperforate and tall mature hedgerow that also forms the boundary with the B2163 Heath Road to the south. The site extends to some 0.4ha in area and has a site frontage to the highway of approximately 50m. a linear development of the site, thus reflecting the character of development to its north may result in 5-8 dwellings. Councillors will be aware that at the northern end of this group of dwellings there is an existing larger allocated site (20 dwellings) subject to policy H1(47) of the Regulation 18 draft that would see development infill the gap between the houses in Hubbards Lane and those in Haste Hill Road.

2.82 It is considered that development of site HO3-220 would not be appropriate due to the fact that a significant length of the existing mature hedgerow would be lost and also that development would be much closer to Heath Road unacceptably extending the existing ribbon of development on Hubbards Lane southwards. Since Cornwallis Academy was redeveloped and the original lower school buildings demolished, there is a greater openness on this section of Hubbards Lane that would be compromised if development were to take place on the site. It is not considered therefore that the site should be allocated for development.��

�� Haynes, Ashford Road Maidstone Policy H1(12)

2.79�� Councillors are advised that due to an oversight, when the submitted representations in response to the 2014 the Regulation 18 Consultation were considered by the Planning Transport & Development Overview and Scrutiny Committee in January and then Cabinet in February/March of this year, a representation on behalf of the owners of this site was not reported and considered.

2.80�� In essence, the representation states that objection is raised to the proposed allocation of the site solely for housing as set out in the Regulation 18 Consultation draft of the local plan on the grounds that this would not be viable or sufficient to fund the relocation of the current businesses on the site to other local sites. The landowner�s preferred option would be for the site to be redeveloped in a mixed retail and residential use as this is considered to give the necessary land value to enable relocation to take place. Some commentary on retail opportunities/provision in Maidstone has been provided in support of the argument that the Haynes site is an appropriate retail site, but no detailed viability information in support of the contention that the site is not viable unless retail provision is included has been supplied.� (The retail representation submitted on the Haynes site during public consultation is addressed in the Retail and Mixed Use report as part of the agenda).

2.81�� In a number of previous pre-application meetings, the site owners and their advisors have been advised by officers that the Haynes site is not a sequentially preferable location for retail development. This remains the case. The site owners and their advisors have again been given the opportunity to submit information as to why they do not consider a 100% residential allocation to be viable and offered the opportunity for further discussion/meetings. It is also understood that the company�s land-holdings on the Parkwood Industrial Estate are in freehold ownership which would if it is the case clearly result in lower land acquisition costs if relocation/rationalisation of this landholding was proposed. No further information has been submitted and the offer of a meeting has not, to-date, been taken up.

2.82�� It is therefore not currently considered appropriate to allocate part of the site for retail development. This sustainable urban brownfield site does, however, remain a suitable site for residential development and should be retained as such, going forward to Regulation 19 Consultation.

�� Bell Farm, North Street, Barming: Policy H1(19)

2.83�� Councillors are advised that as a result of continuing negotiation and consideration of the currently submitted planning application on the site (14/506419/FULL), to ensure appropriate ecological mitigation, a minimum 5m set-back for the development from the street frontage has been secured. The consequence of this is that the development site would extend a further 5m to the west. It is therefore necessary to both amend the existing site plan for policy H1(19) and also to amend criteria 2 of the existing policy in the Regulation 18 Draft to reflect the requirement for the minimum 5m set-back for development from the North Street frontage that has been secured. The changes would then be subject to the forthcoming Regulation 19 Consultation. The amended site plan and revised policy criteria are set out at Appendix 6. ��

3. AVAILABLE OPTIONS

3.1 Councillors have two options to consider.

3.2 Option One: Councillors could consider the re-assessment details set out in section 2 of this report and resolve not to make any changes to the Cabinet decisions made on 2 and 4 February and 9 March 2015.

3.3 Option Two: Councillors could follow the advice and conclusions set out above in section 2 of the report in respect of the Regulation 18 sites Cabinet previously resolved to recommend for deletion, the proposed allocated sites that were not considered appropriate for Regulation 18 consultation by Cabinet, and the sites previously rejected �on-balance� or rejected sites supported by Parish Councils/Ward Members.

4 PREFERRED OPTION AND REASONS FOR RECOMMENDATIONS

4.1 Councillors are recommended to adopt option two.

4.2 In doing so, the gap between the currently identified delivery of 16,664 dwellings and the Objectively Assessed Need figure of 18,560 dwellings between 2011 and 2031, which is 1,896 units, would be addressed. ��The total number of dwellings recommended in the report is 1,877 units.

4.3 Such a course of action would reduce the clear risks of the Local Plan being found unsound at Independent Examination, as outlined in the report considered and also accepted at the last meeting of this Committee on 9 June.��

5.�� CROSS-CUTTING ISSUES AND IMPLICATIONS

Issue	Implications	Sign-off
Impact on Corporate Priorities	The adoption of the local plan will assist in the delivery of the council�s corporate Priorities.	Rob Jarman Head of Planning & Development
Risk Management	A key risk to the local plan programme relates to the council�s ability to meet its objectively assessed housing need. There are a number of risks of not meeting the Objectively Assessed Need	Rob Jarman Head of Planning & Development
Financial	The development of the Local Plan has been fully funded as part of the council�s revenue budget. The total spend from 2006/07 to 2014/15 is �1.8 m. At 31 March 2015, the budget has a balance of �353,480. The base budget for the next 3 years is �60k p.a. plus one-off funding of �480k from New Homes Bonus. The budget does not account for any additional costs arising from the risk that the local plan is found unsound or withdrawn, which would include the preparation of additional evidence, further consultations, and re-examination. This would need to be found from the council�s revenue budget which already has a target to deliver �2.2 m savings in 2016/17 � 2018/19. The council will need to demonstrate financial rigour in terms of decisions that will incur avoidable unbudgeted expenditure.	Zena Cooke, S151 Officer & Ellie Dunnett Finance
Staffing	N/A	Rob Jarman Head of Planning & Development
Legal	There are no legal implications directly arising from this report, although the Legal Team continues to provide advice and guidance on local plan matters, and to review any legal implications of reports	Legal Team
Equality Impact Needs Assessment	N/A	Anna Collier, Policy & Information Manager
Environmental/Sustainable Development	N/A	Rob Jarman Head of Planning & Development
Community Safety	N/A	Rob Jarman Head of Planning & Development
Human Rights Act	N/A	Rob Jarman Head of Planning & Development
Procurement	Consultants are used to prepare specialist or technical evidence to support the local plan and are appointed in accordance with the council�s procurement procedures.	Rob Jarman Head of Planning & Development & Zena Cooke Section 151 Officer
Asset Management	N/A	Rob Jarman Head of Planning & Development

6.�� REPORT APPENDICES

The following documents are to be published with this report and form part of the report:

� Appendix 1: Maps of Maidstone Borough Local Plan Regulation 18 Consultation Draft 2014: Sites recommended for deletion by Cabinet

� Appendix 2: Revised site criteria for site H1 (10) Land South of Sutton Road

� Appendix 3: Maps of sites not recommended for allocation by Cabinet

� Appendix 4: Maps of sites on balance rejected and sites supported by Parish Councils/Ward Councillors

� Appendix 5: Proposed site plan and policy criteria for Land North of Heath Road (Older�s Field) Coxheath.

� Appendix 6: Amended site plan and revised policy criteria for site H1(19): Bell Farm, North Street, Barming.

7. BACKGROUND PAPERS

None

5.����� CROSS-CUTTING ISSUES AND IMPLICATIONS

5.�� CROSS-CUTTING ISSUES AND IMPLICATIONS