MAIDSTONE BOROUGH COUNCIL

 

CABINET

 

MONDAY 24 FEBRUARY 2014

 

REPORT OF HEAD OF PLANNING AND DEVELOPMENT

 

Report prepared by Sue Whiteside 

 

 

1.           Maidstone Borough Local Plan Public Consultation Draft (Regulation 18)

 

1.1        Issue for Decision

 

1.1.1   To approve the draft Maidstone Borough Local Plan (attached at Appendix A). This report brings together all of the policies Members have given consideration to in the past year. New parts of the document include the spatial strategy and site allocation policies.  The report considers the borough’s objectively assessed needs, and explains the processes undertaken in the selection of recommended sites for development.

1.1.2   To reject land at Junction 8 of the M20 motorway as a strategic location for employment use.  The full consideration of this site was deferred until further work on employment needs had been completed.

 

1.2        Recommendation of Head of Planning and Development

        

1.2.1   That Cabinet:

 

                i.     Approves the draft Maidstone Borough Local Plan for public consultation (Regulation 18) attached at Appendix A;

 

               ii.     Rejects the designation of land at Junction 8 of the M20 motorway as a strategic location for employment use; and

              iii.     Approves a further call for housing sites and sites for Gypsy and Traveller pitches, as part of the public consultation on the Maidstone Borough Local Plan.

1.3       Introduction

 

1.3.1   This report will be considered by the Planning, Transport and Development Overview and Scrutiny Committee on 18^th February 2014.

 

1.3.2   This report is seeking approval of the preparation draft of the Maidstone Borough Local Plan for public consultation (Regulation 18 consultation).  It is not seeking approval of all of the policies and site allocations in the plan, but an agreement that the local plan is fit for purpose so that the community’s views on the plan can be sought to assist officers and Members in shaping the publication draft of the local plan for subsequent consultation (Regulation 19).

1.3.3   The consultation is due to commence on Friday 21 March 2014 and close on Wednesday 7 May 2014 at 5pm.  A number of events are being planned in accordance with the consultation strategy (agreed by this Committee and Cabinet Member[1]) to encourage as many people as possible to tell the council their views on the document.  Comments submitted during previous public consultations on the core strategy in 2011 and 2012 have helped to develop the policies in this draft local plan and, in the same way, all representations made during this new consultation will be considered and appropriate amendments to the local plan will be recommended.

1.3.4   Cabinet has given consideration to several groups of local plan policies over the past year.  This report brings those policies together in a single document.

1.3.5   New to Members are:

 

·            updated introductory chapters to the plan which reflect the passing of time;

 

·            an amended Maidstone Borough Spatial Strategy (policy SS1) that rolls forward the plan period to 2011-2031 and sets development targets that are based on an updated evidence base. The policy also confirms the distribution strategy for site allocations;

 

·            the balance of land allocations for housing, in addition to the core strategy strategic site allocations (policy H1 and Appendix A in the draft Local Plan document);

 

·            Identification of broad locations for new housing for the latter period of the Local Plan (policy H3 and appendix F in the draft Local Plan document);

 

·            site allocations for Gypsy and Traveller pitches (policy GT1; appendix D in the draft Local Plan document); and

 

·            economic development land allocations for offices, industry and warehousing and mixed use allocations (policies EMP1 and RMX1; appendices B and C in the draft Local Plan document).  The strategic location for medical and retail use at Junction 7 of the M20 and the retail/residential allocation at Maidstone East station and the Royal Mail sorting office was reviewed by this Committee and Cabinet in December 2013.

1.3.6   At its meeting on 27^th January Cabinet decided to defer the consideration of policies SP3 (Rural Services Centres) and SP4 (larger settlements) until information on the proposed housing allocations was available. These proposed site allocations are now included as part of the draft Local Plan appended to this report.  The recommendation on the designation of settlements is unaltered from previous reports; it is advised that Yalding and Coxheath be designated as two of the seven Rural Services Centres and that Boughton Monchelsea, Sutton Valence and Eyehorne Street (Hollingbourne) be designated as Larger Settlements.

 

1.3.7   The consultation draft Maidstone Borough Local Plan contains:

·         Introductory chapters that highlight the documents that have helped to inform the local plan, identify key local issues which the plan needs to address, and set out the council’s spatial vision and objectives for the plan period;

·         The borough wide spatial strategy which sets development targets and explains the factors that influence the distribution of  development;

·         Spatial policies that focus on the town centre, Maidstone urban area, rural services centres, larger settlements and the countryside;

·         Site allocation policies that list the site specific allocations for housing (including future locations growth), retail and mixed use, employment, Gypsy and Traveller pitches, and park and ride;

·         Development management policies that apply across the borough, within the town centre and in the countryside focus on delivering the spatial strategy and set criteria against which planning applications for development are determined;

·         Infrastructure delivery policies which explain what infrastructure is required to support new development; and

·         The housing trajectory which demonstrates how the council will deliver its housing provisions.

1.3.8   There are also a number of appendices that contain individual policies for site allocations and future locations for growth, which clearly set out the infrastructure requirements and mitigation measures that are crucial for each site’s development.  Other appendices include information on monitoring, and matrices showing how plan policies will deliver the priorities of the Maidstone Community Strategy and the objectives of the Maidstone Borough Local Plan.

1.4       Housing needs and the Strategic Housing Land Availability Assessment (SHLAA)

1.4.1   The Strategic Housing Market Assessment 2014 confirmed the objectively assessed housing need for the borough as 19,600 dwellings (980 dwellings per annum).  The Committee and Cabinet agreed this figure in January 2014.  The next step for the council is to determine whether this need can be fully met, which is a requirement of the National Planning Policy Framework (NPPF) unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF taken as a whole, or specific policies in the NPPF indicate development should be restricted.

1.4.2   The Strategic Housing Land Availability Assessment (SHLAA) process commenced with a widely advertised call for sites on 7 December 2012. The call for sites period was initially scheduled to conclude on 25 January 2013, but the deadline was extended to 31 March 2013 because of the number of sites that were submitted after the initial closing date.  The call for sites invited the development industry, landowners and members of the public to submit sites to be considered for allocation in the local plan. An important consideration at the outset of the process was how to assess all submitted sites for housing in a consistent manner.  A detailed pro forma (approved by the Cabinet Member for Planning, Transport and Development, via this Committee) was used to build consistency into the process[2]. 

1.4.3   As part of the SHLAA assessments, site visits were undertaken and key stakeholders and service providers were consulted on all sites.  The results were fed into the pro forma, and officers engaged with parish councils, landowners and the development industry to gather further information on the submissions. The pro forma incorporated a broad range of criteria against which sites were assessed, and included detailed comments on topics such as planning history, landscape, flood risk, highways and ecology.

1.4.4   The assessment process allowed officers to draw initial conclusions on the potential development of sites in an open and consistent manner, examining the availability, locational suitability, achievability, and viability of each site. Locational suitability has influenced the recommended selection of sites: brownfield sites were prioritised first, and then recommended sites were selected for allocation in accordance with the borough’s settlement hierarchy.  Those sites situated in the urban area, edge of urban area[3] or at rural settlements forming part of the council’s settlement hierarchy were considered more suitable and sustainable than those removed from settlements and essentially in the open countryside. The exception to this rule is Syngenta, which is a large brownfield development site in Yalding parish.

1.4.5   Completed site pro forma were the subject of an independent sustainability appraisal (SA) by the expert consultants appointed to undertake the SA on the local plan. The sustainability of each site was appraised against a selection of key assessment criteria and advised on issues to be addressed and potential mitigation and enhancement measures. The SA also assessed the cumulative impact of the draft allocated sites on their immediate locations and at a strategic level.

1.4.6   As part of the SHLAA process, the site assessment exercise has assisted with the selection of recommended site allocations for the draft local plan (54 housing sites in total, out of 190 sites submitted), but it has also informed site allocation policies. For example, consultation with statutory undertakers and infrastructure providers has highlighted on-site and off-site constraints, and the need for additional surveys to fully understand the mitigation measures required to make development acceptable. This has resulted in the inclusion of criteria for mitigation measures in a number of the site allocation policies.  The mitigation measures are wide ranging but in a number of cases include structural landscaping, junction improvements and the identification of site areas where development will be restricted.

1.4.7   The SHLAA process has ensured that the proposed site allocation policies are robust, and SHLAA sites will contribute approximately 10,000 dwellings[4] towards the borough’s objectively assessed housing need over the plan period.  The pro forma for accepted and rejected sites will be available (as part of the council’s evidence base) to support the published SHLAA during public consultation.

1.5       Future locations for housing growth

1.5.1   The council does not need to allocate land to meet all of the borough’s objectively assessed need of 19,600 dwellings because approximately 4,100 homes have already been built since 2011 or have been granted planning permission on sites that are not yet completed, resulting in a net need for 15,500 homes.  The land allocations that are the subject of this consultation total a further 10,000 dwellings, leaving a balance to find of 5,500 dwellings.

1.5.2   The NPPF directs local authorities to identify deliverable[5] housing sites for the first 5 years (it is implied this starts from the date of adoption of a local plan). For years 6 to 10 and, where possible, years 11 to 15 following adoption (i.e. the last 10 years of the Maidstone Borough Local Plan period), sites should be developable[6].  The greater the number of dwellings on sites that are specifically identified as deliverable/developable, the more robust the local plan will be.  However, the NPPF also allows for the identification of broad locations for housing in this latter period.

1.5.3   Three broad development locations yielding a potential 3,000 dwellings have been identified and included in the consultation draft for the latter years of the local plan period.  This will offer the opportunity to review the locations in detail at the first point of regular review of the local plan in 2026.

Invicta Park Barracks

1.5.4   Invicta Park Barracks covers a substantial area (41 ha) to the north of the town centre. It comprises a range of military buildings, including army accommodation, set within expansive parkland. The site is currently home to the 36 Engineer Regiment. The MoD has categorised the site as a ‘retained’ site in its most recent estates review (2013); there are no immediate plans to vacate this site.  The MoD keeps its property portfolio under regular review. It has been confirmed that, in the longer term, there could be some prospect that the site may be declared surplus and so become available for alternative uses.

1.5.5    In recognition of this potential, and the need to plan positively for it, the draft Local Plan identifies Invicta Park Barracks as a broad location for future housing growth for towards the end of the Local Plan period (post 2026). The Barracks site covers is an extensive area and includes expansive undeveloped open and wooded areas. Development will need to be planned to reflect the site’s arcadian nature and the role it could have in providing additional accessible green space in the urban area.  Primarily focused on the redevelopment of existing developed areas, the site has the potential to deliver in the order of 1,300 new homes.

Town Centre

1.5.6   It is acknowledged in the local plan evidence base that there is an oversupply of poorer quality office stock in the town centre which is no longer fit for purpose.  This has the effect of suppressing the town centre office market and thereby inhibiting new development which could better meet modern business needs.  A route to tackle this is to rationalise the supply of the poorest stock through conversion to alternative uses. Over the timeframe of the plan it is expected that the value of the lowest quality office stock, in terms of rents, will fall further making redevelopment for alternative uses increasingly viable.  With a corresponding uplift in the market for town centre apartments, this trend could see the delivery of significant new housing in and around the town centre.  In view of the market shifts needed, delivery is likely to be phased towards the end of the plan period.  The town centre broad location is considered to have the potential to deliver in the order of 200 additional homes.

Lenham Rural Service Centre

1.5.7   Lenham is a compact settlement surrounded by flat, arable land.  The village benefits from a good range of infrastructure and facilities, including a primary school, secondary school, train station, village hall, local shops, and a medical centre.  The village has access to employment opportunities locally, and good rail and bus links to Maidstone and Ashford towns.  The village has easy access to the A20 which leads to Junction 8 of the M20 motorway.

1.5.8   There is potential for the village to expand.  There are no known major constraints to the provision of additional housing development, although further studies are likely to be required to assess the impact of development on the environment and to identify the mitigation measures necessary for any proposals to proceed.  Impacts on the setting of the AONB will need careful assessment. There are no known flooding issues in the location.  Land is available to the east and west of the village that has potential to deliver in the region of 1,500 dwellings recognising the need to avoid the coalescence of the village with neighboring Harrietsham.

1.6        Unmet housing need

1.6.1   The borough’s objectively assessed housing need is 19,600 dwellings.  Since 2011, approximately 4,100 units have been built or are in the pipeline.  The recommended housing land allocations in the draft local plan yield a further 10,000 homes, and broad locations 3,000 dwellings.  The balance of unmet need is therefore in the region of 2,500 dwellings.

1.6.2   At examination, the council will have to demonstrate why its full housing need cannot be met.  Constraints to development will have to be robustly defended[7] and evidence produced to demonstrate what measures have been taken to address unmet need.

1.6.3   It is recommended that a further call for sites be undertaken as part of the public consultation exercise, to establish whether there are additional sites suitable for development that have not yet been subject to the SHLAA process. At the time of the deadline for the Call for Sites, the agreed ‘working’ housing target was some 14,800 dwellings (2011-31)[8], appreciably below the 19,600 objectively assessed needs figure now in place. A further call for sites exercise will ensure that sites are submitted in full knowledge of the up to date evidence-based needs figure. Alongside this exercise, an appraisal of reasons why SHLAA sites were rejected should be undertaken to establish whether additional mitigation measures could release rejected sites for development.

1.6.4   Ultimately, if objectively assessed need is not met, then a strong case of constraints, substantiated with evidence (for example of infrastructure capacity)  must be made and, under the duty to cooperate, the council must demonstrate whether unmet need can be satisfied by neighbouring authorities.  It is important to note that some adjoining authorities are likely to be more constrained than Maidstone, particularly by national designations such as the AONB and Green Belt.  Also, to be aware that those authorities may in fact look to Maidstone to accommodate their unmet housing need.

1.6.5   A similar position arises with the provision of sites to accommodate Gypsy and Traveller pitches and Travelling Showpeople plots.  Allocations are proposed for some 23 Gypsy and Traveller pitches in the draft Local Plan. With the  addition of the 57 pitches granted permanent consent since October 2011, and the potential 15 pitches which the Homes and Communities Agency-funded new public site would deliver, there is a shortfall of some 92 pitches against the total requirement for 187 pitches (2011-31). A further call for sites to address the needs of these communities should be undertaken in tandem with a call for market housing sites.

	Need	Supply	Unmet need
Gypsy & Traveller pitches	187	95	92
Travelling Showpeople plots	11	0	11

1.7        Employment land needs and Junction 8

Background

1.7.1   The draft Core Strategy (2011) published for public consultation in September 2011 identified Junction 8 of the M20 motorway as a strategic location for employment. At that time, based on the scale of employment land requirements (Employment Land Review Partial Update 2011) it was considered that land at Junction 8 would be required in addition to a dispersed pattern of smaller sites to accommodate industrial and warehousing floorspace.

1.7.2   In July 2012 Cabinet considered the main issues raised in the public consultation on the Core Strategy. As reported at the time, there was support from the public and the development industry for the identification of Junction 8 of the M20 motorway as an employment location (22 respondents or 5%). There were also suggestions that this location could accommodate housing or mixed use development for housing and employment. There was a high level of opposition to development at Junction 8 from local residents (254 respondents or 52%), who objected on the grounds of the KIG appeal decision, the impact on the landscape, the loss of Special Landscape Area protection, increased traffic congestion, and the provision of low skilled jobs in this location. Alternative employment sites were proposed by respondents (but not the landowners) at Detling Airfield Estate, Park Wood and Hermitage Lane.

1.7.3   The same Cabinet report concluded that Junction 8 would be the best location for a critical mass of employment uses, including premier office development, industry and warehouse uses, of a quantity that would enable the delivery of the necessary supporting infrastructure whilst also providing for a qualitative scheme in a parkland setting to help mitigate the impact of development on the landscape. The location also has transport capacity.

1.7.4   Cabinet resolved to retain Junction 8 of the M20 motorway as a strategic location for economic development to address qualitative and quantitative employment needs and the aspirations of the Council (as set out in the Economic Development Strategy 2008), pending further consultation as part of the Strategic Site Allocations consultation in August/September 2012, to enable a more informed decision to be made on the allocation of strategic site(s) at this location.

1.7.5   In March 2013 the outcomes of the strategic sites public consultation were reported to Cabinet. The issues raised in connection with Junction 8 were wide ranging and, to a large extent, focused on public opposition to the principle of development in this location. The main issues raised included the questioning of the need for the development, the availability of alternative sites within and outside the borough, impact on the AONB,  impact on the highway network, the loss of countryside, the sustainability (or otherwise) of the location, precedent and concerns over the quality of jobs which would be generated.

1.7.6   In the same report Cabinet was presented with an update of the borough’s employment land demand (based on delivering interim housing provisions of 14,800 dwellings up to 2031). The updated evidence pointed to a more modest requirement for employment land overall than previously, with a particular emphasis on office uses. Based on this updated evidence, the justification to release employment land at Junction 8 became less clear cut than it had been previously.

1.7.7   Cabinet took the decision to retain Junction 8 as a strategic development location for employment until such time as the work identifying employment land demand (employment land forecasting) and supply (the Strategic Economic Development Land Availability Assessment) was completed.

Employment land requirements

1.7.8   As reported to Cabinet on 27 January 2014, a further employment land forecast has been undertaken to cover the plan period (2011-31). As well as the basis for employment land forecasting, this work was also the starting point for the ‘economic-led’ housing projection in the SHMA, enabling consistency across the Council’s evidence base.

1.7.9   This forecast has stemmed from a sectoral analysis of the economy, critically analysing which sectors are likely to grow and which are contracting. The analysis specifically tries to identify sectors where the potential for growth at above a ‘business as usual’ level. In this respect the forecast is ambitious.  The analysis also allows for the direct and indirect jobs that will be created as a result of the specific Kent Institute of Medicine and Surgery and Maidstone Medical Campus development. This is a specific proposal which will provide a wider catalyst to growth.

1.7.10                 The analysis looks across all the sectors in the local economy.  This growth is then translated into an employment land demand figure for just those sectors which will require office, industrial/manufacturing and warehouse/distribution premises in the future (i.e. B use classes).

1.7.11                 The total floorspace demand figure for the whole Local Plan period is shown in the first line of the table below. Whilst the greatest amount of floorspace will be needed for distribution/warehousing uses, these are land hungry uses.  Office based development will actually be far more significant in terms of the number of the new jobs generated.

2011-2031	Offices	Industrial	Warehousing	TOTAL
Total floorspace requirement (m2)	39,830	20,290	49,911	110,030
Jobs	3,053	226	453	3,733
% B class jobs	82%	6%	12%	100%

Table: Total floorspace requirements and jobs (excluding KIMS/Medical Campus)

 

1.7.12                 This requirement is for the full 20 year period of the Local Plan.  The net requirement to be addressed in the Local Plan results when the following supply factors are deducted:

 

·         Completions achieved in 11/12 and 12/13

·         Sites with planning permission^[9]

·         Vacant premises^[10]

1.7.13                 The net floorspace/land forecast is set out in the bottom row of the table below.  This requirement is additional to the land already identified and granted permission for the KIMS/Maidstone medical Campus proposals.

	Office	Industrial	Warehousing
Total floorspace Requirement (m2) 2011-31	39,830	20,290	49,911
Supply (m2)	24,247[11]	16,595	36,964
Net floorspace requirement  (m2) 2013-31	15,583	3,695	12,947

Table: Net employment land requirement 2013-2031



Strategic Economic Development Land Availability Assessment (SEDLAA)

 

1.7.14                 The SEDLAA has been undertaken in parallel with the SHLAA.  Some 37 sites were assessed for their potential for employment, retail or mixed use. The submitted sites included two sites at Junction 8: land at Woodcut Farm and Waterside Park.

1.7.15                 The sites were assessed following the agreed criteria in the SEDLAA assessment pro forma^[12].  As for the SHLAA, the expert input of key statutory consultees was sought (Kent Highways; EA; KCC ecology; KCC archaeology).

1.7.16                 Based on the SEDLAA assessment, the new industrial and warehousing floorspace required could be delivered in a dispersed pattern of new employment allocations.  This would include the expansion of the existing successful industrial estates at Pattenden Lane, Marden and at Barradale Farm, near Headcorn.  Mixed employment and residential allocations would be made at Syngenta, Yalding, helping to bring forward a brownfield site previously in employment use, and at Clockhouse Farm, Coxheath. This dispersed selection of sites would meet and indeed exceed the floorspace needs for industrial and warehousing space in the borough across a number of locations, providing some flexibility and choice and enabling the local expansion of firms.  Further, the sites at Marden for example could be used for manufacturing type uses or distribution and it would be appropriate to allocate such sites for either use, again to allow for flexibility.  It is recommended that all these sites are appropriate for allocation in the draft Maidstone Borough Local Plan, with necessary mitigation measures set out in the site specific allocation policies.

1.7.17                 Either of the two sites submitted at the Junction 8 location could accommodate the full requirement for industrial and warehousing floorspace.

1.7.18                 Junction 8 is currently a countryside location, removed from the built up area of Maidstone. Development of either of these candidate sites would substantially alter their established character. The existing urban influence in the vicinity of the Woodcut Farm site is slightly greater, provided by the residential and small commercial development along the A20 and the road interchange itself. However its development would significantly alter the immediate rural character of the site and the inherent attractiveness that these fields have as an area of undeveloped countryside located on key routes into, and past, Maidstone.

1.7.19                The vicinity of the Waterside Park site is more rural in character. The site appears as a component of the rolling countryside to the south, particularly in views from the south and from the public right of way which crosses it.

1.7.20                The Woodcut Farm site forms part of the setting of the Kent Downs Area of Outstanding Natural Beauty (AONB) and represents a continuation of the landform of the North Downs. It is also visible, at a distance, from points in the AONB. Development would have an adverse effect on the setting of the AONB. Views from the AONB of Waterside Park are comparatively more limited whilst, in views from the south, the site is clearly seen as part of the foreground to the scarp slope of the AONB.

1.7.21                Officers have previously advised that the size and characteristics of the Woodcut Farm site do offer an opportunity for the landscape impacts of development to be mitigated^[13]. This could be achieved by ensuring the existing topography of the site is respected through minimal site levelling, through significant additional structural landscaping and through careful design in terms of the buildings’ scale, siting, orientation and materials. The context for this advice was a substantive and over-riding need for additional industrial and warehousing development which could not be met on alternative sites.

1.7.22                 To develop the Waterside Park site would require extensive excavation which would be a substantial and unavoidable alteration to the prevailing form of the landscape. There is significantly less opportunity on this site to soften the impacts of development through enhanced landscaping.

1.7.23                 Development of either site would cause substantial landscape harm. Further, Junction 8 is removed from the existing built up area from Maidstone.  The sites are in a relatively unsustainable rural location.  An allocation here would create a new employment destination in a location poorly served by public transport and relatively removed from centres of population and the attendant workforce. These sites are within walking and cycling distance of few residential areas and development of either is likely to particularly attract car-borne workers.

Qualitative need and market considerations

1.7.24                The NPPF directs that local planning authorities need to assess both the qualitative as well as the quantitative need for employment land when drawing up their Local Plans (para 161).  Qualitative considerations are set out below.

1.7.25                Connections to the strategic road network: The Junction 8 location clearly has very close access to M20 and thereafter the wider strategic road network. This is an attractive factor for businesses for business efficiency reasons, and HGV movements on local roads would be more limited. The dispersed selection of sites are located at a distance from the strategic road network. Their development is likely to result in more/longer HGV movements on local roads although it is of note that KCC Highways has not objected to their potential allocation.  Key routes to the M20 from Marden (A229) and Headcorn (A274) require HGVs to pass through Maidstone town centre which is a constraint.  The Syngenta site has a more direct connection to J4 of the M20 via the A228. Experimental Traffic Regulation Orders have been made around Marden and Yalding with the aim of directing lorries in excess of 7.5 tonnes away from this area and on to the main road network. The Joint Transport Board has recently recommended that this order be retained[14]. If made permanent, this risks reducing the attractiveness of the area for businesses as it increases journey times and adds fuel and driver time costs for some deliveries and exports.

 

1.7.26                Price: Premises at Junction 8 will be more expensive to purchase/let because of their motorway location. In contrast with a dispersed pattern of development, sites are likely to be more affordable for a wider range of firms.

 

1.7.27                Range of sites: A site at Junction 8 will be in a single ownership but could be delivered in phases to help stagger supply. The dispersed pattern offers a choice of sites in different locations. It offers a wider geographical spread of potential sites, in different ownerships which could come forward at different times over the plan period in response to demand. 

 

1.7.28                Site capacity: A site at Junction 8 will be capable of meeting larger scale needs, as well as smaller scale requirements.  The dispersed sites are less likely to be able to accommodate a single, large end user.  

 

1.7.29                Market Interest: there is clear, current market interest to deliver and occupy new employment floorspace at Junction 8. The site is likely to be more attractive to inward investors than the dispersed sites. Market demand analysis in the Employment Land Review (2013) however suggests that demand for both industrial and warehousing is more likely to be locally generated (existing firms expanding) or of a sub-regional nature. 

 

1.7.30                Existing/new business locations: Development at Junction 8 would create a brand new business location and could provide a prestigious, business park form of development and a new business ‘offer’ for the borough.  The dispersed pattern provides for the localised expansion of existing successful business locations. It could better enable the expansion of firms in situ, and potentially better serve established, local firms.  

 

1.7.31                Promotion of the borough as a business location: A single large site at Junction 8 (in addition to Junction 7) will bring a significant marketing opportunity to promote the borough as a business location. A diversity of smaller sites is likely to be much less marketable.

Conclusion

1.7.32                 Junction 8 as a location for new employment floorspace has some has significant, qualitative advantages. Key is its location immediately adjacent to the strategic road network.  This helps to drive its market attractiveness and will serve to control HGV movements on local roads.  It is the case that a site at Junction 8 is much more likely to be attractive to an inward investor and would be a more prestigious site for the promotion of the borough. This is a significant consideration; one of the council’s three key objectives is for Maidstone to have a growing economy.

 

1.7.33                However, it is considered that the harm caused by development in the location of Junction 8 would be substantial, in particular in terms of impacts on the AONB and the wider landscape. Local Planning Authorities have a duty to have regard to the conservation and enhancement of the natural beauty of AONB landscapes. This duty equally applies to development proposals outside the boundary of an AONB but which may impact on the designated qualities of the AONB[15].  Coupled with the relative unsustainability of Junction 8 as a new employment location, the harm caused by development here is not considered to be over-ridden by the acknowledged qualitative benefits.

Office requirements

1.7.34                 There is a net requirement for some 15,583m² of new office space over the plan period.  The NPPF directs a town centre first approach to new office development.  There has been no significant new office development delivered in or close to the town centre since the County Gate scheme in the late 1990s, despite planning permissions being granted. In contrast there is over-supply of poorer quality stock. In the first instance this oversupply needs to be rationalised through the conversion of offices to alternative uses.  To this end the draft Local Plan seeks to protect only the better quality office locations as ‘economic development areas’ (Policy DM18).

1.7.35                There is the opportunity to allocate land at Mote Road, Maidstone to provide substantive new town centre offices over the timescale of the Plan. Clockhouse Farm at Coxheath can also provide for an element of office space as part of its mixed use allocation.

1.7.36                With these allocations confirmed, there is a shortfall in of some 5,483m² on measured requirements (equating to 14% of the total requirement or 39% of the net requirement).

1.7.37                As set out, there is a lack of current demand for speculative office development. As and when market demand returns, there is considerable immediate capacity at Eclipse Park (some 7,071m² permitted plus 3,500m² additional capacity). Some general office space (24,750m²) will also be delivered as part of the Maidstone Medical Campus which has outline permission.  The market analysis in the Employment Land Review (2013) highlights that as demand picks up sites such as Eclipse Park, coupled with the rationalisation of the town centre stock, will be able to deliver new flexible, modern floorspace. There is therefore considerable short term (pipeline) and future planned supply of new, modern office space.

1.7.38                Additionally, the ancillary office space provided as part of industrial/warehousing development will contribute to the identified requirement.

1.8        The Spatial Strategy (Policy SS1)  and Sustainability Appraisal

1.8.1   There have been a number of iterations of the Sustainability Appraisal as the local plan has developed. These iterations have produced recommendations which have, in turn, helped to shape the local plan policies. The following examples show some instances where this has been the case:

·         Policy DM2 (sustainable design standards) was amended following a recommendation from the SA that the wording could be strengthened in relation to the Code for Sustainable Homes, BREEAM and stress on water resources;

·         Policy DM4 (principles of good design) was amended following a recommendation from the SA that the policy would be enhanced through explicitly identifying the need for development proposals to be designed to ensure that the borough’s biodiversity and geodiversity features are protected and enhanced; and

·         The SA highlighted the fact that that a number of employment sites fell within flood zone 3b, and recommended that policies be amended to emphasise the need to avoid new development within areas at risk from flooding, or to mitigate any potential impacts of new development within areas at risk from flooding.

1.8.2   The local plan sets out a clear settlement hierarchy for determining which locations are the most sustainable for allocating new development sites.  Following the redevelopment of brownfield sites within settlement boundaries, the most sustainable location for greenfield development is adjacent to the currently defined^[16] urban boundary, where access to services is greatest and best use can be made of existing infrastructure.  Rural service centres are the most sustainable villages and form the second tier in the settlement hierarchy because they act as a focal point for trade and services for wider communities, providing a concentration of public transport, employment and community facilities.  Larger settlements form the third tier of the settlement hierarchy and can accommodate limited development, where appropriate, having a smaller range of services than rural service centres, but still meeting the day-to-day needs of local communities.

1.8.3   Within this settlement hierarchy there are options for the distribution of development, and alternative strategies must be considered as part of the local plan process.

1.8.4   The emerging sustainability appraisal (SA) has appraised various housing options that follow the settlement hierarchy, but has also assessed the impact of the Golding Homes’ proposal for a new settlement^[17], which was submitted during the call for sites.  The SA appraised three targets for housing: 19,600 dwellings (objectively assessed need), 17,100 dwellings (draft capacity to date including broad locations for development), and 14,100 dwellings (draft capacity to date excluding broad locations for development).  The targets were assessed against the various distribution options for development: a dispersed pattern of development, with and without broad locations for development and/or the new settlement.  This compares the local plan strategy of development dispersal with an alternative of a new settlement together with a reduced dispersal of development.  These options were tested against their ability to deliver the objectively assessed need for housing, but were balanced by sustainability indicators including flooding, health, poverty, education, congestion, climate change, biodiversity, countryside, heritage, waste, energy and economy.

Table 3: Sustainability Appraisal of housing development options
1	19,600	Dispersed and broad locations
2	19,600	Dispersed, broad locations and a new settlement
3	17,100	Dispersed and broad locations
4	17,100	Dispersed and new settlement
5	14,100	Dispersed only
6	14,100	Dispersed and a new settlement

 

1.8.5   The emerging results show that, on balance, alternatives 5 and 6 would fail to meet the housing need for the borough, leading to negative impacts on the economy, health and wellbeing in the longer term. Alternatives 1 and 2 would have a more pronounced positive impact on housing and economic factors, but adverse impacts on levels of congestion would be more likely. Options 1 and 2 could also lead to an oversupply of housing compared to the level of jobs planned for. In combination, these factors could have negative implications for the wider local economy, health and wellbeing.  Alternatives 3 and 4 may not quite meet the identified housing need, but would be likely to have a less severe impact in terms of congestion and other environmental impacts. These two options are also likely to be more suitably matched to the number of projected jobs.   However, due to the constraints and uncertainties associated with the delivery of a new settlement, the SA concludes that alternative 3 is more favourable than alternative 4.

1.8.6   Based on all known sites at this point, the SA supports the local plan strategy of providing for 17,100 dwellings in a dispersed distribution pattern of development supported by the identified broad locations for future housing growth.

1.8.7   Additionally, the SA has examined two employment distribution options: the local plan dispersed strategy and one of concentration at Junction 8.

Table 4: Sustainability Appraisal of employment development options
Option	Employment provision (m2)	Distribution pattern
A	Office – 39,830 Industrial – 20,290 Warehousing – 49,911 Medical – 98,000	Concentrated (town centre, J7 and J8)
B	Office – 39,830 Industrial – 20,290 Warehousing – 49,911 Medical – 98,000	Dispersed (town centre, J7 and RSCs)

 

1.8.8   The emerging results show that both alternatives would have a significant positive impact by increasing the quantity and quality of employment opportunities. There would also be benefits in terms of increased opportunities to develop skills in the health sector in particular.

1.8.9   Both options would help to tackle deprivation by providing jobs in close proximity to areas of need. This is particularly the case for alternative A. However, there is a danger that increased movements into the Maidstone urban area could exacerbate existing congestion and air quality issues, having an effect on the wider local economy and health. These effects would be less pronounced for alternative B, which would disperse an element of employment to a number of settlements to the south of the urban area. This dispersal strategy would also support the local economies in a number of service centres, but might not attract high-profile development.

1.8.10                Alternative A could have a significant negative impact on landscape character due to the location of the Junction 8 site in relation to the Kent Downs AONB. Although alternative B could still lead to localised impacts on character around a number of settlements, the impacts are considered less significant. Both alternatives make little use of previously developed land and would lead to the loss of grade 2 and 3 agricultural land.

1.8.11                The SA concluded that, on balance, alternative B (the local plan strategy) has fewer impacts on congestion, countryside and heritage

1.8.12                The SA highlighted the fact that proposed mixed use development at Syngenta, Yalding, is within areas at significant risk of flooding.  This has been recorded as a negative impact for alterative B, but mitigation measures can be implemented to avoid negative impacts.

1.8.13                The spatial strategy (policy SS1) sets housing provisions of 17,100 dwellings, to be delivered in a dispersed distribution pattern of development.  Employment provisions are also met through a dispersed strategy.  Both options are supported by the interim sustainability appraisal, including the balance of new jobs and homes.

1.8.14                The sustainability appraisal will continue to evolve with the local plan, and the interim SA will be published as part of the evidence base during public consultation.

1.9        Affordable Housing (Policy DM24)

1.9.1   The 2014 Strategic Housing Market Assessment (SHMA) identifies the affordable housing need in the borough, for the period 2013 to 2031, as 322 per annum. It is important to note the reasons for the change in affordable housing need arising from the new study compared to the need identified in 2010.

1.9.2   The 2010 SHMA identified an annual affordable housing need of 1,081 homes. This change in need can be attributed primarily to the methodology used. The 2010 methodology sought to address affordable need in a five year time period, rather than across the period of the local plan. Where the need is significant, as was identified in the 2010 SHMA, this approach causes difficulties in attempting to meet that need through policy targets. The 2010 SHMA did recognise this and offered an alternative approach that addressed needs across the plan period – based on the then housing target of 11,080 [for the period 2006-2026], it recommended a target of 38%.

1.9.3   In the four years between the studies, the baseline conditions in the borough have also changed, each affecting the affordable need figure. The 2011 Census showed that the population of the borough has increased further than the Office for National Statistics had previously estimated. The list of people on the housing register has changed, mainly through a change in the housing allocation policy, which has restricted access to the register (April 2013). The amount of affordable housing stock has increased in the intervening period as a result of development in the borough. Consequently, the 2014 SHMA recommends that a 30% target across the borough would be appropriate to meet affordable need.

1.9.4   The 2013 Local Plan Viability Testing identified that the following affordable housing targets were achievable in viability terms:

 

·         Previously developed land (urban) – 15%

·         Greenfield and private residential land (urban and urban periphery) – 30%

·         Countryside, rural service centres and larger villages – 40%

This viability information means that if the targets for these areas were set higher, affordable housing could still only be delivered at these rates.

 

1.9.5   Using this information in conjunction with capacity based potential development splits to these broad geographical areas, 4,144 affordable units could be expected to be delivered for the period 2013-2031. In addition to the 427 units in the pipeline, this equates to 254 units per annum, a shortfall of 68 units against the identified annual affordable need. It is reasonable to expect that this shortfall could be addressed by the private rented sector, based on current estimated lettings levels.

 

1.9.6   Drawing on the evidence in the 2014 SHMA, the proposed tenure split in Policy DM24 has been amended, with agreement from the council’s housing department, to seek not less that 65% affordable rented housing, social rented housing, or a mixture of the two. The balance of up to 35% of affordable dwellings delivered will be intermediate affordable housing (shared ownership and/or intermediate rent

 

1.10     Countryside (Policy SP5)

 

1.10.1                Policy SP5 (Countryside) has been amended to include a map that identifies the borough’s landscapes of local importance, namely the Greensand Ridge, Medway Valley, Loose Valley and Len Valley. These landscapes were highlighted as areas of local importance by the public through previous consultation. The council will, where possible, protect its most sensitive landscapes that are in good condition, in accordance with the Landscape Character Assessment.

 

 

 

 

1.11    Alternative Action and why not Recommended

 

1.11.1                 Alternative courses of action are discussed throughout the report.

 

1.12    Impact on Corporate Objectives

 

1.12.1                 The Maidstone Borough Local Plan supports the delivery of the spatial objectives of the Maidstone Community Strategy and the Strategic Plan.  It also has regard to objectives set out in other corporate documents, in particular the Housing Strategy.  The local plan supports the council’s priorities for Maidstone to have a growing economy and to be a decent place to live, and the consultation processes will strive to meet corporate and customer excellence.

 

1.13    Risk Management

1.13.1                 The council still has a local planning policy framework that comprises adopted development plan documents and supplementary planning documents, endorsed guidance, and saved policies from the Maidstone Borough Wide Local Plan 2000.  These policies are still relevant and carry weight in the decision making processes provided there is no conflict with the National Planning Policy Framework (NPPF).  However, the council has a duty to maintain an up-to-date policy framework, and current policies are increasingly becoming outdated or are in conflict with the NPPF.  It is important to maintain the momentum for the preparation of the Maidstone Borough Local Plan and to reach a consensus that the local plan is fit for public consultation.

1.13.2                 The retention of legal and professional services to guide the local plan through its preparation stages, and the production of up-to-date robust technical evidence will ensure the Maidstone Borough Local Plan is found sound at examination.

 

1.14    Other Implications

 

1.14.1                 

1.      Financial	X
2.           Staffing	X
3.           Legal	X
4.           Equality Impact Needs Assessment	X
5.           Environmental/Sustainable Development	X
6.           Community Safety
7.           Human Rights Act
8.           Procurement	X
9.           Asset Management

 

 

1.14.2                 Financial: A dedicated budget has been identified to undertake the work relating to the preparation of the local plan.  The costs of public consultation can be accommodated within that budget.

1.14.3                 Staffing: The public consultation on the Maidstone Borough Local Plan can be managed within existing staff resources.

 

1.14.4                 Legal: Legal services have been retained to offer advice on document content and processes to ensure the Maidstone Borough Local Plan is found sound at examination.  A number of meetings have been held with Counsel and the Head of Legal Services.  These services can be managed within the existing budget for local plan production.

1.14.5                 Equalities Impact Assessment: the consultation process will engage with all individuals and communities in accordance with the equalities legislation and the council’s equalities policy.

 

1.14.6                 Procurement: Although additional evidence base work has been prepared in-house where possible, it is necessary to employ consultants on short term contracts to undertake specialist pieces of work.  Appointments are in accordance with the Council’s procurement procedures and the costs can be managed within the existing budget for local plan production.

 

1.14.7                 Environmental/sustainable development: A sustainability appraisal, incorporating a strategic environmental assessment, is required for all local plan policies including site allocations.  Consultants have been appointed to undertake this technical exercise, and costs can be managed within the existing budget for local plan production.  The sustainability appraisal is an iterative process, and the draft Maidstone Borough Local Plan has undergone initial appraisal.

 

1.15    Relevant Documents

Maidstone Borough Local Plan 2014 evidence base http://www.maidstone.gov.uk/residents/planning/local-plan

 

1.15.1                Appendices

Appendix A: Maidstone Borough Local Plan – Preparation (Regulation 18) 2014

 

1.15.2                Background Documents

None

 

IS THIS A KEY DECISION REPORT?                  THIS BOX MUST BE COMPLETED    X     Yes                                               No     If yes, this is a Key Decision because: The report affects local plan policies, plans and strategies     Wards/Parishes affected: All wards and parishes