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Decision details
Maidstone Borough Local Plan Public Consultation Draft (Regulation 18)
Decision Maker: Cabinet.
Decision status: Recommendations Approved
Is Key decision?: Yes
Is subject to call in?: Yes
Purpose:
To seek approval to undertake public consultation (Regulation 18) on the draft Maidstone Borough Local Plan.
Decision:
a)
That the draft Maidstone Borough Local Plan, as
attached at Appendix A to the report of the Head of Planning and
Development, be approved for public consultation (Regulation 18)
subject to:-
i) The deletion of the following
housing sites:-
H1(18) Cross Keys,
Bearsted
H1(19) Fant Farm, Maidstone
H1(51) Cripple Street, Loose
H1(58) Ware Street, Thurnham
ii) That Yalding and
Coxheath be reclassified as larger villages;
iii) That paragraph 14.10
be revised to reflect the top priority for
Community Infrastructure Levy (CIL) resources being transport;
iv) That paragraph 1 of SP5 be amended to read “Provided proposals do not harm the character…..”;
v) That under H1(7) paragraph 13, v. be amended to read “widening Gore Court Road to a suitable width to accommodate contra-flow traffic and a footway on the eastern side of the carriageway between White Horse Lane and the access into the north of Sutton Road site” and this be repeated in each of the site allocation policies for the South East sites, as well as the removal of paragraph 11 from H1(7);
vi) That H1(17) be amended to include a landscaping and buffer zone to protect the amenity of residents to the South and to retain the character of the lane itself as a country lane; and
vii) That paragraph 11 of Key
Local Issues (top of Page 9 of the Local Plan) be amended to
read:-
“Ensuring that applications for development adequately
address:-
(a) the impact of climate change;
(b) the issues of flooding and water supply; and
(c) ensure dependable infrastructure is included for the
removal
of sewage and waste
water”
b)
That further transport modelling will be undertaken
in the near future be noted;
c)
That the designation of land at Junction 8 of the
M20 motorway as a strategic location for employment use be
rejected;
d)
That 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, a review of the currently
rejected housing sites and further consideration of additional
housing in the town centre, be agreed;
e)
That the recommendations set out in the Urgent
Update circulated at the meeting be agreed; and
f) That the responses to the SCRAIP (attached as Appendix A) be agreed.
Reasons for the decision:
The report of the Head of Planning and Development was considered by the Planning, Transport and Development Overview & Scrutiny Committee on 18 February 2014 and their recommendations were considered by Cabinet and responses were agreed and are set out in Appendix A to this decision.
The
Cabinet considered the report of the Head of Planning and
Development seeking approval of the preparation draft of the
Maidstone Borough Local Plan for public consultation (Regulation 18
consultation), together with the Urgent Update circulated at the
meeting. It was 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).
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 the 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.
Cabinet
has given consideration to several groups of local plan policies
over the past year. The report of the
Head of Planning and Development brought those policies together in
a single document.
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.
At its meeting on 27th January Cabinet decided to defer the consideration of policies SP3 (Rural Services Centres) and SP4 (larger settlements) until information on the proposed housing allocations were available. These proposed site allocations are now included as part of the draft Local Plan. The recommendation on the designation of settlements were unaltered from previous reports; it was 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. However, Cabinet felt that it was not appropriate for Yalding and Coxheath to be designated Rural Service Centres (RSCs) as their facilities/services were not in line with other RSCs.
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.
There
were a number of appendices that contained 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 included 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.
Housing
needs and the Strategic Housing Land Availability Assessment
(SHLAA)
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.
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) was
used to build consistency into the process[2].
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.
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.
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.
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.
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.
Future
locations for housing growth
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 yetcompleted, resulting in
a net need for 15,500 homes. The land
allocations that are the subject of this consultation total
afurther 10,000 dwellings, leaving a balance
to find of 5,500 dwellings.
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.
Recommendations received from the Planning, Transport and Development Overview & Scrutiny Committee included the removal of some of these site allocations. Cabinet felt it was appropriate to remove the following sites from the Local Plan:-
H1(18)
Cross Keys, Bearsted
H1(19) Fant Farm,
Maidstone
H1(51) Cripple Street,
Loose
H1(58) Ware Street,
Thurnham
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
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, therecould be some prospect that the site
may be declared surplus and so become available for alternative
uses.
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
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 was originally considered to have the potential to deliver in the order of 200 additional homes. However, due to emerging proposals for The Mall, which would see substantial new residential development coming forward as part of a comprehensive redevelopment of the shopping centre, it was felt appropriate to increase this number to 600.
Lenham
Rural Service Centre
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.
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 neighbouring
Harrietsham.
Unmet
housing need
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.
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.
It was
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.
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 was 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.
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 |
Employment land needs and Junction 8
Background
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.
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.
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.
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.
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.
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.
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
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.
This
forecast was 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 was a specific proposal
which will provide a wider catalyst to growth.
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).
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)
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]
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)
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.
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).
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 was 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.
Either
of the two sites submitted at the Junction 8 location could
accommodate the full requirement for industrial and warehousing
floorspace.
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.
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.
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.
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.
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.
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
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.
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 Transportation 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.
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.
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.
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.
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.
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.
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
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.
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
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).
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.
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).
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.
Additionally, the ancillary office space provided as part of
industrial/warehousing development will contribute to the
identified requirement.
The
Spatial Strategy (Policy SS1) and
Sustainability Appraisal
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.
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.
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.
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 |
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.
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.
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)
|
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.
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.
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.
The SA
concluded that, on balance, alternative B (the local plan strategy)
has fewer impacts on congestion, countryside and heritage
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 alternative B, but mitigation measures can be
implemented to avoid negative impacts.
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.
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.
Affordable Housing (Policy DM24)
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.
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%.
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.
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.
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.
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
Countryside (Policy SP5)
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]August 2013
[2]A similar pro forma was used in the assessment of potential Gypsy and Traveller sites, and for economic development sites, both of which were part of the call for sites.
[3] As defined in the Maidstone Borough Wide Local Plan 2000. Settlement boundaries will be amended to take account of new land allocations once the local plan is adopted.
[4] Including strategic site allocations to the north west and south east of the urban area.
[5]Deliverable sites must be available, offer a suitable location, be achievable (with a realistic prospect of being delivered within those 5 years), and be viable.
[6] Developable sites must be suitably located, and available and viable at the point of release.
[7] A section on development constraints was included in 27 January 2014 Cabinet report.
[8]Cabinet, 13th March 2013.
[9] This figure excludes two sites where the extant planning permissions for offices (= 23,150sqm) are unlikely to be implemented because of alternative proposals; the site at Eclipse with permission for Next and the site at Springfield which is proposed to be allocated in the draft Maidstone Borough Local Plan for housing
[10] Includes deduction of 5,000sqm for the poorest quality vacant town centre office stock
[11] Includes CIA adjustments at Eclipse Park
[12] Pro forma agreed by Cabinet Member for Planning, Transport and Development 22 March 2013
[13] Cabinet report 25 July 2012
[14]Maidstone Joint Transport Board 22nd January 2014
[15]Draft National Planning Practice Guidance (August 2013)
[16] Maidstone Borough Wide Local Plan 2000
[17] Proposal for a freestanding garden suburb, accommodating 3,000 to 5,000 new homes on greenfield sites located to the south east of the urban area.
Alternative options considered:
Alternative courses of action have been included in the reasons above.
Reason Key: Policies, Plans, Strategies;
Wards Affected: (All Wards);
Details of the Committee: None
Contact: Sue Whiteside Email: suewhiteside@maidstone.gov.uk Email: suewhiteside@maidstone.gov.uk.
Report author: Sue Whiteside
Publication date: 26/02/2014
Date of decision: 24/02/2014
Decided: 24/02/2014 - Cabinet.
Effective from: 06/03/2014
Accompanying Documents:
- Appendix to Decision
PDF 54 KB View as HTML (1) 43 KB
- Maidstone Borough Local Plan Public Consultation Draft (Regulation 18)
PDF 207 KB View as HTML (1) 170 KB
- Appendix A: Maidstone Borough Local Plan - Preparation (Regulation 18) 2014
PDF 7 MB
- 140224 cabinet - urgent update FINAL
PDF 56 KB View as HTML (3) 20 KB