MAIDSTONE BOROUGH COUNCIL
RECORD OF DECISION OF THE Cabinet
|
Decision Made: |
25 July 2012 |
Core Strategy Public Participation: Key Issues and Responses
Issue for Decision
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 Made
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;
i)
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;
ii)
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;
iii) 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;
iv) Retain
the five rural service centres of Harrietsham, Headcorn, Lenham, Marden and
Staplehurst;
v)
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;
vi) 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;
vii) Reword the Gypsy and Traveller accommodation policy (CS12) to provide clarity and to include a landscaping criterion; and
viii) That the work that is ongoing to provide for a suitable public site(s) for Gypsy and Traveller accommodation be noted
.
Reasons for 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[2].
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[3].
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[4])
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[5]
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 allocations within 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)[6].
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[7] 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[8],
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[9]
sites that proved difficult to develop[10].
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[11].
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[12]
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[13]
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[14]
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[15]
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.
Alternatives considered and why rejected
Alternative options are contained within the reasons above.
Background Papers
None
Should you be concerned about this decision and wish to call it in, please submit a call in form signed by any two Non-Executive Members to the Head of Change and Scrutiny by: 3 August 2012. |
[2] Town and Country Planning Act (Local Planning) (England) Regulations 2012
[3] Demographic and labour supply forecasts 2010
[4] Town and Country Planning (local Planning) (England) Regulations 2012
[5] Cabinet 9 February 2011
[6] Cabinet 29 September 2010
[7] South East Plan Examination in Public Panel Report (2007)
[8] Cabinet 9 February 2011
[9] Strategic Housing Land Availability Assessment 2009
[10] Strategic Sites Assessment 2009
[11] Annual Monitoring Report 2010/11
[12] Cabinet report on Core Strategy Strategic Site Allocations 25 July 2012
[13] Gypsy and Traveller and Travelling Showpeople Accommodation Assessment 2012
[14] Planning Policy for Traveller Sites March 2012
[15] Cabinet decision 8 June 2011