Proposed Revisions to Draft Local Plan (Preferred Options)

Document Section 1. Preferred Options Revisions Section 4 - Revised Location of Housing Revised Location of Housing [View all comments on this section]
Comment ID 907
Respondent V Ellis - CPRE Kent [View all comments by this respondent]
Response Date 17 Mar 2017
Response Type OBJECT
What is the nature of this representation?
  • Object

At the previous consultation CPRE urged the Council to take account of environmental constraints (including agricultural land and water supply/quality) in its setting of a housing targets and this may moderate the need for loss of high quality agricultural land to housing.  CPRE notes that the 4 additional large sites will assist delivery of transport infrastructure and a new ‘inner circuit’ in particular. 

In terms of housing allocations, and the preparation of a positively prepared, justified and effective Local Plan, the following observations can be made:

1.       The proposed highways and infrastructure proposals (strategic route) are ambitious, and described as critical to support the development in the draft local plan.  It is essential that prior to publication of the Regulation 19 draft that the Council produces a sites viability assessment, transport strategy and up to date Infrastructure Delivery Plan (demonstrating costs and funding sources).  Although some of the measures and proposals in the Local Plan and Transport Strategy can be implemented by the Council using statutory planning powers, it is likely that other public sector funding and private sector investment will be required.  Implementation of an inner circuit is mentioned as a future scheme in the LTP4, but this is unlikely to be sufficient for funding bids at this stage.  

Given network capacity constraints, the existing air quality issues (and AQMA designation), and the acknowledged importance of road network improvements to the delivery of the plan as a whole, transport modelling should be completed to demonstrate future network capacity based on anticipated traffic growth.   Further, it is essential that proposal sites can remain viable despite the range of anticipated infrastructure required.  Although the Infrastructure Development Plan anticipates much of the infrastructure to be development funded, additional work on detailed and cumulative costs of infrastructure is necessary.

2.       Clearly some of the additional strategic route requirements will have implications for draft housing allocations which were considered in previous consultations.  It is likely that viability and prospects for the quality of place-making may be raised as concerns for these sites in future consultations.  Sites west of Birchington, for example still need to demonstrate that they can be delivered without unacceptable impacts on landscape and setting of historic buildings (such as Gore End farmhouse and barn). Deliverability of plan proposals is important, since village edge locations will be very vulnerable to speculative development proposals in the absence of a 5 year supply.

 3.      CPRE is concerned about the reliance placed on large sites with substantial infrastructure requirements. Small sites are likely to be essential to deliver a 5 year supply in the early years of the plan – these should be in sustainable (and preferably brownfield) locations.  CPRE urges the council to proactively seek to identify urban brownfield sites. The council is in a position to be able to be able to facilitate the delivery of brownfield sites where there are land assembly challenges.


4.       It is essential that a Sustainability Appraisal of all sites are completed, so that the sites can be compared according to the extent to which they meet sustainability objectives.   SHLAA Assessment is not sufficient, on its own, for site selection purposes.  It is not clear that SA/SEA has contributed to the assessment of alternatives, and thereby contributed to selection of strategic sites.