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 1053
Respondent Joshua Mellor - Barton Willmore LLP [View all comments by this respondent]
Response Date 17 Mar 2017
What is the nature of this representation?
  • Observation


5.1 The Site currently comprises greenfield land west of Birchington, located north and south of

the A28. The Site encompasses land proposed for allocation as part of the emerging Local Plan

under Policy SP14 (Strategic Housing Site at Birchington) and Policy H02C (Land fronting Park

Lane, Birchington).

5.2 We note that there are discrepancies between the land ownership boundaries and the land

identified as being part of the emerging allocation plan. The allocation plan should be updated

to reflect the correct land ownership boundaries to ensure that the scheme can come forward

in a comprehensive manner. The correct site boundary and its relationship to the proposed

allocation is included in Appendix A.

5.3 As referenced at paragraph 5.10 – 5.15 an additional parcel of land is submitted to be included

as part of the emerging Strategic Housing policy for Birchington.

i) Emerging Policy SP14 and H02C

5.4 Emerging Policies SP14 and H02C comprise several parcels of land, controlled by Ptarmigan

Land and Millwood Homes, adjoining the existing limits of built development of Birchington,

extending from Minnis Road, in the north, to the A28, and from the A28 to Park Lane, to the

east (See Appendix A).


5.5 The site comprises 4No. sites submitted for consideration as part of the Strategic Housing Land

Availability Assessment (SHLAA, 2013) as SHLAA sites S498, S499, part of S515 and ST3 (See

Appendix E).

5.6 It is noted that the additional parcel of land put forward and as shown in Appendix B was

also assessed in the SHLAA as part of SHLAA site S515.

5.7 Each site was scored 1 to 4 for suitability, availability and achievability; score 4 being most

favourable, based on the following criteria:


4 – No material constraints or impact mitigation required

3 – Constraints/impacts easily overcome/mitigated

2 – Overcoming constraints/impact mitigation more difficult to achieve

1 – Constraints unlikely to be removed/impacts mitigated before 2031


4 – Development commenced

3 – No known constraints to availability

2 – Any constraints can be overcome within relevant timescale

1 – Constraints cannot be overcome by 2031


4 – The development is well in progress

3 – Factors above (Market, Cost and Delivery) are unlikely to impact availability

2 – Factors above may cause a delay but site could be available by 2031

1 – No development seems achievable before 2031

5.8 All 4No. SHLAA sites scored 3 on Suitability, Availability and Achievability. This includes S515

– which assessed the land being put forward in Appendix B.

5.9 The site, including the additional parcel has been assessed by TDC as being a sustainable

location for residential development as part of the emerging Local Plan which is available and

achievable, and as such has been included as an emerging allocation which we fully support.

5.10 To ensure allocated development on the Site can be successfully delivered, policies SP14 and

H02C should provide sufficient flexibility to allow any future planning application(s) to address

details not presently known at this time. By way of example only, details in respect of the

access arrangements from the A28 and/or at Park Lane may require land outside that shown

as presently allocated. Sufficient flexibility in the wording of the policy would allow land to

come forward to deliver such access if so required.

ii) Additional Parcel

5.11 The additional parcel of land (Appendix B) is not presently included as part of the emerging

policy but fully formed part of SHLAA site S515 - which scored highly in terms of Suitability,

Availability and Achievability.

5.12 Sites put forward for allocation through the SHLAA, and the reason for not including sites for

allocation as part of the LPPO, are listed in the ‘Reasoning in respect of sites that were assessed

in the SHLAA’ [Online only3]. SHLAA site S515 is noted as being part of a larger allocated site,

with no detail provided as to why the additional parcel of land was not included for allocation

as part of the LPPO. There is no justification for its exclusion as a potential allocation.

5.13 The additional land forms a logical extension of the emerging allocation and would provide a

better and more appropriate interface with the wider countryside.. The allocation of this land

would enable the emerging allocation to deliver, in overall terms, additional residential

development, open space and infrastructure including appropriate landscape buffers to the

surrounding countryside. Furthermore, this would allow the opportunity to provide a greater

number of character density/areas, forming a strong and locally recognised start to the urban

edge where there is a transition from the countryside to the settlement of Birchington.

5.14 The potential provision of additional residential development land would assist the Council in

meeting its identified housing requirement, including strengthening the Council’s ability to

avoid any potential shortfall that may arise from a lack of delivery of unidentified sites or

Manston Airport. In addition, it would help for master-planning purposes as it would make the

site a more regular shape.

5.15 Baseline assessments, in regards to Landscape and Ecology, have been undertaken which have

identified no significant constraints which would result in the additional parcel not being

deliverable as part of the wider emerging allocation. The following reports are appended:

Appendix F: Ecological Report (February 2017)

Appendix G: Landscape and Visual Baseline Report (March 2017)

Appendix H: Heritage Desk-Based Assessment (March 2017)

Ecology Summary:

The Ecological Report confirms the intensively managed nature of the Site limits its potential

to support protected or otherwise notable species, although further surveys are recommended

to be undertaken in advance of any future planning application. Notwithstanding this, the

adoption of a suitable masterplan and implementation of habitat and species protection

measures would avoid significant adverse effects on ecological resources and deliver net

ecological gains overall.

Landscape and Visual Summary:

The Landscape and Visual Baseline Report identifies the Site being within a landscape which is

open and with few features. Arable farming has resulted in landscape and ecological features

being lost, generally resulting in a raw edge to existing development where it interfaces with

open countryside. The report identifies, in landscape and visual terms, the Site has significant

development potential. The additional parcel is identified as being able to play an important

transitional role from the wider landscape to the new urban edge for Birchington, having

potential for both development and the provision of green infrastructure.

Heritage Summary:

The Heritage Desk-Based Assessment identifies the site to have potential for archaeological

remains. However, this alone is not an overriding constraint to the Site that would preclude it

as an allocation in the emerging plan as part of a wider development site. Any future

development proposal will need to be supported by further archaeological evaluation.

Appropriate mitigation measures can be incorporated into any future design and/or addressed

through an appropriate programme of archaeological investigation, recording, analysis and


5.16 Based on the housing density for emerging policies SP14 and H02C, the additional parcel could

accommodate around 400 dwellings. However, it is suggested the parcel could deliver around

250 – 300 dwellings, allowing a transitional role from the wider landscape to the new urban

edge of Birchington through the provision of increased levels of green infrastructure.

5.17 The additional parcel of land is Suitable, Available and Achievable, and would form a

sustainable location for residential development, and as such should be allocated alongside the

remainder of the Site. The allocation would not affect the aims and objectives of the proposed

spatial strategy and would not result in a detrimental impact upon the sustainable growth

objections for Birchington and the District.