Agenda Item No: 8
Report To: CABINET
Date: 11th October 2012
Report Title: Response to public consultation and proposed submission of the Chilmington Green Area Action Plan (AAP)
Report Author: Simon Cole, Planning Policy Manager
The Council’s adopted Core Strategy (2008) identifies land at Summary: Chilmington Green, to the south-west of Ashford, as a location for a major new sustainable urban extension and sets out that an Area Action Plan should be produced to guide the detailed planning of the area.
Accordingly, the Council has progressed with a Chilmington Green Area Action Plan (AAP) over the last few years, to establish how development at Chilmington Green should come forward. A draft version of the AAP (the regulation 19 version) was published and was released for 8 weeks of public consultation between the 16th April and 11th June 2012. A total of 541 formal representations were received, from a total of 352 respondents. This included a petition of 8,081 signatures, submitted by the ‘Keep Chilmington Green’ group.
This report sets out the Council’s intended response to the issues raised from these representations, and includes a number of minor amendments to the Reg 19 version of the AAP. The report also recommends that the Council should now submit the Area Action Plan (as amended) which would trigger a public examination.
Key Decision: YES
Affected Wards: Great Chart with Singleton North Weald South Washford Singleton South Godinton
1 Recommendations: The Cabinet are asked to: i) agree the proposed Council response to representations received on the Regulation 19 version of the Chilmington Green Area Action Plan (appendix A),
ii) agree the proposed amendments to the Regulation 19 version of the Chilmington Green Area Action Plan (appendix B),
iii) recommend to Full Council to authorise the Head of Planning and Development to submit the Chilmington Green Area Action Plan (as amended) to the Secretary of State for independent examination,
iv) grant delegated authority to the Head of Planning and Development to:
a) make any further modifications he considers necessary or desirable before or during the examination, b) ask the Inspector to recommend modifications to the draft AAP under Section 20 (7C) of the Planning and Compulsory Purchase Act 2004, c) take any action he deems necessary to progress the draft AAP through the examination process.
Policy Overview: Once adopted, the Chilmington Green AAP would form part of the Council’s Local Development Framework. It needs to be sufficiently consistent with the adopted Core Strategy in order to be sound.
Financial None, other than the normal costs associated with conducting Implications: a public examination.
Risk Assessment Yes
Equalities Impact Stage 1 (Screening) carried out. Concluded that it was not Assessment applicable to go to stage 2 (Full assessment).
Other Material None Implications:
2 Exemption None Clauses:
Background None Papers: Contacts: [email protected] – Tel: 330642
3 Agenda Item No. 8
Response to public consultation and proposed submission of the Chilmington Green Area Action Plan (AAP)
Purpose of the Report
1. This report: - highlights the main issues raised following the recent public consultation into the draft version of the AAP (regulation 19 version) and proposes the Council’s intended response to these issues, - proposes a number of minor amendments to the draft version (regulation 19) of the AAP which take into account some of the formal comments received and the Council’s desire to link Chilmington Green with the Garden Suburb principles, - provides a series of recommendations (see above) in order to progress to the submission stage of the AAP. This would trigger a public examination into the soundness of the AAP.
Issues to be Decided
2. The Cabinet is asked to agree the proposed responses to the representations received during the public consultation and the proposed amendments to the Regulation 19 draft Chilmington Green AAP. Subject to this, the Cabinet is asked to recommend that the Full Council authorizes the submission of the amended AAP to the Secretary of State so that it can be formally examined by an independently appointed Government Planning Inspector.
Background
3. The principle of significant growth at Chilmington Green has been thoroughly debated through the evolution of the Council’s Core Strategy (2006 – 2008). The Core Strategy was also subject to an examination in public, overseen by an independently appointed Planning Inspector who determined that the Core Strategy policy approach was sound.
4. The Core Strategy was adopted in 2008. Policy CS5 ‘Ashford Urban Extensions’ states that “With immediate effect, major new development areas are proposed at Chilmington Green/Discovery Park…. The Chilmington Green/ Discovery Park area should be planned to accommodate no less than 3,350 dwellings and 600 jobs by 2021 and has the potential for over 7,000 dwellings and 1,000 jobs in total’.
5. Policy CS5 goes onto state ‘the development of these areas must be planned and implemented in a comprehensive way that is linked to the delivery of key infrastructure. Area Action Plans will be produced to guide the detailed planning
4 of these areas, supplemented where needed by development briefs and design codes.”
6. Accordingly, a Chilmington Green Area Action Plan has been prepared over the course of the last 2 years, with the aim of establishing the key principles and policies that will govern the future detailed development of the area and inform the Council’s response to planning applications within the AAP area.
7. The production of the AAP (and its supporting masterplan) has involved significant consultation throughout its evolution. This has included targeted consultation with stakeholders through the Issues and Options stage of the process (conducted in 2007). In addition, there have been ongoing discussions with local residents and stakeholders, the three local Parish Councils and other statutory bodies. A number of workshops and events, as well as a regular community steering group, have also been held to discuss the emerging approach for Chilmington Green.
8. Officers have also liaised with the developer consortium and their consultants to help steer the masterplan for Chilmington Green (a key supporting document to the Area Action Plan). This approach helped ensure that the council’s aspirations are aligned with and built into the developer’s proposals for the area when they come forward. A detailed list of the consultation events that have taken place over the last 3-4 years on the Chilmington Green Area Action Plan is appended to this report (see Appendix C).
9. There have also been regular reports to the Planning Policy Task Group on the chapters of the AAP as they have been drafted, to allow members to help shape and evolve the policy approach.
10. The culmination of all of this work led to the publication of the Regulation 19 version (draft) of the Chilmington Green Area Action Plan. In essence, the policy framework contained within this version of the AAP sets out the policies which the Council intend to adopt as local policy. A number of key themes are incorporated within the AAP, as follows:
a) The quantum of development: Policy CS5 of the Core Strategy states that the Chilmington Green area had the potential for over 7,000 dwellings and about 1,000 jobs in total. However, by applying the Council’s desire for quality at Chilmington Green (such as the application of suitable residential space standards and residential parking requirements), alongside applying the various layers of evidence which supports the AAP, the number of houses now being proposed at Chilmington Green is 5,750. However, the number of jobs proposed remains over 1,000.
b) Infrastructure planning and phasing: To deliver a development of real quality at Chilmington Green, the timely provision of the right levels of social and
5 physical infrastructure is needed. The AAP responds by providing a policy framework which requires that infrastructure is delivered in a way which serves the needs of the community as it evolves. This includes road improvements, the delivery of new schools and community facilities as well as the creation of open space, green corridors and sporting facilities. Adopting this approach ensures that each phase of the development will be sustainable in its own right. c) Movement and Transport: Crucial for a development to function properly is to ensure that traffic is properly catered for. The AAP proposes a movement network which promotes a clear movement hierarchy for vehicular and non- vehicular movements both within and adjoining the site. This is balanced with the aspiration to respect the character of the existing rural lanes, as far as possible. d) Community development: Although not a specific land use issue, how an area is governed and managed can have a significant impact on the quality of the development when built. The AAP responds by supporting the principle of developing a community-led management arrangement at Chilmington Green – one which would ensure that there is ongoing professional management, yet the local residents retain a strong voice and ownership in the process. e) Urban structure: The AAP proposes a clearly defined urban structure with a vibrant District Centre as its focal point. This Centre is planned to accommodate a range of uses (including retail, employment, community and leisure) which will help meet the everyday needs of the residents, whilst providing activity during the day and evening. Later on in the development, two smaller local centers, within easily walkable catchments, are also proposed. f) Character Areas: The AAP provides more detailed policy guidance to a number of important locations within the development. This will ensure that the development is interesting and varied, but also responds to some of the important characteristics of the site, such as the existing listed buildings around the Hamlet area, and the proposed treatment of the southern boundary of the development. g) Provision of a range of services: Chilmington Green provides the opportunity to deliver a range of services in close proximity to each other. This includes a range of community and leisure facilities, sports pitches, green space areas, as well as four primary schools and a secondary school. h) Discovery Park: Policy CS18a of the adopted Core Strategy identifies that a strategic recreational resource should be delivered in the Chilmington Green area. Accordingly the AAP safeguards an area to deliver a strategic park,
6 currently referred to as ‘Discovery Park’ (an alternative name will be decided upon later). Discovery Park will include a range of formal and informal uses and sporting activities, of a scale to benefit Ashford’s wider population. Shortly, the Council - with the involvement of local stakeholders - will begin work on the Discovery Park Masterplan which will set out the detailed planning of the Park area, including the establishment of a strong vision, the range of uses to be delivered and their proposed location, as well as how these various uses will be delivered over time.
i) Quality: An overriding theme which resonates across all of the policies in the AAP is the clear desire that Chilmington Green becomes a place of real quality, whether this is through the design, layout and architecture of the built form, the high quality standard of the buildings delivered, or the spaces between them. The AAP also proposes a policy which establishes how any planning application should be handled, including the need for design codes, masterplans for each phase of the development and the need for extensive workshops, exhibitions and continuing our established tradition of using the Design Review Panel.
Consultation
11. The Regulation 19 version of the AAP was released for 8 weeks of public consultation between the 16th April and 11th June 2012. A total of 541 formal representations were received on the draft AAP, from a total of 352 respondents. This included a petition of 8,081 signatures, submitted by the ‘Keep Chilmington Green’ group. A summary of these representations is set out below. A complete overview of all representations can be found under appendix A of this report, alongside the recommended responses to those representations, arranged by topic headings.
12. The petition contained the headline:- “We, the undersigned, petition the Prime Minister, the Secretary of State for Communities and Local Government and Ashford Borough Council to abandon any plans, either now or in the future, to permit new building in Chilmington Green or the surrounding countryside.”
13. The petition therefore relates only to the principle of development at Chilmington Green and didn’t comment specifically on the content of the draft AAP. It was accompanied by a covering letter that set out some of the main reasons for objecting to the development – these have been reflected elsewhere in the main objection points alongside the proposed response in Appendix A.
14. Looking at the other representations, a significant majority also object to the principle of development at Chilmington Green, rather than the detailed policies within the AAP. These objections mainly surround the ‘need’ for the Chilmington Green development, the decision to press ahead with the AAP ahead of the Core Strategy review, the impact on Ashford town centre, water supply constraints,
7 traffic congestion, the ability of infrastructure to cope, the balance between homes and jobs, impact on ecology and the loss of agricultural land. Most of these comments were raised in two standard objection letters of either nine points or five points (all of the five points were included in the nine point letter) which were submitted by a total of 186 respondents (53% of the total respondents). Please refer to theme 1 of the appendix A, which addresses all these objections to the principle of the development.
15. There were also a number of detailed objections to the extent of the development area. These included the extent of the southern boundary and issues of blight on a resident, the potential for heritage assets to be eroded around Brisley Farm and the western edge to Discovery Park, impact on the village of Bethersden and the extension to Brisley Farm itself. Please see theme 14 of appendix A for those matters and the proposed responses.
16. Conversely, representations were received which requested the inclusion of additional land to the east of Long Length at Court Lodge Farm (for what appears to be part of Discovery Park - reps CG321 & 371), and to the west of the A28 at Blue Barn for a park and ride site – rep CG485. There have been no representations which promote other areas of land as an alternative major development area to Chilmington Green.
17. There were also a series of representations from the developer consortium’s team (rep references CG280 – 309), most of which are supportive of the contents of the AAP. However, they have raised objections to the parts of the AAP on the management of open space (they feel that the requirement for a management agreement to be in place before development can be occupied at Chilmington Green is too onerous – rep CG290), provision of affordable housing (they consider there should be less affordable housing on viability grounds with no provision for clawing back a deficit subsequently – rep CG300) and the promotion of a CHP network at the District Centre (they wish to see less emphasis on CHP – rep CG301).
18. There were also a number of representations which did make specific comments about the contents of the AAP. These are set out within the various themes, please refer to the relevant sections of appendix A.
19. Finally, it should also be noted that there were some supportive representations, in addition to those submitted by the developer team, (about 50 in total). Most notably these were from the water companies, Southern Water and South East Water (general comments of support in principle) and Kent County Council. However KCC did raise concerns about ecology and archeological issues, particularly around the Brisley Farm area, and are also requesting minor alterations to a number of policies within the AAP.
8
Handling / Next Steps
20. The Council now has three main options available. Each carries a degree of risk (see risk assessment section below). The Council must decide whether to:
a) Make significant changes to the AAP: Should any significant changes be deemed necessary (for example a change which alters the policy approach) a further round of public consultation would be needed, before the AAP could be submitted.
b) Make minor changes to the AAP: Should only minor changes be necessary (i.e. changes which would not alter the thrust of any policy in the AAP) the Council could progress to submission without the need for further consultation.
c) Withdraw the AAP: This remains an option for the Council, up until the Council decides to adopt the AAP. However, there is significant risk associated with this option (as set out below).
21. These options were debated at the Chilmington Green Task group meeting (24th September). The Task Group recommended (in line with officer’s advice) that the approach in the AAP continues to be sound and that there is no need to make significant changes to the contents of the AAP.
22. Although significant changes are not considered necessary to the AAP, there are a number of minor amendments which officers propose to make and the Task Group recommends the Cabinet agree to (see appendix B). These amendments are mainly in response to representations (see para below) and also a series of editorial changes to the AAP as it currently refers to the old Planning Policy Guidance/Statements which are no longer relevant, having been superseded by the NPPF (the National Planning Policy Framework). However, officers and the Task Group are also proposing some amendments to the AAP to reflect Members’ clear desire to relate the garden suburb principles to the Chilmington Green development.
23. As a whole, the amendments proposed under appendix B are considered to make the AAP more robust and up to date, without altering the thrust of the policy approach of the AAP. No consultation on the amendments is therefore required. The Cabinet is asked to endorse the recommendation from the Chilmington Green Task Group, in that the proposed minor amendments to the AAP, as set out under appendix B, are agreed.
24. Should Full Council agree to the submission of the Chilmington Green Area Action Plan, the AAP (as amended) can be formally submitted to the Secretary of
9 State in late October. A Planning inspector will be appointed shortly after this point to conduct the public examination of the AAP.
25. All the representations made at the public consultation stage, including the Petition, would be forwarded to the Inspector as part of this process, for consideration by him/her.
26. The Examination will effectively begin once an Inspector is appointed. It will be up to the Inspector to determine the timescales of the Examination as well as the issues he or she would like to debate, either by way of written representations or through formal hearing sessions around the table.
27. It is most likely that the formal hearing sessions will be held around late January or early February 2013. Should the Inspector find the policy approach advocated in the AAP sound, the Council could be in a position to adopt the AAP in the summer of 2013.
Risk Assessment
28. There are three main risks which need to be considered at this stage.
29. One scenario could be that the Council submits the Area Action Plan, but through the Examination process it is found to be ‘unsound’ by the Planning Inspector. The risk associated with this scenario is that the Council would lose control over the process. There would no longer be any relevant detailed analysis or policy framework to assess a planning application against. Instead, the application would have to be determined solely on the higher level policies contained within the adopted Core Strategy and the National Planning Policy Framework.
30. Another scenario could be that the Council submits the Area Action Plan, but the Inspector requires a number of changes to its policy approach. Should these be changes which the Council are unwilling to entertain, then the Council would have no choice but to withdraw the AAP.
31. The alternative approach would be that the Council does not progress towards the submission of the AAP, and instead withdraws the AAP at this stage.
32. On balance, it is officers view (endorsed by the Chilmington Green Task Group) that the AAP should progress to formal submission stage as it is this option which results in the Council retaining the greatest level of control over the detailed planning of the area – which is crucial if the high quality environment envisaged for Chilmington Green is to be delivered.
10 Equalities Impact Assessment
33. A Stage 1 screening assessment has been carried out. It has concluded that the policies contained within the AAP do not miss any opportunities to promote equality or prejudice any existing groups. Indeed, the AAP provides a framework for the delivery of a range of services that will support all sections of the community and all ages. As a consequence, it is unnecessary to proceed to a full assessment.
Implications assessment
34. The areas of debate at the AAP Examination will be determined by the appointed Planning Inspector. Unlike most Plans the Council have produced to date, this debate is not likely to surround alternative sites for development, as no strategic alternatives have been promoted through the representations.
35. It is more likely – based on the nature of representations received - that the following topics will be debated:
i. Principle of Chilmington Green: Although not an issue directly related to the contents of the AAP (in that the principle has already been established through the Core Strategy) it is likely that this issue will be debated, particularly given the scale of representations on this matter.
ii. Transport issues: As with most large developments, transport and movement are significant issues. In a Chilmington Green context, this debate is likely to focus on the off-site road improvements required to support the development (most notably along the A28), the proposals for traffic distribution throughout the development, the impact on the existing rural road network and the likely vehicular movements eastwards. Debate will also centre on the aspiration for a 20% modal shift, public transport concerns and how pedestrians and cyclists will be catered for.
iii. Deliverability: It is likely that two main themes will be debated. The first will surround whether the development can actually deliver the level of social and physical infrastructure proposed in the AAP. The second will be whether the AAP is suitably flexible to allow viability to be taken into account at the planning application stage.
iv. The extent of the development area: Should there be a debate on this issue, it will probably include the proposed Brisley Farm extension, the extent of ecological mitigation areas proposed in the south, and the extent of the southern boundary of the development.
v. Topic based issues: A number of more detailed objections raised relating to several topic policies has been submitted. Debate would probably surround
11 the AAP’s proposed approach to ecology, SuDS, affordable housing, sustainable design and construction requirements and open space management. In addition, the overall flexibility of the policies within the AAP is also likely to be debated.
Conclusion
36. It is clear that proposals for large-scale development at Chilmington Green are contentious and the strength of feeling expressed through the representations and the related petition is acknowledged and respected. It is entirely understandable that large new developments that mean significant change to an area may create concern and anxiety amongst local residents and it is right and proper that the council is questioned and challenged about such proposals.
37. A large proportion of the objections the council has received to the draft AAP relate to the principle of development at Chilmington Green rather than detailed comments on the content of the AAP. The only substantive alternative approach promoted is that of no development at Chilmington Green, as the petition puts it, ‘either now or in the future’.
38. The case promoted by the main body of objectors to justify no development at Chilmington Green contain a number of observations which are addressed in the proposed responses in Appendix A and no compelling evidence has been provided to support many of these contentions that are put forward. As a result, on balance, the principle of major development at Chilmington Green remains valid.
39. A number of representations have suggested ways in which the draft AAP could be strengthened and improved and where this is reasonable, minor amendments to the Plan are proposed in Appendix B.
40. In reaching this conclusion, it is relevant to note that since the draft AAP was published, an outline planning application for the Chilmington Green development has been submitted to the council. The AAP will play a central role in the council’s approach to considering the application and ensuring that the highest quality development possible is achieved along with the delivery of all necessary infrastructure and services to support it. Withdrawal of the AAP at this stage would undermine this position.
Portfolio Holder’s Views
41. This report and the Appendices represent a detailed and thoughtful consideration of all the comments made on the Area Action Plan for this major planned development.
12 42. The responses to the representations received on the Regulation 19 version of the Chilmington Green Area Action Plan (Appendix A) have been rational and balanced.
43. As a result of the examination of the responses to the Regulation 19 version of the Chilmington Green Area Action Plan, amendments have been made. Furthermore the Chilmington Green Task Group has met and has closely examined the responses and the officer’s comments. This led to further amendments to the Regulation 19 version of the Chilmington Green Area Action Plan and all these amendments are embodied in Appendix B.
44. I am satisfied that that this Area Action Plan has quite properly been submitted to full and proper consultation, and that the officers of this Authority have exercised due care and attention in examining all the comments and have amended the Area Action Plan wherever it was appropriate to do so. Accordingly, I have no hesitation in commending to Cabinet that they recommend that the Chilmington Green Area Action Plan (as amended) be progressed to Full Council for onward submission to the Secretary of State for independent examination.
45. I further commend to Cabinet that the delegated authority sought in this report for the Head of Planning & Development, be approved.
G.D. Clarkson CBE, QFSM Deputy Leader & Portfolio Holder for Planning & Development.
Contact: Simon Cole 01233 330642
Email: [email protected]
13 Appendix A: Main issues raised following cconsultation on the Publication Version (Regulation 19) of the Chilmington Green Area Action Plan
The council received a total of 541 representations, one of which was a petition of over 8,000 signatures. This paper sets out the issues raised by these representations and divides them into themes (as listed below) and also sets out the Council’s response to these issues. For ease of reference, the name of the respondent, alongside the representation number, is provided at start of each theme.
A complete list of all the representations received on the draft Chilmington Green Area Action Plan can be found under Addendum 2 of this paper, or via the Council’s website, please visit www.ashford.gov.uk/consult and follow the pages to the Chilmington Green Area Action Plan. In addition, for information purposes, an index showing which representations were submitted by each respondent can be found under Addendum 3 of this paper.
A number of comments made by respondents requested a change to the text of the Chilmington Green Area Action Plan. Where this is acceptable, these have been agreed to and are referenced accordingly in this paper. The exact wording of the proposed amendment is contained within the Council’s schedule of proposed minor amendments – a supporting document to the Chilmington Green Area Action Plan, Submission Version (regulation 22). Please visit www.ashford.gov.uk and follow the links to the Chilmington Green Area Action Plan pages of the website.
The representations have been divided into the following themes:
Theme 1 – Objections to the principle of Chilmington Green Theme 2 – Vision and Objectives of the AAP Theme 3 – Character Areas Theme 4 – Open space, outdoor sport, play areas and Discovery Park Theme 5 – Community governance Theme 6 – Transport Theme 7 – Education and social provision / community facilities Theme 8 – Indoor Sport and community leisure buildings Theme 9 – Affordable housing Theme 10 – Sustainable Design and Construction Theme 11 – Flooding and SUDs Theme 12 – Ecology and Landscape Theme 13 – Monitoring, phasing, delivery and Infrastructure Delivery Plan Theme 14 – Boundary of the Area Action Plan Theme 15 – Miscellaneous
1 THEME 1: OBJECTIONS TO THE PRINCIPLE OF CHILMINGTON GREEN a) Standard letters and the Petition
Representations were received from the following consultees:
7 – John Barton 60 – John Ley 130 – Ann Milner 8 – Mr Loftus 61 – Wood 131 – P Spink 11 – Gill Haigh 62 – M Carter 132 – B Varney 12 – Angela Couling 63 – Ian Sleeper 133 – John Durrant 13 – S Hollingshead 64 – Chris England 134 – G Bowring 15 – Michelle Parsons 65 – Michael Dowsey 135 – S Keehy 16 – Lee Robinson 66 – John Durrant 136 – Tom Bryon 18 – Linda Seaton 67 – Amanda Pocknell 137 – M and J Carter 19 – Steve Faldon 69 – Derek Parris 138 – Mr and Mrs Hinwood 20 – David Lay 74 – D Hammett 139 – K Frohnsdorff 21 – M Robey 75 – D Hammett 140 – R Beaugie 22 – Owner / occupier 78 – D Hammett 142 – S Stanfield 24 – R Isworth 81 – D Hammett 143 – R M Hayward 25 – R Dawkins 96 – UKIP (N Taylor) 144 – Donald Fagg 26 – Eric Chapman 97 – Dunster 146 – Mr Lacey 27 – R and M Clark 98 – Spencer Dorey 147 – Mr White 28 – Colin Creedy 99 – McCort 148 – Sally Gathern 29 – Stuart Moss 100 – Stuart Akers 152 – Syed Gilani 30 – J V Meek 101 – Robert Hughes 153 – Cllr Andrew Mortimer 32 – M Slann 102 – R A Sander 154 – Owner / occupier 33 – Ray Dawkins 103 – Jacky Watts 155 – N Perrott 34 – John Emms 105 – S Keaveney 156 – Owner / occupier 35 – G Hewins 106 – S V Squibb 157 – Owner / occupier 36 – Frances Brann 107 – J Reeves 158 – C Rogers 37 – Wilson 108 – K J Bowers 159 – Ms and Mr Crealock 38 – Heather Hayward 109 – Sharon Bowers 160 – James Eberlein 40 – M and N Bowers 110 – T Gardfold 161 – JL and AJ Kent 41 – K Drewett 111 – Lorraine Harp 162 – Owner / occupier 42 – Owner / occupier 112 – Car Ricketts 163 – Owner / occupier 43 – G Humneman 113 – E and J Bishopp 164 – A Barrett 44 – Owner / occupier 114 – Bruce Lowe 165 – Charlotte Fraser 45 – C Joyce 115 – A and J Strang 166 – Yvonne Ho 46 – W Barrett 116 – J E Durrant 167 – C Craib 47 – C M Vavasour 117 – Janina Dawkins 171 – Owner / occupier 48 – Lee Robinson 118 – Ray Dawkins 172 – K Brown 49 – RC Foreman 119 – J S Carter 173 – S Brown 50 – Peter Williamson 120 – Owner / occupier 174 – A Brown 51 – D Richardson 121 – Owner / occupier 175 – Mr and Mrs Bryant 52 – Owner / occupier 122 – D Botting 176 – Ashford Independent 53 – P Churcher 123 – J Botting Party 54 – J Churcher 124 – Mr and Mrs Taylor 181 – Deborah Rafferty 55 – P Roughton 125 – K Williamson 182 – Karen Hopkins 56 – Raymond Woodcock 126 – Mike Adams 183 – D Craib 57 – M Ludlow 127 – Ian Payne 184 – D Hendricksen 58 – Lanning 128 – Jeanette Payne 185 – Andrew Anselmi 59 – Roger Coker 129 – Gary Milner 186 – Frederick Westwood
2 189 – Philip Norris 252 – Freelove 359 – A Bateson 190 – M A Priestley 255 – Little Chart Parish 361 – L Carrenk 191 – G Priestley Council 362 – A Bennett 192 – L Collins 256 – Evan Stirzaker 365 – Clive and Margaret 193 – M Reading 257 – Central Ashford Young 194 – M Lally Community Forum 368 – Lisa Taylor 195 – J Lally 261 – Margaret Cook 369 – R Charlton 196 – Owner / occupier 262 – Margaret Cook 371 – Owner / occupier 197 – Jane Davey 269 – A Williams 373 – J Charlton 198 – Y Larbey 270 – Sophie Walkden 375 – Nicola Hawkes 199 – W Morgan 274 – Howard Barrett 376 – Owner / occupier 200 – A and L Carrie 276 – Cllr Peter Davison 378 – L Kemp 201 – V Cleaves 310 – J Dacre 379 – Owner / occupier 202 – S P Featherstone 311 – P Fagg 381 – M Yates 203 – C Knight 312 – S Collins 384 – Owner / occupier 204 – I Marchant 313 – John Holland 385 – Brenda Hedley 205 – E Relf 314 – G and E Hope 387 – R Chaplin 206 – Mick Carr 315 – Zoe Snazelle 389 – Penny Boorman 207 – YPS Accounting 316 – N Lawrence and L 390 – M Yates Services Ltd Spring 392 – Owner / occupier 208 – Ashford Green Party 318 – M Russell 396 – Laura Furlong 210 – N Christian 319 – Gavin Curtin 397 – Valerie Joynson 211 – Catherine Stevens 320 – G Cowper 399 – B L Dryland 212 – Ashford Independent 322 – B Walsh 401 – Ian Hawkes Association 323 – Owner / occupier 403 – Owner / occupier 213 – Hazel Griggs 324 – Sue Davison 404 – L Garrabos 214 – Richard Carr 325 – Owner / occupier 405 – R Eccles 215 – Vinit Shah 326 – Owner / occupier 406 – P Bidwell 216 – D Marchant 327 – P Walsh 407 – Owner / occupier 217 – J Marchant 328 – Owner / occupier 408 – Michelle Beerensson 218 – C Simpson 329 – Ian Procter 409 – Lesley Bourne 219 – Matt Hopkins 330 – B Goode 410 – David Beerensson 220 – Ieda Hogarth 331 – Carol Procter 411 – Owner / occupier 221 – C Cleaves 332 – Ross Procter 412 – J Edwards–Moss 222 – M Cleaves 333 – P Ridley 413 – Will Watkinson 223 – L Donaldson 334 – B Hewison 414 – Sharon Kelly 225 – Lillian Brookes 335 – A Procter 415 – Owner / occupier 226 – Shirley Ambrose 336 – R Axers 416 – Claire Coombes 227 – A Rowe 337 – J and M Morris 417 – J Palmer 228 – Independence & 338 – S Pond 418 – N Edwards-Moss Access Matters 339 – Owner / occupier 419 – Owner / occupier 229 – Ken Scrivner 340 – Owner / occupier 420 – I Holiday 230 – T Hendricksen 342 – Owner / occupier 421 – Valerie Carpenter 231 – F Summers – Smith 343 – C Willis 422 – A Holiday 241 – J Preston - Ladd 344 – R Davies 423 – J Carpenter 242 – E and G Milborrow 345 – Owner / occupier 428 – P Tuck 243 – Owner / occupier 347 – Owner / occupier 435 – Owner / occupier 244 – J Cameron 348 – M & L St. John 438 – Owner / occupier 245 – M Cameron 351 – Colin Creedy 440 – Alex Carson 246 – Jo Brand 354 – Jim Hunt 443 – P Rothwell 248 – Kath Carr 355 – Mrs Creedy 448 – Gordon Roberts 249 – G Roberts 358 – Mrs Ridley 449 – J Till
3 451 – Owner / occupier 486 – H and S Franks 531 – Keep Chilmington 452 – L Rae 507 – Helen Lyon Green 453 – Owner / occupier 514 – Linda Cleaves 532 – Keep Chilmington 454 – Kenardington Parish 515 – R Hughes Green petition Council 517 – Robert Hughes 533 – G & M Richardson & 455 – Mr and Mrs Doughty 518 – Judith Knight Ransley 465 – Great Chart with 519 – Sarah Dacre 534 – Helen Manaton Singleton PC 520 – S Bailey 535 – J Gilburt 467 – Great Chart with 521 – A McLeod 536 – C Laill Singleton PC 522 – Cllr Winston Michael 537 – Vincent Mulhern 468 – Great Chart with 523 – N Chaplen & Eleanor 543 – R and M Olds Singleton PC Chaplen 544 – Neil Ruddock & Miss 483 – A Maltby 524 – Max Frohnsdorff L Newman 484 – Alice Frohnsdorff
1. All of the representations listed above made objections to the principle of Chilmington Green. Most of these responses came forward through a number of ‘standard’ letters. There were two versions, one containing nine reasons of objection and the other containing five reasons (which were all contained within the nine-point objection letter).These objections focused on the principle of Chilmington Green and not any specific policy, or part of the AAP. Please refer to Addendum 1 of this statement for a copy of each standard letter.
2. A number of other principle objections were also received. Although these were not worded in exactly the same way as the two ‘standard’ letters, they raised the same, or similar, issues and points of objection. These have been highlighted in section b and c of this theme, below.
Objection Point 1: “An overwhelming majority of the people who live in the areas affected by these plans have signed a petition opposing the development of the area. Clearly, the plans do not have the support of the local community” Response
3. The principle of significant development being located at Chilmington Green has already been thoroughly examined and established previously. At the regional planning level, the amendments to RPG9 in 2004 and the subsequent confirmation of the approach in the South East Plan, both identified a south-western extension of Ashford.
4. The Core Strategy also confirmed a more detailed approach to the scale, timing and delivery of new development at Chilmington Green and, at the time, there were very few objections in principle to development there. During the Core Strategy Examination process, the Inspector considered a full range of options for the growth of Ashford. This was the culmination of a consultation process that looked at and tested various strategic options for growth contained in the Greater Ashford Development Framework (GADF).
5. The Core Strategy Inspector fully endorsed Chilmington Green as a location for a sustainable urban extension which included a larger amount of residential development than is now being proposed in this AAP. As such, the principle of development at Chilmington Green is not a matter that is dealt with in the AAP.
4 6. If there were no AAP, the Core Strategy still remains in place until a formal review of it has been adopted. This would not be until 2014. In this case, any planning application for strategic development at Chilmington Green could rely on para.14 of the National Planning Policy Framework (NPPF) which states that proposals that accord with the development plan should be approved “without delay”. In reality, this could mean a lot less control for the council over the quantity and quality of development there.
7. In relation to the petition which was handed to the Council, its headline stated “We, the undersigned, petition the Prime Minister, the Secretary of State for Communities and Local Government and Ashford Borough Council to abandon any plans, either now or in the future, to permit new building in Chilmington Green or the surrounding countryside.”
8. The petition therefore relates only to the principle of development at Chilmington Green and didn’t comment specifically on the content of the draft AAP. It was accompanied by a covering letter that set out some of the main reasons for objecting to the development – these have been reflected elsewhere in the main objection points (see below) alongside the proposed response.
9. A summary of the petition responses shows that, of just over 8,000 signatures, 2725 were local residents (i.e. living in Chilmington, Great Chart, Kingsnorth (inc. Park Farm), Shadoxhurst, Singleton, Stubbs Cross and Washford Farm). About 3,900 live elsewhere in the Borough and about 1,300 live outside the Borough. A small number (<20) of the total respondents gave no address or postcode.
10. In order to asses the proportion of local residents who signed the petition, the table below shows the number of signatures from those people who live in the nearby wards and compares this with the total number of residents who are registered on the electoral roll.
No. on % of Electoral Local Residents - Breakdown of Wards Signatures Electoral Roll July Roll 2012 Great Chart with Singleton North 595 2639 22
Park Farm North 335 2496 13
Park Farm South 78 2077 4
Singleton South 203 2321 9
Washford 778 2533 31
Weald East 67 2114 3
Weald South 659 4340 15
Not Known 10 0 0
2725
5 11. It is accepted that concern has been raised about this development on a considerable scale. These views are respected but, as explained above, the principle of a significant scale of development at Chilmington Green has been previously considered, assessed, consulted upon and examined at length. It is the council’s role to make what are sometimes difficult or unpopular decisions that will deliver wider benefits to the community at large.
Objection Point 2: “Development of Greenfield sites is environmentally irresponsible when brownfield sites have not yet been developed. When the Growth Area development started in Ashford, it was agreed that the development was to be ‘central’ and ‘concentric’, yet ABC is planning to build a new satellite town in the countryside before brownfield land in the town centre has been redeveloped. There are still large brownfield sites in the town centre with planning permission awaiting development.”
Response
12. This objection suggests that development at Ashford should be ‘sequential’ (i.e. brownfield before Greenfield) rather than complementary (i.e. brownfield and Greenfield coming forward at the same time). There are several references in the adopted Core Strategy to this point which are worthy of consideration.
13. Firstly, the Core Strategy’s Vision as set out in paragraph 1.27 is explicit about the growth model for the town. It states that:- “Its expansion will follow a compact growth model based on the existing urban area of Ashford town and a small number of sustainable urban extensions to it.”
14. Guiding Principle F in policy CS1 states that one of the key planning objectives is “the best use of previously developed land and buildings to help regenerate urban areas and the carefully phased release of Greenfield land to make best use of a finite resource.”
15. Chapter 2 of the Core Strategy sets out the growth strategy in more detail. Here, the optimum use of the urban area for new development is clearly emphasised but it is also explicitly stated that the growth challenge cannot be accommodated solely on existing urban sites and that planned extensions to the existing urban areas are the next most sustainable option (paras. 2.24 & 2.25, Core Strategy).
16. Importantly, there is no sequential approach to release of development identified in policy CS2 with the exception of a 3rd urban extension (after Chilmington Green and Cheeseman’s Green). This is reinforced in policy CS5 of the Core Strategy where the policy starts with the phrase “with immediate effect, major new development areas are proposed at Chilmington Green / Discovery Park…” and the accompanying housing trajectory for the Plan which shows a combination of brown and green field sites coming forward simultaneously. Similarly, there is no such sequential approach to the delivery of brownfield sites in the NPPF.
6 17. In any event, it can be said that the Council has prioritised the allocation of previously developed land. The Town Centre AAP was the first site allocation document to be adopted following the Core Strategy in February 2010 and this identified detailed policies for a whole range of brownfield sites with no Greenfield sites identified whatsoever. A similar approach has been followed in the Urban Sites & Infrastructure DPD with available brownfield opportunities being identified and allocated. In the meantime, development has continued at Repton Park – the largest brownfield site in the town.
18. Of course, it is frustrating when redevelopment of brownfield sites is allocated in Plans, and even gets as far as planning permission being granted, but is not then implemented. However, there is no support either in the Core Strategy or in the NPPF for an approach which prevents Greenfield sites coming forward only after brownfield sites have been developed.
Objection Point 3: “The proposed development is so large that it would place significant additional pressure on the services and infrastructure of Ashford and the surrounding areas. I doubt that any central government development funding that is made available as a result of building additional houses, or the financial contributions from the developers, would pay for the increase in public services and infrastructure that an enlarged Ashford would require.”
Response
19. The relationship of infrastructure provision to new development is fundamental to the success of creating high quality, sustainable communities. Admittedly, in the past, that relationship has not always been as clear and has resulted in residents lacking access to local facilities at the right time. Several different agencies and organisations can be involved in delivery and it can often be a complicated process ensuring that all the relevant parties are involved at the right time.
20. The Chilmington Green AAP is clearly infrastructure-led. More than half of the 22 policies in the AAP deal specifically with infrastructure provision of one sort or another and one of the key development principles is that each main phase of the development will be capable of standing in its own right through the provision of the necessary social and physical infrastructure both on and off-site (policy CG1 b). This will be secured through legal agreements attached to any grant of planning permission that will require the delivery of certain infrastructure by a series of defined stages of the development. There is a comprehensive infrastructure delivery plan for each phase set out in Appendix 3 to the AAP.
21. These requirements have been worked up alongside key service providers over the course of preparing the AAP and are based on their analysis of both current and future demands with the Chilmington development in place.
22. Much of the funding for new infrastructure will need to come from the developers themselves from the rise in the value of the land with planning permission, and their ability
7 to progress the development will be dependent on the infrastructure being in place when it is required. Of course, service providers will also have a responsibility to deliver, especially if adequate funds are being made available to them.
23. Whilst a development of this scale will inevitably place pressures on services and infrastructure, it also represents the opportunity to deliver new facilities that can serve not just the new community at Chilmington Green but existing residents too – for example, the creation of the major new strategic park and its associated sporting facilities would not be achievable without development-led funding. Similarly, much needed improvements to the A28 corridor could not be funded solely from the public purse for the foreseeable future.
Objection Point 4: “The development would cause severe environmental damage, destroying the habitats of water voles, dormice, great crested newts, brown hares, snakes, badgers, deer, cuckoos, woodpeckers and bats. The fields around Chilmington Green have been productive for centuries and building on them would be a loss of agricultural capacity and valuable biomass.”
Response
24. Core Strategy Policy CS11 ‘Biodiversity and Geological Conservation’ establishes that a hierarchical approach to dealing with the issue of impact on ecology and habitats should be applied. As a general principle, development should avoid harm to ecological and biodiversity conservation interests and where practicable, enhance them. However, if there are exceptional circumstances where some harm may be justified, the policy requirement is to appropriately mitigate and compensate any impact. This approach is supported within the recently published NPPF (paras. 117-118).
25. Accordingly, a range of detailed ecological fieldwork was undertaken to support the evolution of the AAP to ascertain the extent of ecological and habitat resource on site, and what mitigation and compensation measures might be needed. This included surveys for both protected and non-protected habitats and species (covering great crested newts, bats, breeding birds, reptiles, dormice, invertebrates and badgers).
26. In general terms, the evidence base suggests that the site is not particularly rich in ecological or habitat resource (in part, owing to its current active agricultural use) and is not located within any relevant statutory protected or locally designated areas. However, a number of important species and habitats were noted (including a number of protected ones). In response, the AAP includes a range of measures and policies.
27. Policy CG21 ‘Ecology’, sets out that any locally important ecological networks and semi- natural habitats will not be lost. It also requires that an ecological enhancement and mitigation strategy will be produced to support any planning application. This will establish how any required compensatory measures will be implemented (including that any new areas are suitably established prior to development commencing) and how they will be managed, phased and maintained in the longer term.
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28. The AAP also identifies an area to the south of the proposed built footprint which will play a primary ecology role (this area will include a number of sustainable drainage systems (SuDS) to support water based species, as well as areas for skylarks – a red-listed bird of conservation concern). This sizeable area brings with it many benefits such as the encouragement of greater co-location between species and habitats, as well as making its longer term management easier.
29. In addition, the AAP also proposes a built form that avoids impact on the more sensitive species that were identified (such as roosting bats). In doing so, it also promotes an integrated network of green spaces which provides opportunities for greater connectivity between habitats and species throughout the site and into the countryside.
30. Overall, it is accepted that Chilmington Green (as with most developments) will have some impact on local ecology and habitats in terms of disturbance and areas that will be lost. However, the AAP provides a robust policy framework that will not only avoid harm to the most sensitive areas and species, but will also deliver substantial new and dedicated areas for various species and habitats to thrive. These new areas will far exceed what is currently present on site and will be planned in a comprehensive way.
31. With regards the loss of agriculture land, the NPPF states that where development on agricultural land is necessary (when balanced with other planning factors), local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality, as established through the Agricultural Land Classification. The NPPF confirms that it is only land classified as Grade 1, 2 or 3a (the ‘best and most versatile agricultural land’) that is relevant in this context.
32. To ascertain the quality and scale of agricultural land at Chilmington Green, a survey was carried out on behalf of Ashford’s Future and the Chilmington Green Development Consortium. This survey showed that the majority of agricultural land that falls within the AAP boundary is categorised as ‘Grade 3b’, with a small amount of ‘Grade 3a’.
33. Although not the highest ranked Grade 1 or 2 land, agricultural land that is classified as ‘Grade 3a’ is still considered to be of high quality and capable of consistently producing moderate to high yields of certain arable crops, (especially cereals) and moderate yields of grass, oilseed rape, potatoes, sugar beet and the less demanding horticultural crops. Land that is classified as ‘Grade 3b’ is only considered to be of moderate quality, capable of producing moderate to low yields of certain crops (mainly cereals) and high yields of grasses, principally for grazing purposes.
34. The proposals in the Chilmington Green Area Action Plan shows that the proposed built footprint of the development is almost entirely confined to the lower quality Grade 3b land, and would only encroach onto a very small amount of the higher quality Grade 3a land. However, it is accepted that some additional areas of Grade 3a land might also be lost as a result of the development, where it falls within the proposed green corridors or
9 Discovery Park even though some of these areas may actually remain in low intensity agricultural uses, as complementary ‘green uses’, within the Park area.
35. In total (assuming that no Grade 3a agricultural land within Discovery Park is retained for such purposes) it is likely that around 18 ha of Grade 3a land will be lost or adversely affected by development at Chilmington Green. However this only represents 4.6% of the total agricultural land surveyed, and is very small in scale – certainly in terms of it making a meaningful contribution towards agricultural productivity.
36. On balance, it is considered that the benefits associated with the Chilmington Green development outweigh the impact on agricultural land, particularly as the vast majority of this land is not classified as high quality, in a planning context. This position is consistent with the approach advocated within the NPPF.
Objection Point 5: “We are told that Ashford’s borough councillors only acquiesced to the construction of 30,000 new homes because the council leader at the time stated that failure to do would result in the establishment of a New Town Commission under the control of Whitehall. The Chilmington Green scheme was therefore devised under duress. Since that time, the South East Development Plan has been scrapped and all government development targets have been abolished. Therefore, Ashford no longer has any obligation to be a growth town and can no longer justify the Chilmington Green development on these grounds.”
Response
37. No comment is made on the first sentence, although regardless of whether it is accurate or not, it would be correct to say that the Core Strategy needed to be in accordance with the prevailing regional planning guidance at the time. If not, the Core Strategy would have been found to be unsound or the Inspector would have imposed the requirements anyway.
38. As things currently stand, the South East Plan remains an extant consideration although it is fair to say that the government’s intention to scrap it remains in place. However, the growth targets identified in the adopted Core Strategy will remain in place until a formal review of it has been undertaken. As such, the starting point should still be the policies of the Core Strategy where the Chilmington Green area is identified for a major urban extension.
39. Although specific national or regional growth targets are in the process of being removed, it is fair to say that the government’s intention is clearly to encourage additional house building. The NPPF makes it clear that local planning authorities should “boost significantly the supply of housing” (para.47).
40. In any event, there is a need to roll the Core Strategy forward to 2030 which means a further 9 years worth of development needs to be planned for. Whilst the rate of overall growth may slow to reflect the potential for jobs growth over this period, the preliminary
10 work to support the Core Strategy Review process indicates that several thousand new dwellings will still be needed in the Borough simply to accommodate natural population and household growth to 2030. Development at Chilmington Green has the potential to play a significant role in meeting these future needs, which would otherwise need to be met elsewhere -potentially in areas that previous assessment work (in the GADF and Core Strategy preparation) has shown to have a greater overall impact.
Objection Point 6: “Ashford has suffered from excessive development over the past decade that has led to falling house prices, lower average household incomes, increased unemployment, traffic congestion and stretched public services. The overdevelopment of Ashford resulted in house price falls of 13% in 2011 – the third greatest decline anywhere in the UK. Since the year 2000, approximately 6,000 new houses have been built in Ashford Borough. In addition to this, it was revealed under the FOI Act in 2010 that Ashford Council had granted permission for 6,300 houses to be built which had not yet been constructed owing to weak demand. The council also stated that it intended to grant planning permission for a further 3,000 houses since that time. That equates to a 75% increase in Ashford’s housing stock over the past decade and excludes the proposed South Ashford New Town at Chilmington Green. Ashford already has enough unused capacity to build 500 houses every year for the next 18 years without any development at Chilmington Green.”
Response
41. Firstly, in response to a number of the statistical claims that are made in this objection, the following observations are made:-
i) house price changes – the council’s own house price survey based on a sample of asking prices across the housing market every other year shows that there has been a rise of around 50% in average house prices in the Ashford urban area between 2000 and 2011. Although there has been a decline since the peak in 2007 (about 15%), this is in line with many other locations in the country.
ii) average household income – data on average weekly earnings in Kent show that Ashford Borough residents earned just over £500 per week in 2011 (marginally below the national average). This shows an increase from the average in 2006 which was in the lowest 20% in the country (£300-450 per week bracket).
iii) Unemployment rates – unemployment rates in the Borough have tended to follow the regional trend over the last decade and have fluctuated over this period. They are higher now than a few years ago but this is most likely attributed to the economic downturn rather than as a direct result of additional housebuilding.
11 42. This data suggests that development at Ashford has not had a constraining effect on house prices or average household income – indeed, the opposite could be argued. However, it is more likely that national macro-economic factors probably play a more significant role, in particular, in respect of house price inflation and unemployment.
43. Regarding housing completion data, from 2000 -11, a total of 7362 dwellings had been completed in the Borough, of which 5,626 were in the Ashford urban area. This is an average of 669 dwellings a year in the Borough (highest 962pa, lowest 359pa).
44. The recently released 2011 census data for the Borough shows an approximate 15% increase in the number of households since 2001. Although this is not exactly the same as housing stock, this provides a clear indication of the increase in stock since 2001 (rather than the 75% claimed).
45. The up-to-date position (at 31st March 2012) on extant residential planning permissions shows a total of 4958 dwellings with extant planning permission as yet not started (plus 205 under construction but not yet complete). Further analysis shows the large majority of these are only outline permissions (4295 units – 83%). Furthermore, over 40% of these units are contained in just two sites, namely at the former Powergen site on Victoria Way (1002 units) and at Newtown Works (821 units), where there are significant viability and infrastructure constraints to full implementation. As a result, these schemes are very unlikely to come forward in the form previously permitted.
46. It is too simplistic to assume that all sites with planning permission will come forward in full and within a particular timescale. Some are constrained by motorway junction capacity such as Newtown Works and Cheeseman’s Green and the wider economic conditions currently mean it is more difficult for developers to finance such improvements without assistance.
47. Therefore, it would not be sound for the council to base its planning strategy on such an assumption. Paragraph 47 of the NPPF makes it clear that local planning authorities should base their approach to housing land supply on readily available and deliverable sites and so the strategy must consider more than a simple aggregation of permitted units. To be deliverable, the NPPF states that sites should “be achievable with a realistic prospect that housing will be delivered on the site within 5 years and in particular that development of the site is viable.”
48. A realistic assessment of potential deliverability in the foreseeable future indicates that a combination of extant planning permissions and allocations in the council’s various Development Plan documents might deliver around 4,800 dwellings, excluding any development at Chilmington Green – significantly less than is claimed in this objection. This equates to a potential supply of around 270 units per year to 2030.
Objection Point 7: “It is unwise to construct a new town with a high street that will compete with Ashford town centre. Shop vacancy rates in Ashford town centre
12 have increased dramatically over recent years and the proposed development at Chilmington Green would ensure that Ashford town centre continued to decline.”
Response
49. Again the starting point for responding to this point is the Core Strategy. Para 12.9 states that the ‘Ashford urban extensions are to be served by a new ‘High Street’ which should include retail provision suitable to serve the needs of the locality. This should involve the provision of small to medium size foodstores and a limited range of services but not major comparison goods retailing or superstores that would have a much wider catchment’.
50. Policy CS16 ‘Retail’ goes onto say that retail development should be provided at the urban extensions at an appropriate scale to serve their local needs, without having a detrimental impact on the existing hierarchy of retail provision. Ashford Town Centre clearly sits at the top of this hierarchy, as this is where most retail provision for the Borough should be focused.
51. The NPPF (para. 23) reaffirms the Core Strategy position and repeats much of the guidance contained within the old Planning Policy Statement 4 (which was relevant at the time of writing the Core Strategy). The NPPF (para. 70) clearly places an emphasis on retail being targeted towards Town Centres first and also advocates the role of neighbourhood centres, supported by retail uses, to play a key focal point role for communities.
52. To establish the amount of retail provision which should be delivered at Chilmington Green to accord with Policy CS16, a retail evidence base report was produced by specialist retail consultants to the support the evolution of the Area Action Plan. This report took into account a number of factors, including: - the number of proposed houses (5,750) now being suggested in the AAP; - Chilmington’s likely position in the retail hierarchy once the development is in place; - existing retail planning permissions; - planned retail and population growth in the urban area (including the figures in the adopted Town Centre Area Action Plan and the emerging Urban Sites and Infrastructure DPD; - the nature of the built form proposed at Chilmington Green; and, - the need for retail provision to compete (in a local context) with other out-of-town centres to avoid leakage of retail spending to these areas.
53. The report recommends a figure of approximately 8,500 sq.m. of retail floorspace (comparison and convenience) including a medium size foodstore (3,100 sq.m.) to support the Chilmington Green development. It is worth noting that this retail provision is part of a wider pattern of provision of services and facilities (such as indoor sports space and local employment space) which are intended to complement each other, as part of the delivery of the proposed District Centre.
13 54. Overall, the scale and breadth of retail provision proposed in the AAP is consistent with para. 12.6 of the Core Strategy and will not compete with Ashford Town Centre (and its planned expansion). Instead it will cater for local needs and contribute to the type of place which is aspired to in the Core Strategy and AAP. A lesser scale of retail provision would necessitate far more car based trips, deliver a much less sustainable development overall, and be inconsistent with the Core Strategy and current Government planning guidance.
55. In this context, it would be wrong to make a direct connection between retail development at Chilmington Green and shop vacancy rates in Ashford Town Centre. Whilst acknowledging vacancy rates have increased in the last 3 years, this is fundamentally linked to the demise of a number of High Street chains and the difficult economic conditions, in common with many other locations. Indeed, it could be argued that the additional spending potential in the Ashford retail catchment arising from the Chilmington Green development may have a beneficial impact on trading conditions in the town centre in the future.
Objection Point 8: “The planned growth of Ashford has been predicated on additional water supplies being made available from Bewl Water and the construction of an entirely new reservoir at Broad Oak. The Broad Oak reservoir scheme appears to have been abandoned and Bewl Water is in a state of crisis with water levels at historic lows for the time of year. Given that a drought has already been declared in Kent and the water companies have already introduced restrictions based on their inability to meet Ashford’s existing demands, how will they cope if Ashford increases in size by circa 15% following the construction of a New Town at Chilmington Green ? The introduction of water restrictions appears to be an admission by the water companies that there is not enough water. Pushing ahead with development without increasing water supplies will have severe consequences for everyone who lives in Ashford.”
Response
56. The current Water Resources Management Plan (WRMP) for South East Water (SEW) runs from 2010 to 2035. Work is progressing on updating the WRMP with a view to a draft being published for consultation in March 2013 in preparation for adoption in 2014/15 to cover the 2015-40 period.
57. Alongside these run 5 year ‘business plans’ or ‘Asset Management Plans’. The current AMP5 covers 2010-15 with the review of this commencing in 2013 to look at the 2015-20 period (AMP6).
58. The SEW supplied area is divided into different ‘resource zones’. Most of Ashford Borough, including Chilmington Green, lies within RZ8, where the large majority of potable supply comes from groundwater resources and not reservoirs. In fact, there is enough capacity in this area that, at the current time, RZ8 is a net exporter of water supply to other parts of the SEW region.
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59. South East Water has the strategic infrastructure in place, or in plans, to meet all predicted requirements for the 2035 WRMP. This would be funded by the company and would not be reliant on 3rd party funding.
60. In relation to the planned Broad Oak reservoir, this remains part of the company’s plans as set out in the WRMP. However, it would not be required until the late 2020s on current estimates of demand. These estimates include the South East Plan and Core Strategy growth targets for the town. As growth targets across the south-east are likely to generally reduce compared to the South East Plan figures (for example, Chilmington Green itself is now proposed in the AAP for a reduced scale of 5,750 dwellings), it would be reasonable to suggest that Broad Oak reservoir could actually be delivered later than envisaged. This will be a matter for the draft 2015-40 WRMP to address.
61. In addition, South East Water has made formal comments on the draft Area Action Plan, as part of the recent public consultation. These support the overall policy approach advocated in the AAP and reiterate their desire to work closely with the Council to ensure that Chilmington Green is adequately served with water.
62. With regards to drought and water restrictions, it is important to note that the water companies plan for such fluctuating environmental situations both through their budgets and charges, as well as their strategic business planning. Therefore periods of drought do not often significantly affect the water company’s’ ability to deliver an appropriate level of service, as they have already been catered for. This is also true when there are periods of heavy rainfall, such as those experienced this summer.
63. It is clear that the water company’s forward planning for their resources has accounted for major development at Chilmington Green and, in fact, the wider Ashford area. Short-term fluctuations and longer–term changes in weather patterns are expected and planned for. There is no evidence that the development of Chilmington Green will place an undue burden on water supplies in the future.
Objection Point 9: “The Core Strategy states that the development of Chilmington Green will result in 7,000 houses and 1,000 jobs. The plans appear to suppose that there will only be 1 additional job per 7 additional households. If there are two people living in each new house, there will only be 1 local job per 14 people. As there is no industry or business in Ashford that wishes to recruit large numbers of additional staff, the construction of a new town will make it significantly harder for local people to find jobs and cause unemployment to increase.”
Response
64. The Core Strategy has already established what the appropriate balance of houses and jobs should be at Chilmington Green, taking into account the location and type of development envisaged. In this context, the ratio of one job per 7 households can be derived, as suggested by the objection.
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65. However, this point fails to take into account that the draft Area Action Plan now promotes a policy framework which delivers far fewer homes (5,750), yet still seeks to deliver at least 1,000 jobs (in line with Policy CS5). In fact, the AAP actually envisages that 1,184 jobs will be created at Chilmington Green – a figure which doesn’t take into account those residents who will work from home, a significant and expanding sector of the workforce. Given this, the assumed ratio of 1 job per 7 houses is no longer relevant. In fact, the AAP is now proposing a far more balanced development at Chilmington Green, than envisaged in the Core Strategy.
66. This objection also fails to take into account the role of other areas around the Town, which are proposed to play a primary employment function. For example, 1,803 additional jobs are proposed at Eureka Park and Sevington by 2017, with a further 8,160 additional jobs planned in the Town Centre by 2021. For a fair and balanced view, Chilmington Green must be seen as part of the wider growth strategy for the town as a whole, and not in isolation, as this objection is doing.
67. The second part of this objection makes a separate point. It needs to be remembered that the Chilmington development is expected to take about 25 years to complete. Over this time major jobs growth in the town is likely in a variety of locations. In fact, it may be argued that there would be less chance of business investment if there is a perception that there is an insufficient local labour supply or housing opportunities for people to move into from elsewhere. This is a key issue for inward investors. There is no fundamental reason why unemployment should increase as this is determined by the availability of jobs which may be inside or outside the Borough.
b) Additional objections to the principle of development at Chilmington Green
Representations were received from the following consultees:
14 – KTI Energy Limited 105 – Sarah Keaveney 207 – YPS Accounting (Bill Temple-Pediani) 141 – P Purnell Sevices Ltd (Mark 23 – Peter Williamson 142 – Sarah Stanfield Sandells) 31 – David Richardson 143 – R M Hayward 208 – Ashford Green 37 – Mr Wilson 144 – Donald Fagg Party (Steven Campkin) 39 – Cllr Jim Wedgbury 146 – Mr T R Lacey 209 – Elizabeth Eyre 53 – P G Churcher 153 – Cllr A Mortimer 210 – Nigel Christian 56 – Raymond Woodcock 166 – Yvonne Carole Ho 211 – Catherine Stevens 59 – Roger Coker 167 – C Craib 212 – Antony Bartlett 62 – Martin Carter 168 – Julia Spooner 224 – L Donaldson 63 – Ian Sleeper 176 – Ashford 225 – Lillian Brookes 65 – Michael Dowsey Independent Party 226 – Shirley Ambrose 70 – Lionel Goddard Executive 228 – Independence & 74, 76, 77, 78, 81, 83 – 178 – Fiona Birrell Access Matters Daniel Hammett 183 – D A Craib (Francoise Montford) 97 – Dunster 206 – Mick Carr 229 – Ken Scrivner 98 – Spencer Dorey 232 – Christine Rees 100 – Stuart Akers 241 – Jerry Preston-Ladd
16 246 – Joanne Brand 335 – Alexandra Procter 484 – Alice Frohnsdorff 253 – Yolanda Barker 337 – JA & MR Morris 514 – Linda Cleaves 257 – Central Ashford 375 – Nicola Hawkes 515 – Robert Hughes Community Forum (Emily 378 – L Kemp 518 – Judith Knight Neighbour) 385 – Brenda Hedley 519 – Sarah Dacre 259, 260, 263 – Margaret 414 – Sharon Kelly 522 – Cllr W Michael Cook 417 – JP Palmer 523 – Nicholas Chaplen 268 – Mason Brannan 423, 429, 430 – JR and Eleanor Jeffrey- Design Partnership (Keith Carpenter Chaplen Brannan) 454 – Kenardington 524 – Keep Chilmington 276 – Cllr Peter Davison Parish Council Green (Max Frohnsdorff 277 – Linda Cleaves (c/o 459 – Wittersham Parish 531 – Keep Chilmington D Jarman, Hobbs Parker) Council Green (Max Frohnsdorff) 313 – John Holland 460 – CPRE Ashford 533 – G Richardson & M 315 – Zoe Snazelle (Hilary Moorby) Ransley 329 – Ian Procter 463, 468 – Great Chart 331 – Carol Procter with Singleton Parish 332 – Ross Procter Council
i) Local opinion
68. Representation 31 states that although public consultation was involved, the outcome failed to demonstrate that there was any reasonable possibility of the outcome being any different. Consultations must have a reasonable expectation of influencing the outcome for them to be valid.
69. Representation 53 feels that the people of Ashford should have been consulted before the proposals got as far as they have.
70. Representation 59 considers that if something was done about tightening immigration laws there would be enough housing, health care, and quality education for the over populated country.
71. Representation 62 states that if the council has a desire to continue building houses why don’t you pursue this obsession in the Waterbrook Farm area off Junction10 of the M20 where the roads infrastructure is already in place and the landscape has been scarred already and lays abandoned?
72. Representation 63 states that you have to stand up to the developers for the sake of quality of life. Representation 63 also finds it amazing how you keep picking on this side of Ashford for development and ignore the Canterbury side.
73. Representations 76 and 77 states that the stakeholder forum and various detailed planning days never included ordinary people and additional consultation events didn’t discuss whether the development at Chilmington Green was wanted or not. Therefore, local people have never had a chance to voice their concerns on the proposal. The stakeholder forum only included parish councils, landowners, developers and the Borough Council.
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74. Representation 97 considers that the national requirement for housing needs to be seen as a whole and not just develop areas close to London.
75. Representation 141 feels that with this many houses, schools will speak 5 languages.
76. Representation 146 states that the June 2000 Development Plan mentions no figure above 280 dwellings which puts the present target of 5750 homes into the realms of megalomania. CG3 Appendix 6 sums up the patronising manner towards the present community. If the existing community do not cooperate the question is raised as to whether a new parish council will be up in such a contingency.
77. Representations 176 and 276 state that no development should be take place until the Core Strategy has been reviewed.
78. Representation 178 Ashford is a historic market town, which is defined by the surrounding countryside. It does not have the same attributes as larger surrounding towns. Further development, will continue its decent into a non-descript town, made up of joined on housing estates.
79. Representation 206 considers that these homes are for immigrants?
80. Representation 209 states that although people in Ashford are aware of future development, people were not aware of the extent of it. The comment states that the council has made little effort to make this widely known to the population.
81. Representation 257 considers development of the site is unsustainable because it is a distance from amenities. Amenities should be proportionate to proposed population. 225 further objects to the development, because it is unsustainable and it will prevent Ashford functioning.
82. Representations 23, 276, 519 and 531 consider that people do not want the development and have signed a petition. Representation 268 wants greater recognition to be given to local opinion.
83. Representations 153, 167, 212, 246, 276 and 519 feels that if localism means anything then it should be for the community that will be affected to decide what will happen and not the planners and developers. Local people do not want this development and have signed a petition.
84. Representations 56, 142, 176, 212, 228, 518, 524 and 253 consider the evidence which the AAP is based on is flawed and/or out-of date. Representation 142 notes that new figures need to be ascertained as to the true housing needs for local people due to the recession. Representations 228 and 524 state that targets for Ashford’s growth were about 10 years ago and have since been abolished. Representation 176 outlines that the job creation and projected housing numbers seem to confirm that the statistics are
18 seriously flawed, in that projections are too high. Representation 56 adds that a Housing need assessment has not been undertaken.
85. Representations 176, 183 and 423 it should be borne in mind that Shepway Council have also got plans for massive construction on Romney Marsh. If the Shepway scheme and the Chilmington Green go ahead this part of the south east will be changed beyond recognition
86. Representation 253 and 276 states that for the residents of Great Chart, Singleton, Shadoxhurst, Great Chart and further afield their quality of life would be decreased or be destroyed if the development goes ahead. Representation 253 states that the general quality of life of residents will be affected.
87. Representation 268 states that greater attempts should be made to positively consult with existing communities that are effected by the proposals.
88. Representation 276 wants to know why the Council is not listening to the Shadoxhurst, Singleton, Great Chart, Chilmington Residents? It is difficult to give a constructive response.
89. Representation 337 feels that someone has a ‘bee in their bonnet’ and will now not let it go, but are determined to continue with the plan.
90. Representation 484 considers the short and long term effects on the area will not only detrimentally prejudice you and me, but also the next generation, who will have to live with the selfish decisions of a minority who are not in touch with the wishes of the majority.
Response: See response to objection point 1 above
ii) Impact on countryside / environment
91. Representations 37, 53, 63, 105, 142, 143, 153, 166, 178, 208, 211, 226, 263, 277, 315, 337, 378, 514 and 519 expressed their concern over development of the countryside, as it was considered concreting over ‘green belt’ land, especially when there are brownfield sites available in the existing urban area. The representations also outlined that the countryside was particularly attractive, peaceful and tranquil in this area and once developed it could never be returned to its former state. In general, it was stated that the Chilmington Green Development would majorly impact on the countryside. Representation 208 adds further development could leads to further development.
92. Representations 23, 53, 56, 142, 144, 153, 167, 206, 208, 228, 241, 246, 253, 276, 423, 459, 519, 522, 524 and 531 state that brownfield sites should be used first.
93. Representation 166 feels that you could renovate a lot of derelict houses and have them sold to people.
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94. Representation 207 question why develop Greenfield sites. A significant proportion and percentage of properties within the confines of the Ashford ring road itself are in a poor state of repair and a number of them are empty.
95. Representations 208, 232, 246 and 484 outline that empty houses should be used first.
96. Representation 375 considers the most important thing for ABC is to do the best thing for its residence and not what's best for those wishing to concrete over our countryside even if it means taking a step back and looking at the situation with a fresh perspective and not the preconditioned minset that has developed over recent years.
97. Representations 423 and 414 states that the hamlet comprises 10 listed buildings dating back to the twelfth century and is ‘a near perfect example of an agricultural settlement’, as stated by the Society for the Protection of Ancient Buildings. This will be ruined by this development.
Response See response to objection points 1 and 2 above
iii) Services and Infrastructure
98. Representation 519 states that critical infrastructure must be delivered in step with housing development.
Response See Council response to objection point 3 above
iv) Environmental Damage
99. Representations 53, 143, 210, 211, 277, 315, 337, 378, 423, 484, 514, 519 and 523 outline that there is an abundance of wildlife, birds and plants at CG which will be disturbed if development goes ahead. A number of representations list the endangered and protected species that are present (e.g. bats, water voles, dormice, badgers, brown hares, and great crested newts etc. please refer to 519 for a comprehensive list) Historic hedgerows are also cited as a species rich habitat, in addition to key amphibian sites. Representation 211 acknowledges that the provision of Discovery Park is ‘green-space’ but outlines that the parkland won’t attract the same amount of wildlife as is currently on the site.
100. Representations 53, 56, 176, 183, 210, 224, 225, 228 and 246 feel it will create a loss of agricultural / food producing land.
101. Representations 329, 331, 332 and 335 feel that there would be irrevocable damage that will be done to the natural environment. CG and the surrounding areas are naturally very beautiful and productive, they are also home to a diverse and important variety of wildlife.
Response: See Council response to objection point 4 above
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v) Justification for Chilmington Green
102. Representations 98, 178, 232, 241, 468, 524 and 533 states that the prospect of urban extensions and the Ashford Growth are only came about as a result of the Sustainable Communities Act, from the previous Labour Government, effectively imposing them on us. Now that this target has been scrapped, there is no local need or desire for this development to take place. Representation 232 adds that “Does Ashford Borough Council questions whether the so-called millions of grants are still going to be available in this recession?”. Representation 375 adds we are in a different economic climate to what we were in 10 years ago
103. Representations 65, 176, 423 and 524 state that ABC can no longer blame central government for forcing their hand. They can change the Core Strategy if they want to. Representation 524 adds the Core Strategy is an obsolete document that must urgently be replaced by policies that accurately reflect economic reality and the aspirations of local residents. Representation 176 adds “why Ashford is under such pressure to build so many houses, especially when the South East Plan has been thrown out?” Representation 423 adds development will affect CG and the wider community for years to come.
104. Representations 329, 331, 332 and 335 are concerned that ABC together with the promoters seem unwilling to consider anything that challenges their vision for the future. This is evident in the unwillingness to change the Council’s commitment to the South East Plan (2009) and the implied inevitability expressed with the consultation document and other communication methods.
Response: See Council response to objection point 5 above
vi) Housing Supply
105. Representations 56, 97, 100, 142, 228, 229 and 276 consider there to be enough existing extant planning permissions in the Borough.
106. Representations 153, 241, 454, 484, 524 and 533 consider the demand for housing to be falling, there is therefore no need for more.
107. Representations 176 and 531 state that in 2011 local Ashford house prices were reported to have dropped by 13%.
108. Representations 176 and 531 consider the current building rate to be excessive
109. Representations 241, 253, 423 and 524 feel that there is enough existing housing supply in the borough.
Response: See Council response to objection point 6 above
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vii) Impact on the Town Centre
110. Representations 53, 100, 146, 167, 176, 228, 246, 417, 423, 430, 519, 522 and 531 consider a new town to compete with the existing town centre. Chilmington Green, with a Town Centre including a supermarket with an immediate customer base of some 15,000 residents plus those from Great Chart, Singleton, Brisley Farm and Shadoxhurst, will inevitably be in competition with Ashford Town Centre, the very thing that the original plans said should be avoided. Representation 167 also adds that it could affect Tenterden High Street. Representation 53 states development at Chilmington will be the final nail in the coffin for the Town Centre. Representation 522 adds the continuing decline of the Town Centre it is far more logical to encourage small scale developments around the Town. These can be more easily absorbed within their existing surroundings and will not demand in their own right shopping precincts that draw footfall away from the Town Centre. Representation 417 states the supermarket will also add further destruction to Ashford Town centre as they will sell all consumer goods as all supermarkets do.
111. Representations 65, 207 and 531 states that a significant proportion and percentage of properties within the confines of the Ashford ring road itself are in a poor state of repair and a number of them are empty. Representation 207 adds “How on earth, is any local business supposed to attract new works for Ashford when quite clearly the focal point, ie the town centre is quite frankly an eyesore.” Representation 531 adds that the town centre is now characterised by pound shops and charity shops.
112. Representations 166, 337, 423, 519 and 523 consider many of the shops in the existing town centre are already vacant and there are already too many supermarkets in Ashford. Representation 225 adds there is no descent town centre anymore- shops closing, too few local amenities.
Response: See Council response to objection point 7 above
viii) Water supply
113. Representations 23, 39, 53, 56, 65, 70, 97, 105, 142, 144, 153, 178, 183, 210, 225, 226, 228, 229, 241, 253, 257, 276, 313, 329, 331, 332, 335, 337, 378, 417, 423, 454, 460, 484, 519, 522, 523, 524, 531 and 533. These representations outline that there is inadequate water supply to supply the development and should the development go ahead this will have a detrimental impact on the water supply of existing residents.
Response: See Council response to objection point 8 above
ix) Jobs and the local economy
114. Representation 14 states that the target is to create 1.5 new jobs for each dwelling planned at CG. That means the onus falls upon the Council to create 8,625 new jobs and not the dismal 1,000 described in its AAP. How those jobs are to be created, which
22 Ashford's Future dismally failed to achieve, is by zoning a large part of Ashford as a Green Enterprise Zone.
115. Representations 53, 59, 65, 142, 166, 210, 226, 253 and 385 state that Ashford already has high unemployment, which will be made worse by an increase in the population. Representation 142 acknowledges under 25’s unemployment is particularly high. Representation 226 questions how will jobs be created in the long term? Representations 166 and 253 state that the existing community will find it harder to find work. Representation 59 states that no houses should be built until this issue is addressed.
116. Representations 70, 81, 98, 144, 246, 337 and 375 consider that the jobs created by a ‘new town’ will certainly not sustain the amount of people that would be living there. A target of 1000 jobs against 5750 homes will force the majority of residents to travel elsewhere to work. More attention needs to be given to providing local employment rather than creating another dormitory village. Representation 144 states Ashford would not be able to meet the job need.
117. Representations 74, 78, 168, 515 and 523 consider the ratio of jobs to houses to be too low. Representation 168 adds 3350-7000 dwellings with only 600-1000 proposed jobs. Even with only one person working from each dwelling there will be a shortfall of 2750- 6000 jobs. It is likely that this number will be higher. Representation 78 adds at least 75% of working households will need to find employment outside the borough. Representations 515 and 523 adds the job opportunities may not necessarily be offered to the local residents. Hence by necessity the proposed estate will become a 'commuter estate' /dormitory town.
118. Representations 176 and 423 Ashford Borough job creation targets have not been met over the last 10 years and fall short by some 40%. There can be no guarantee that speculative building of large numbers of new houses will bring the commensurate number of new jobs.
119. Representations 208, 375, 378, 423 and 519 consider the competition for the local jobs which are created will increase with any influx of new residents. Representation 208 believes the claims of job creation will be outweighed by the movement of new people into the area, ie; jobs created = 1184; new residents (our estimation, assuming all properties are filled) = 12,000. Unemployment in Ashford is already approx. 2000. Representations 375 and 519 clarify this by stating that the construction of a new town will make it significantly harder for local people to find jobs and cause unemployment to increase.
120. Representations 375 and 519 point to the Core Strategy which states that the development of Chilmington Green will result in 7,000 houses and 1,000 jobs. The plans appear to suppose that there will only be 1 additional job per 7 additional households. If there are 2 people living in each new house, there will only be 1 local job per 14 people. 519 is the same comment, but quotes 1 additional job per 6 additional households and 1 local job per 12 people.
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121. Representation 430 considers it difficult to believe that 1000+ jobs will be created just through retail and services serving local area. Most proposed jobs appear to be low grade minimum wage retail – hardly basis for a sustainable community. Also it is not realistic to expect so many jobs new jobs in education and health when the public sector is contracting and all the signs are that it will continue to do so for some time.
Response: See Council response to objection point 9 above
122. Representations 329, 331, 332 and 335 recognise the Borough Council’s commitment to addressing the decline of Ashford town centre. However we are concerned that promoting out of town developments such as this, risks countering the benefits of town centre regeneration strategies. Successful commercial and social regeneration of towns and cities involving repopulation of the centres is well documented. We believe that investment of this level of political commitment and capital should be directed to the town centre and its immediate areas as the first priority.
123. Representations 259 and 463 consider high streets to be failing nationally as shoppers prefer space and facilities they can access by car. This is evidenced by Ashford’s many out-of-town retail parks eg McArthur Glen, Eureka Park etc which have exacerbated difficulties being experienced by Ashford town. A positive strategy to bring new life to the town would be to develop available brown field sites and empty properties in the town centre as residential schemes. Both the NPPF and the Core Strategy state that brown field should be developed first. The requirements of the NPPF and the needs of the town and the community should be served before the profit for developers.
124. Representation 246 feels that a far better solution would be to invest in Ashford Town Centre by extending the County Square shopping centre along Elwick Road.
125. Representations 100 and 228 adds the town centre is literally being strangled by restricted road access, exorbitant business rental rates, inflexible parking solutions, and global recession. Shop owners/tenants are already struggling with high rents and business rates and property prices have also fallen dramatically.
126. Representation 429 states that there are many homes in and around the town centre yet it is full of empty shops and struggles to pull in shoppers. Why is it likely that this new town centre will fare any better in attracting businesses and shoppers. The Town Centre clearly sits at the top of this hierarchy, as this is where most retail provision for the Borough should be focused.
127. Representation 459 state a number of shops in Tenterden have closed as a result of the economic downturn. Tenterden attracts significant trade from those who live outside the immediate area. It is felt that another competing High Street from a town twice its size might lead to further loss of businesses.
24 128. Representations 83 and 484 consider job creation figures to be optimistic with much of Ashford Town Centre in seeming decline as evidenced by the increasing number of pawn shops, pay cheque cashing shops, discount and pound shops. 484 The economy in Ashford is at its lowest ebb; business premises are disappearing at an alarming rate.
129. Representation 141 considers there to be no leisure facilities for Children and the elderly stay away from the shops due to the people that shop there. There are more people working in Debenhams than shoppers.
Response: See Council response to objection point 7 above
c) Additional points of principle objections to Chilmington Green
130. Representations 241, 524, 260 and 531 consider job in Ashford to be of low quality and overly dependent on development - this is economically unsustainable as further development only worsens the imbalance and increases the rate of dependency and relative decline. This increasing imbalance between jobs and housing, and the fact that the jobs themselves are becoming lower paid, raises a serious question as to the sustainability and soundness of this development and its compliance with policy CS7 of the Core Strategy (Representation quotes figures from the Ashford SHMA). Representation 531 adds housing growth in the absence of underlying economic growth has caused Ashford to become increasingly poor and to underperform relative to surrounding boroughs.
131. Representations 241, 260, 524 and 531 state that ABC based their case for development at CG on a report by consultants G L Hearn Strategic Options Report (2012). This report states that employment in Ashford has grown by some 7,000 jobs since 2001 and it assumes there will be a rapid return to strong growth levels in national and local economies and a subsequent level of population growth in Ashford that exceeds that for any other area in the South East. • However, data from the ONS shows that in the last eight years there has been a net decline in total employment of 600 jobs despite an increase in population of over 10,000 and the housing stock rising by nearly 4,100 units. • However, using figures quoted in the Annual Monitoring Reports, the number of jobs in the borough in 2006 totalled 56,000 and by 2010 the total was 55,400 - a reduction of 600 jobs when, in the same period, new house completions totalled 2,517.
132. The proposed development at CG is projected to provide only 1,184 jobs against a housing increase of 5,750, thereby creating an even greater imbalance in the local economy. That means the AAP proposes a development that would result in 11.65 new residents per 1 new job, which would make the plan a net drain on the local jobs market and increase local dependency on employment opportunities outside the borough.
133. Representation 276 feels that the AAP should not have gone out to public consultation until all Councillors were satisfied that the statistical projections have a sound base. Data
25 points to jobs growth of less than 400 pa and substantially fewer houses than the Council predicts. GL Hearn’s projections are based on the irrelevant boom years, fail to take into consideration people working longer, and those returning to work who already have housing. Ashford Independent members have compiled and are still compiling evidence on the irrelevance of GL Hearn’s statistics.
134. Representations 329, 331, 332 and 335 see little to support the economic argument for development especially as the justifying growth figures and other data are outdated as they are drawn from the South East Plan of 2009, which is soon to be cancelled.
135. Representations 228, 375, 417 and 523 feel that no major new employers have been attracted to move to Ashford, so where will the jobs come from? Representation 523 adds it is hard to envisage that an estate on the outskirts of Ashford will attract business of any size to fulfill the promised employment opportunities.
136. Representation 313 compared with neighbouring areas (i.e. Maidstone, Medway), Ashford has a poor record in attracting new industry and what has been achieved merely replaces some of the losses experienced during previous years.
137. Representation 522 considers that there is no evidence that the underlying economic indicators make this development necessary or essential.
138. Representation 212 considers the proposed development is economically unsustainable and exceeds credible jobs led demand.
139. Representation 153 feels that the jobs trajectory is such that the numbers are unsound.
140. Representations 97, 484 and 519 consider reliance on London for the main jobs market along with the service sector will increase the feeling of a dormitory town rather than a vibrant local economy. 519 adds a commuter estate that adds nothing to the local economy other than the increased burden of providing services for the residents.
Response
141. In addition to the points made in response above, these representations primarily address issues that are currently being considered in the council’s review of the Core Strategy. The GL Hearn report that is referenced examines a range of potential job growth scenarios for the Borough to 2030 based on different micro and macro-economic assumptions. Even on their most pessimistic scenario for jobs, it is still expected that Ashford can expect jobs growth in total to 2030 albeit on a lesser scale than has been experienced on average over the last decade.
142. In conjunction with the predicted household formation expected over the next decade, this is likely to mean a requirement for new housing in excess of that proposed at Chilmington Green over the next 25 years. Therefore, even if proposed growth in the Borough is not to be taken forward at the rate and scale envisaged in the South East Plan or the Core
26 Strategy, there remains a sound and justifiable argument for a sustainable urban extension of the scale proposed in the AAP.
143. The GL Hearn led work considers the sectors of the economy that might be expected to be most successful in Ashford as a result of its location, accessibility and market advantages. Whilst the local skills base is an acknowledged issue in the success of the future local economy, significant areas of land have already been allocated for a variety of sectors and types of economic development, e.g. the Commercial Quarter in the town centre, Eureka Park, Orbital Park and Sevington. These areas alone are expected to accommodate thousands of new jobs in Ashford.
144. Commuting rates are one of the variables considered by GL Hearn in their work. These can be affected by several different factors such as the availability and attractiveness of jobs elsewhere as well as in the local area. In reality, residents of Ashford may decide to work outside the Borough and vice versa.
27 THEME 2 – VISION AND OBJECTIVES
Representations have been received from the following consultees:
9– Rita Hawes 280, 281, 282, 309 – 476 – Kingsnorth Parish 39 – Cllr J Wedgbury Chilmington Green Council 68 – Nanibabu Magar Developer group 491 – Kent County Council 79 – Daniel Hammett 350, – Kent Wildlife Trust 509 – Highways Agency 177, 179 – Angus Willson 427 – JR Carpenter 539 - Trevor Hall (Kent 233 – Natural England Police)
a) Flexibility of Approach
145. Representation 476 generally agrees to the flexibility of the proposed plans which allow changes to be made if and when circumstances dictate. However they are concerned that this approach could become too flexible which could allow major changes to be made without proper consultation.
Response
146. In response to representation 476, the AAP is clear that it adopts a reasonably flexible approach, which balances the need provide clear guidance with the need to allow the policy position to react to changes. This is particularly important given the long timeframe of the plan. However, the AAP also makes it clear that the policy position in the AAP will be reviewed regularly (every 7 years1). In addition, Chapter 11 of the AAP makes it clear how the process of handling the planning application will be dealt with to ensure that the aspirations of the AAP are met and control is retained.
b) Viability
147. Representation 280 is from the development consortium. They argue that the current wording in Para 1.22 is misleading in suggesting that a phase 1 assessment will be undertaken in the context of only phase 1 costs and revenues. They suggest an alternative form of words:
“Due to the length of time of the build out period for Chilmington Green, any viability case made as part of the outline planning application will initially focus on the first phase. However, this first phase will be assessed in terms of the anticipated costs and revenues of the whole development. Subsequent phase assessments will update the information on costs and revenues, including the actual figures from earlier phases.”
148. Representation 281 (also from the development consortium) goes onto question the concept of ‘catch up’ (para. 1.24) in later phases as this brings a significant element of financial uncertainty to the financial modelling of the development which in turn could
1 Now being proposed to be changed to every 5 – 7 years in light of comments made on the Area Action Plan. Please refer to the schedule of proposed minor amendments.
28 make it difficult to attract finance at the start of the project. They propose the deletion of Para 1.24 of the AAP.
Response
149. The approach to the viability of development is a matter of ever-increasing importance as has been made clear in recent government announcements and policy initiatives, not least in the NPPF. However, predicting with any degree of accuracy what the viability of the Chilmington development will be in its latter phases is impossible and so the AAP position allows for a flexible approach to be taken as economic circumstances may change over time.
150. It would be unrealistic to expect a robust viability position for the whole development to be based entirely on today’s values and costs and would fundamentally undermine the AAP’s desire to deliver a truly cohesive, sustainable and quality development at Chilmington Green. As such, the starting point must be that all infrastructure contributions justified by the Chilmington development will be sought and the aim should be to deliver all of these by the end of the development’s construction.
151. In response to representations 280 and 281 would appear to want to treat the development at Chilmington Green as a series of sites, rather than a collaborative whole. Whilst there may be a justifiable case (although none has yet been provided) for a re-phasing of some contributions initially due to current economic conditions and the scale of up-front key infrastructure costs, there is no justifiable reason why, if conditions improve, additional contributions to make up any initial shortfall should not be forthcoming. This is the principle the council currently employs in its approach to ‘deferred’ contributions on smaller sites. Therefore, no proposed changes to the AAP are recommended on this issue.
c) Vision and Objectives and Policy CG1
152. Representation 9 supports the vision and objectives section of the AAP and considers Chilmington Green an exciting project. Representation 68 agrees that the development is interesting, and that the UK requires an annual housing increase. Representations 177 and 179 think that the introduction section is clear and comprehensive and that the vision sets a clear and high level of aspiration. Representation 309 supports Policy CG1 as the think it sets out clear and logical development principles.
153. Representation 79 feels that the community objectives will be difficult to achieve with 75% of working households having to commute to work. Those people are going to find it tough to engage with their community. That means that the community volunteers are unlikely to be fully demographically representative of their communities.
154. Representation 233 welcomes the vision but if feels it would be appropriate to include some reference to the commitment to enhancing the natural environment, insofar as this message runs through the rest of the document. Representation 350 also wants to see
29 more references to the importance of natural habitats within the network of green spaces and additional wording should be added to Policy CG1 to provide clarity within the development principles on this issue.
155. Representation 539 feels that the vision should include mention of delivering low crime and disorder and fear of crime in accordance with the NPPF which states: 'Planning policies and decisions should aim to ensure developments: create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion; It adds: 'Planning policies and decisions, in turn, should aim to achieve places which promote: safe and accessible environments where crime and disorder, and the fear of crime’.
Response
156. Supporting representations are noted.
157. Responding to representation 79, the Council accept there is likely to be some commuting from Chilmington Green, as is the case with most development. However this, in itself, does not mean that community cohesion and engagement will necessarily suffer. Given the size of the community created at Chilmington Green, there will be a number of different people and demographics residing here, not simply workers community elsewhere.
158. In response to Representations 233 and 350, the vision already includes references to the natural environment, as it states that Chilmington Green will be a place that ‘respects and integrates heritage buildings, landscape features, and woodland and wildlife habitats as part of a well-planned layout.’ In addition, the importance of the natural environment is already referenced under Policy CG1 (e & f), which means that this issue is at heart of the place-making agenda here already, without anymore references needed.
159. In response to Representation 539, the Council fully support the aspiration the development should take into account the issue of crime and fear of crime so that development can create safe and accessible environments. However, there is no need for the AAP to simply repeat what is in the NPPF. In addition, Core Strategy Policy CS1 D already covers this issue. This policy remains relevant, and will be applied when detailed plans for the area are explored as it is at this detailed stage where such issue will be addressed in more detail.
d) Achieving the Vision and Objectives and Policy CG2
160. Representation 282 supports Policy CG2 as it sets clear priorities for the number of new homes and jobs at Chilmington Green and the respective roles that will be undertaken by the District Centre and the local centres. Representation 491 (Kent County Council) supports the overall quantum of development and the analysis of need. They accept the
30 reduced dwelling figure as a means of delivering high quality development which supports the expansion of Ashford.
161. Representation 39 believes the overall number of dwellings and density is too high and should be reduced to 4000 dwellings and that the proposals include too many smaller flats, which Ashford has an oversupply of, and not enough bungalows or executive houses.
162. Representation 509 (the Highways Agency) is concerned with the reference within Policy CG2 which states the development will deliver ‘at least’ 1,000 jobs. Whilst it would seem likely that the proposed reduction in overall housing numbers will compensate for any additional traffic movements generated by a modicum of additional employment, this “no limit” approach could mean that the current transport related evidence base, Strategic Environmental Assessment and Strategic Appraisal are not able to demonstrate that the AAP is sound. It is therefore suggested that the AAP should more precisely state the level of employment to be generated across the development, and hence likely to be permitted.
163. Representation 427 comments that in para 4.2 iv) It is misrepresentation to say there are “several” properties when there are many properties within and adjoining the area that are privately owned.
Response
164. Supporting comments are noted.
165. In response to representation 39, the overall quantum of development has been established through a variety of layers of evidence, as set out under Para 4.7 – 4.13 of the AAP. These have included reference to the Council’s commitment to residential space standards; guidance for open space and car parking, as well as the clear Council desire for a quality development at Chilmington Green.
166. Responding to representation 509, this comment is noted. However, it is implicit within the policy framework that the nature of development envisaged at Chilmington Green will deliver around 1,000 jobs and be mainly focused on B1 uses, alongside education, shops, community and cultural. To suggest that the current AAP policy approach could lead to ‘unlimited’ job creation is not accurate. In addition to the AAP, the adopted Core Strategy position - which clearly outlines the nature and type of development envisaged at Chilmington Green - is also relevant. Nevertheless, detailed planning applications coming forward will need to be supported by suitable transport evidence. It is considered that the AAP provides the right balance between flexibility and certainty on this issue and therefore no amendments are necessary.
167. In response to the concern about the housing mix being proposed, this is a detail which will be determined through the planning application stage and will need to accord to Policy CS13 which encourages a range of dwelling types and sizes to be delivered.
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168. The density plan which supports the AAP (Strategic Diagram 3) clearly shows a gradation of densities across the site. This includes a large number of very low density areas where large detached properties will be provided (such as the hamlet and southern fringe to the development). Combined this approach will add interest to the overall development and provide variety and options to Ashford’s housing market.
169. Responding to representation 427, the context of this statement is to set out that there are a number of existing properties within and adjoining the site area that have been taken into account through the evolution of the sites opportunities and constraints to establish the masterplan for the area. In this context, the wording remains valid.
32 THEME 3 – CHARACTER AREAS
Representations were received from the following consultees:
4, 5 – Mr Hopkins 356, 357, 360, 363, 364, 480 – Great Chart with 180 – Angus Willson 366, 367– Kent Wildlife Singleton Parish Council 253 – Yolanda Barker Trust 499 – Save Great Chart 279 – WM Morrison 432, 433, 434 – J R Action Group Supermarkets Plc Carpenter 523 – Nicholas Chaplen 283, 284, 285, 286, 287, 456 – Mr Howard and Eleanor Jeffrey- 308 – Chilmington Green Matthews Chaplen Developers
a) District centre / Local Centre Character Areas
170. Representation 180 comments that the coherence of the character areas will be a significant indicator of the success of the development. Representation 499 supports the flexibility and frequent reviewing of the quantum and range of uses at the district centre. Representations 283 and 284 support Policies CG3 and CG4 as they combine an appropriate level of policy guidance on the essential components of the district and two local centres whilst allowing some design flexibility. Representation 363 welcomes the requirement to produce a detailed design strategy for the district and Local centres as it will be important that the green corridors are incorporated into the design of the centres wherever possible.
171. Representation 253 is concerned about mixed-use development in the district and local centres especially where it is envisaged larger shops may be placed as these get deliveries/refuse collections very late at night/early morning and which is antisocial and undesirable for residents.
172. Representation 279 considers that there should be some flexibility in the proposed location of the District Centre / Local Centres and the points of access from the surrounding primary highway routes e.g. the A28 to ensure that they will have the greatest chance of success once the plans for the new community are drawn up in more detail.
173. Representation 360 recommends Policy CG3 should be amended to include g) Soft landscaping throughout the character areas should incorporate enhancements such as verges, green roofs and semi natural habitat to ensure routes for biodiversity extend throughout the development and attractive natural areas are delivered for the local population to enjoy.
Response
174. Supportive comments noted.
33 175. In response to representation 253, this issue can be dealt with through the detailed planning application of the development and the use of suitable planning conditions.
176. In response to representation 279, the location of the district centre allows it to come forward in the first phase of the development so that the various uses there can begin to support the emerging residents from the outset. Its location also allows for easy access onto the A28, whilst still remaining within walking distance from the whole development. With regards to the two local centres, these are indicated on Strategic Diagram 1 of the AAP and are proposed within easy walking distance of a number of residential properties and each primary school. However, the AAP accepts there is an element of flexibility relating to the Local Centres (given when they are proposed to come forward) and suggest more detailed policy can come forward later.
177. Responding to representation 360, it is not necessary to include issues on ecology, as they are already covered elsewhere in the AAP. Most notably, Policy CG21 states, ‘where practical, development should enhance and improve semi natural habitats and ecological networks’. In addition, Policy CS1 of the Core Strategy also promotes the enhancement of ecological networks and habitats. Furthermore the detail of plans (and any connections for ecology or wildlife) will be determined through the planning application process.
b) High Street comments
178. Representation 308 (the developer consortium) suggests that The Indicative Quantum of non-residential development proposed at Chilmington Green Table is slightly different from the information contained in Appendix 1 of the Employment Report. As follows: - the B1(a) floorspace areas are net internal area (NIA) not gross internal area - the amount of B1 (a) floorspace in the Local Centres is 1,700 m2 and not 1,750 m2 - the number of D2 ‘sports and fitness’ jobs is assumed to be 77 and not 46. As a consequence, the overall number of jobs rises to 1,215.
179. Representation 432 suggests that there will need to be some other sizeable employers in the district centre than merely retail to encourage activity during the day and questions that if development has a “limited B1 role...” how will there be sufficient employment to create a sustainable community?
180. Representations 480 and 499 do not feel that the district centre can fulfil a High Street role as the new development will not be far enough away to be independent from Ashford's own High Street. Representation 433 questions where the evidence is that shows this High Street will be able to attract businesses and shoppers and the evidence that people are keen to walk everywhere.
181. Representation 523 also comments that the provision of retail outlets will be commercially driven and therefore outside of the control of Ashford Borough Council or the Developers and therefore hard to envisage that an estate on the outskirts of Ashford will attract business of any size to fulfil the promised employment opportunities and thus meet the 'key element' requirement for a 'sustainable community' of 'Economy’.
34 182. Representation 499 suggests that within the high street, suitable uses both at ground and above ground floor level should be designed to be sufficiently flexible to allow for adaption to residential use as this is better than empty unused retail units. Also feels that only services (restaurants, hair dressers, professional services) can work above ground floor, not retail. This representation also states that 5.28 and 5.29 conflict with each other about the ground floor unit suitable uses. Representation 523 disagrees with this comment by objecting that if there is no interest by the commercial sector for the high street units then it is likely that they will revert to becoming houses.
Response
183. In response to representation 308, the Council disagree that the figures in Table 1 of the AAP require amendments (figure relating to B1 (c) within and on edge of Local Centre apart – see proposed minor amendment schedule), as they correlate with Table 1 of the Chilmington Green Employment Report which supports the AAP. In any event, these figures should not be interpreted rigidly. In this context, a planning application which proposes justified and minor differences to these figures could still be considered in accordance with the policy approach advocated in the AAP.
184. Responding to Representations 433, 523 and 432, the Council accept that the market will play an important role in determining whether there is interest in locating at Chilmington Green. However, the AAP seeks to provide for a range of uses (not just B1), alongside a variety of building stock (for example new office premises) which will be different to what is provided elsewhere. In doing so, the Council are providing as an attractive environment as possible, for a diverse range of commercial operators, both now, and in the future when more usual market conditions return.
185. In response to representations 480 and 499, the type and level of provision envisaged along the high street is to meet the everyday needs of the local residents. Therefore it will provide a different offer from the range of shops currently in Ashford Town Centre and have a clear local catchment.
186. In reply to representation 499, the AAP already proposes (under Para 5.10) that the building stock in the high street area should be designed in a flexible way, to allow for desired changes of use in the future. In relation to retail units above the ground floor level, there are many examples where this occurs successfully and therefore the policy approach which prioritise ground floor retail, yet also allows retail above the ground floor is considered appropriate.
c) Parking
187. Representation 499 states that there is no mention of parking provision, and if other outlets elsewhere have free parking, shoppers will go there instead. Representation 480 supports this comment. Representation 456 is concerned with regarding the width of the access road and suggests that there be a lane each way for through traffic and two lanes with temporary parking with a five to ten minute waiting it will help trades.
35 Response
188. In response to representation 499 the need for parking bays along the high street area is referred to in paragraph 5.27 of the AAP. Parking is also referenced in paragraph 5.34 which suggests that there should be spaces in the Market Square to capture passing trade and other on-street parking on the main roads for shoppers and residents. However, the exact design of the parking areas will be developed through the planning application stage.
d) The proposed supermarket
189. Representation 279 (Morrison’s supermarkets) believes there should be flexibility of the size of the supermarket which will allow for a potential alternative larger store within the District Centre and/or Local Centres, subject to an appropriate retail impact assessment.
190. Representation 432 suggests that the proposed supermarket will need to be very big if it will compete on food spending with other existing out of town supermarkets, which have substantial associated car parking. They also suggest that there should be a choice of supermarkets within the development.
191. Representation 499 feels that one supermarket will not provide vibrancy. The Retail Evidence Base, by GL Hearn suggests only 10% of spend will be from comparative shopping, yet they have allocated 51% of retail space for this purpose.
Response
192. Responding to representation 279, 432 and 499, the size of the supermarket has been assessed through up-to-date retail evidence that supports the AAP approach which explores issues such as the impact on the town centre, the nature of development envisaged at Chilmington Green, its location, the adopted Core Strategy position and whether this provision can compete (in a local context) with other out of town locations. In addition, the AAP already sets out that there is an element of flexibility with the figures within the AAP, providing they are supported by an up-to-date retail assessment and they don’t undermine the objectives of the AAP or the adopted Core Strategy. More flexibility on this issue is therefore not deemed necessary.
193. With regards to the need for more supermarkets at Chilmington Green, the evidence which supports the AAP does not support this position and none has been presented by the objector. A significant increase in supermarket provision here would have a negative impact on the town centre, and could lead to unhealthy competition between each other. With regards to the type of retail provision, the AAP does not specify between convenience or comparison retail uses (supermarket aside) to aid greater flexibility. Having said that, it is likely that any comparison retail uses here will be small in scale and independent in nature and this is reflected in the AAP.
36 e) The Chilmington Green Hamlet Character Area
194. Representation 285 supports Policy CG5 as it combines an appropriate level of policy guidance on the essential components of the Hamlet Character Area whilst allowing some design flexibility. Representation 4 support the desire for building materials and design to reflect those of the current properties and is strongly in favour of minimising the visual impact on existing residents of the area. Representation 364 welcomes the preservation and enhancement of the hedgerow network, verges and green infrastructure within this policy and looks forward to being consulted on the design strategy.
195. Representation 434 states that Figure 8 is inaccurate; several listed buildings are not marked as such.
Response
196. Supportive comments noted.
197. In response to representation 434, the Council accept that amendments are needed to Figure 8 to show the listed buildings correctly. Please refer to the minor amendment schedule.
f) The Southern Fringe Character Area
198. Representation 5 agrees that early advance planting needs to occur, as native tree varieties will need 10 to 15 years to mature sufficiently to have any impact. Representation 286 supports Policy CG6 as it combines an appropriate level of policy guidance on the essential components of the Southern Fringe Character Area whilst allowing some design flexibility.
199. Representations 356 and 357 support the low densities proposed for the southern fringe area as this should limit the recreational impacts on the ecological habitats to be created, and welcomes the soft edge proposed to buffer the ecological areas and feel this will provide further protection for the ecological habitats proposed. Representation 366 welcomes and supports the careful consideration given to the protection and enhancement of the ancient woodland and hedgerow network and enhanced ecological habitats within this policy and the balance obtained between increased access into the countryside and protection of the natural habitats.
Response
200. Supporting comments noted
g) Discovery Park Edge Character Area
201. Representation 287 supports Policy CG7 as it combines an appropriate level of policy guidance on the essential components of the Discovery Park Edge Character Area whilst allowing some design flexibility. Representation 367 welcomes the sensitive nature in
37 which the edge has been designed and the green corridor which provides a connection into the park and enables biodiversity to migrate in and out of the development.
202. Representation 367 raises the issue that within Discovery Park, Colemans’ Kitchen Wood will require protection. They are concerned that the woodland seems to have become surrounded by roads.
Response
203. Supportive comments noted.
204. In response to representation 367, the Council agree that Colemans’ Kitchen Wood is an ecologically sensitive area, and is referenced as such in the AAP. In addition, the AAP also recognises that this area should have limited public access and will require a management strategy to be formulated (for all uses within Discovery Park). However, it would be too inflexible to set out what these exact arrangements should be at this stage. A more appropriate approach is to deal with this issue through detailed planning application discussions.
38 THEME 4: OPEN SPACE, OUTDOOR SPORT, PLAY AREAS AND DISCOVERY PARK
Representations were received from the following consultees:
6, 9 – Cllr Rita Hawes 273 – Ashford Clinical 469, 478 – Great Chart 15 – Michelle Parsons Commissioning Group with Singleton Parish 84 – Daniel Hammett 288, 289, 290 – Council 141 – P Purnell Chilmington Green 479 – Kingsnorth Parish 185 – Andrew Anselmi Developers Group Council 235 – Natural England Group 502 – Save Great Chart 251 – NHS Kent and 353, 370, 372, 374 – Action Group Medway Kent Wildlife Trust 525, 526, 527, 528 – 253 – Yolanda Barker 436 – J R Carpenter Sport England 263 – Margaret Cook 464 – CPRE Ashford
a) Public Open Spaces
205. Representation 9 considers it important to have an area of unspecified open space to accommodate future change.
Response
206. In response to representation 9 the policy framework in the AAP includes a number of measures to aid the flexibility of the approach. This includes a planned formal review period which will ensure the Plan can adapt to changes in circumstances. In light of this, it is not considered necessary to set aside areas of open space to achieve this purpose.
b) Equipped Play Areas
207. Representation 370 has concerns regarding the location of equipped play areas within the green corridor as hard surfaced play areas will create blocks to the migration of species through the green corridor network.
Response
208. In response to representation 370 the AAP proposes that the green corridor network should be designed in a way that encourages multifunctional activities, including playing an ecological role. The detailed design of these areas will come forward through the planning application stage. However there is nothing to suggest that the approach advocated in the AAP will result in significant blockages to migration, as has been suggested.
39 c) Informal space / Natural Green Space
209. Representation 251 supports the inclusion of public open spaces and informal natural green spaces as this will promote leisure activities and opportunities for improved health and wellbeing. Representations 235 and 288 also support Policy CG8.
210. Representation 273 considers good quality open spaces to make a significant contribution towards healthy living, and want the development to have an environment friendly for dementia patients.
211. Representations 370 and 372 are concerned that Strategic Diagram 1 does not detail the corridor of woodland and parkland proposed within the Ecology Strategy to the Millennium Wood and Coleman’s Kitchen Wood as well as the finer detail of green infrastructure being proposed. They recommend a clause be added to Policy CG8 regarding the corridor within Discovery Park and that Strategic Diagram 1 is changed to show the green network in its entirety. Representation 370 suggests additional wording for policy CG8 (ii): green connections to the surrounding areas, connecting Chilmington Green with Millennium Wood, Singleton Hill and the Singleton Environment Centre, Long Length and the woodland and hedgerow network present within Discovery Park and to the South.
212. A further comment by KWT (353) sets out that in addition to access and transport, enhancements for biodiversity should also be included in the role for Green Infrastructure as set out in paragraph 4.2.
Response
213. Supportive comments welcomed.
214. In response to representation 273, the AAP sets out that the delivery of a high quality environment is a key theme for development here and this is reflected within the key principles. In relation to providing an environment friendly for dementia patience, this level of detail will need to be explored through the planning application to ensure their needs are suitably taken into account.
215. In response to representation 370, 372 and 353 Policy CG8 (i) requires an integrated network of green corridors that connects key destinations within the development. The precise nature and design of the green corridors within the Discovery Park area will have to be agreed as part of the masterplanning for the Discovery Park area. Being too prescriptive (at this stage) would undermine the flexibility of the Plan and hence, not justified.
d) Outdoor Sports Space
216. Representations 525, 526 and 527 support the identification of outdoor sports facilities needs of the proposed new development and the proposal to create hubs of sporting activity.
40
217. Representation 141 consider there to be a lack of local activities for young people (ice rinks, roller rinks, ski slopes, boating, parks), conversely representation 185 considers there to be plenty of play areas for children to play in around Ashford (noting Singleton).
218. Representation 253 had concerns that the proposed cricket pitch in phase 1 would not be a useable space for all, and wanted to know who would police the facility as they consider cricket pitches on village greens to be underused by the general public often getting vandalised. Representation 253 wanted to know if the cricket pavilion could also be used as a village hall, and who was going to pay for the facility.
219. Representation 527 acknowledges that an Open Space Study (2008) has been undertaken, but objects to the robustness of the evidence base and urges the Council to undertake a Playing Pitch Strategy to ensure developer contributions are not challenged at planning application stage. They further request a review of the Public Green Spaces and Water Environment SPD in light of the findings of a Playing Pitch Strategy.
220. Representation 527 encourages the potential joint provision by providers and the dual use of facilities in appropriate locations. The dual use of sports pitch provision delivered as part of the secondary school, referred to in paragraph 6.22 of the AAP is supported.
Response
221. Supportive comments noted.
222. Responding to representation 141, Discovery Park is intended to be a major park, sports and recreational facility for Ashford which will provide a range of uses that will be used by the town as a whole. This will be determined through the evolution of the Discovery Park masterplan. It is hoped that these range of uses will cater for differing age groups.
223. In response to representation 253, the cricket pitch and pavilion are seen as an importance use which will complement the open space and sports facilities delivered elsewhere around the development. It is proposed that the Pavilion will also serve as a meeting place for the community. The detailed management of this facility could fall within the remit of a community led trust, although this will be a detailed matter determined through the planning application process.
224. With regards to representation 527, the standards set out within the AAP adhere to the Council’s recently adopted Public Green Spaces and Water Environment SPD and are therefore up to date and robust. The Council share the aspiration for dual use, provided it is fit for purpose and the provision is truly available to the public. This position is established within the AAP.
41 e) Allotments
225. Representation 84 objects to the development of Chilmington Green, but does support the provision of allotments for its residents, should it come forward. Representation 370 recommends that within the application process allotments are designed to mirror the habitat created within the green corridors to provide a multifunctional role for these sites.
Response
226. Supportive comments noted.
227. With regards to representation 370, the principles which will be applied for allotment provision will be consistent with the adopted Public Green Spaces and Water Environment SPD which explores quantitative standards and guidance as to their design and location.
f) Strategic Parks & Cemetery provision
228. Representation 370 suggests that there are opportunities to provide a green burial site within Discovery Park comprising woodland to compliment the woodland and hedgerow network currently present.
Response
229. Noted, although the AAP refers to this possibility within Para’s 6.28 – 6.30.
g) Discovery Park
230. Representation 6 supports the removal of ‘Discovery Park’ from the AAP title (as stated in footnote 1, p.7) as this may confuse members of the public. Representation 15 objects to the development but supports Discovery Park as a way of creating new habitats for wildlife, as this may encourage visitors to the local area.
231. Representations 263 and 469 feel that Coleman’s Kitchen Wood is heavily abused and wants priority to be given to the immediate management intervention for mitigation of the wood.
232. Representation 289 (the Developer consortium) considers para 6.29 of the AAP should determine what is meant by ‘the delivery of an additional part of Discovery Park’. They note that Chilmington Green will deliver part of the ‘strategic parks’ provision identified within the SPD, and as such it should not be considered as being ‘additional’.
233. Representation 290 (the development consortium) object to the wording within the final sentence of Policy CG9 as they consider it prevents the developer commencing any development in the AAP area until such time as the Council has entered into a
42 management agreement with the owners of that part of Discovery Park not procured by the developers.
234. Representation 374 does not object to policy CG9 but considers there to be opportunities to incorporate natural habitat within Discovery Park to enable an extension of the work at the Environment Centre, particularly in relation to encouraging greater educational and community participation.
235. Representation 464 feels that the area defined as the Discovery Park has reduced in size to that visualised within the GADF and therefore its area should be safeguarded as a town green to ensure no further encroachment.
236. Representations 464 and 479 objects to the road that is proposed to run through Discovery Park, as they feel it will create two distinct areas and destroy the overall concept of the park as a continuous area of green space, as well as disrupt the ‘green necklace’. It could also become a rat run.
237. Representation 464 would like to see access to the surrounding countryside by footpath and cycleway to be addressed in the policy approach here.
238. Representation 528 supports the proposal to provide a sports and recreations hub at Discovery Park.
239. Representations 478 and 502 seek clarity as to who will pay when using the facilities at Discovery Park and who will be charged the management fees, and whether residents of affordable housing are also charged. In addition, Representation 436 considers the proposals for Discovery Park to be highly speculative, with no guarantee that the Council will have the money to pay for developing the park.
Response
240. Supportive comments noted.
241. In response to representations 263 and 469, Policy CG9 requires that a management Plan will be needed to establish how the Wood will be managed. In addition, the range of uses and activities which are proposed in this area are required to be agreed through the evolution of a Discovery Park masterplan. Combined, these approaches should ensure the long term future of the Wood.
242. In relation to representation 289, the Council proposes a new to clarify the text of the AAP, please refer to the schedule of proposed minor amendments.
243. In response to representation 290, a Management Plan is needed to provide certainty that the areas of Discovery Park are appropriately maintained up to the point the land is transferred, to a third party, likely to be the Council. This is to ensure that any active uses on this land, up until its transfer, does not prejudice either those uses which are delivered
43 early on as part of the development (such as sports pitch provision), or any future uses envisaged for Discovery Park. This is not merely limited to open space uses within Discovery Park. Any management plan may also need to cover how ecological sensitive areas which lie adjacent to the built form (such as Coleman’s Kitchen Wood) are proposed to managed in the longer term.
244. In response to representation 290 an appropriate management plan can be agreed between the relevant parties early on in the process, and it is not a requirement of Policy CG9 to wait until the Discovery Park Masterplan is finalised before it can be agreed. In this context, the Council does not see how this approach can be considered overly onerous, and no evidence has been presented which suggests why this would be the case.
245. In response to representation 374, these possibilities can be explored through the Discovery Park masterplan preparation.
246. In response to representation 464, it is accepted that the GADF did show an area (referred to as Discovery Park) to the east of Long Length. This area falls outside the spatial area covered by the AAP, and is beyond the scope of its proposed policies as it is a strategic issue which should be dealt with through the Core Strategy Review, as suggested by the text in the AAP.
247. In relation to representations 464 and 479, it is not accepted that, in itself, a road through Discovery Park will substantially detract from its attractiveness or its primary function. In addition, this route will play a key role in dispersing traffic around the development and provide for movements towards eastern Ashford (see response to Transport section of this paper). Details with regards to the issue of rat running, and improvements to the cycle and footpath network (representation 464) will be dealt with at the detailed planning application stage.
248. In relation to paying for facilities at Discovery Park (representations 478, 502 and 436), there are a number of options which include the possibility of a Trust taking on a lead role, people undertaking various activities, as well a reasonable residential levy applied to the development. All of these options will be explored in more detail through the planning application process.
44 THEME 5: COMMUNITY DEVELOPMENT AND GOVERNANCE
Representations were received from the following consultees:
9 – Rita Hawes 291 – Chilmington Green 79 – Daniel Hammett Developers Group 478 – Great Chart with 95 – Daniel Hammett 437 – J R Carpenter Singleton PC 264 – Margaret Cook 470 – Great Chart with 506 – Ian Wolverson Singleton Parish Council
Main Issues Raised
249. Representation 9 considers social networking to be very important and would like community infrastructure, for example medical facilities, community space, primary schools etc. to be in place early on in the development to support the building of community pride. Representation 9 supports the concept of community governance initially with the developer consortium, as indicated in paragraph 8.9 and would support the creation of a new Parish Council.
250. Representation 506 feels there is lack of evidence to show that the three existing Parish Councils are willing to take on responsibility at Chilmington Green, only for those responsibilities to be turned over to a new Parish Council once it is formed.
251. Representation 79 feels that it will be difficult to achieve community engagement and involvement in shaping the new community with 75% of working households having to commute to work, and questions whether the community volunteers will be fully demographically representative of their communities.
252. Representation 95 is concerned about the delivery of services through Section 106 Agreements and want the agreement to be open, transparent and easily audited with clear trigger points that can be verified by a third party, especially as these may be turned over to Parish Councils or other community groups.
253. Representation 291 supports policy CG10 and considers it to clearly set out the Council’s preferred form of community governance, the contents of the necessary business case and the timescales for its agreement.
254. Representation 437 objects to the development of a ‘community development trust’ as outlined in paragraph 8.6 of the AAP. Consider this to be a Council role, and question why one part of Ashford should be governed in a different way to the other parts of the town. Also, he has concerns about who will represent the new trust, and feels that this will be a difficult task to achieve on a voluntary basis. Also, how can a community-led trust be established before the community?
255. Representation 478 seeks clarity as to who will pay when using the facilities. Representations 264 and 470 object to charging residents a management fee, and suggest alternatives are explored to commissioning a management trust / company.
45 Representation 437 seeks more detail about how the service charge arrangement will work, and query why new residents of Chilmington Green should pay more for services than other residents within the Borough.
Response
256. The supportive comments are noted.
257. At present, it is important to understand that the Council (through Policy CG10) is promoting a community led management arrangement for Chilmington Green as the ‘preferred solution’, as it is seen as providing the right balance between professional management and retaining ownership for residents.
258. The Council accepts that there is a large amount of detailed work that is needed to progress this issue, and this work is ongoing. During this process, the Council will continue to liaise with local stakeholders, including the existing Parish Councils, to ensure that all relevant bodies have clearly defined roles and are engaged in the process in a constructive way. This dialogue will be crucial in the early years of the development, but will also need to continue throughout the development of Chilmington Green.
259. In response to representation 506 the extent to which the three existing Parish Councils will take on responsibility for governance at Chilmington Green is yet to be determined, as is the exact membership of any Trust. However, any Trust will need to be professionally resourced and will need dedicated staff to run it effectively (representation 437). In relation to any future resident members, measures will be in place to ensure that they are fully representative of their community (representation 79) and the correct democratic process has been adhered to.
260. Representation 437 considers the principle behind pursuing a CDT model at Chilmington Green is the added value it can bring, in terms of the quality of environment delivered which the public purse alone could not provide. This is clearly referenced in the AAP and is not simply asking people to pay for services already provided by the Council, as has been suggested. Besides, people will have the choice as to whether to move to Chilmington Green or not (representations 478, 264, 470 and 437). They will need to balance the cost of any levy with the quality of the environment delivered.
261. Representations 478, 264, 470 and 437: the exact financing arrangements needed to support a Trust model is a complex issue, although it is likely to involve a range of factors including asset transfers, money generating ventures, endowments, S106 monies, as well as a reasonable residential levy (likely to be covenanted to properties). The details of these arrangements will be determined through the planning application process. In response to representation 95, as a principle, the Council agree that any Agreements between the relevant parties should be as open and transparent as possible.
46 THEME 6 – TRANSPORT
General representations on A28 and M20 were received from the following consultees:
9 – Cllr Rita Hawes 183 – DA Craib 397 – Valerie Joynson 19 – Steve Falden 185 – Andrew Anselmi 423 – JR Carpenter 23 – Peter Williamson 208 – Ashford Green Party 439 – J R Carpenter 53 – PG Churcher 209 – Elizabeth Eyre 454 – Kenardington Parish 55 – Paul Roughton 210 – Nigel Christian Council 60 – John Ley 225 – Lilian Brookes 457 – Wittersham Parish 61 – Wood 226 – Shirley Ambrose Council Yvonne Osborne 65 – Michael Dowsey 228 – Independence & 464 – CPRE Ashford 70 – Lionel Goddard Access 471 – Great Chart with 72, 73, 85, 87 – Daniel 246 – Joanne Brand Singleton PC (Linda Hammett 249 – Gordon Roberts Hedley) 97 – Dunster 253 – Yolanda Barker 479 – Kingsnorth PC 98 – Spencer Dorey 257 – Central Ashford (Dorothy Alsop) 99 – Mc Cort Community Forum (Emily 492 – Save Great Chart 105 – Sarah Keaveney Neighbour) Action Group (Ian 140 – Richard McN. 265 – Margaret Cook Wolverson) Beaugie 268 – Mason Brannan 500 – KCC (Tim Martin) 142 – Sarah Stanfield Design 508, 510 - Highways 144 – Donald Fagg 276 – Cllr Peter Davison Agency (Kevin Bown 146 – TR Lacey 292 – Chilmington Green 516 – Robert Hughes 150 – Sally Gathern Developers Group 519 – Sarah Dacre 153 – Cllr Andrew Mortimer 313 – John Holland 522 – Cllr. Winston Michael 160 – James Eberlein 315 – Zoe Snazelle 533 – G Richardson & M 176 – Ashford Independent 337 - JA and MR Morris Ransley Party Executive 378 – L Kemp 178 – Fiona Birrell 385 – Brenda Hedley
Main Issues Raised
262. The greatest number of representations concerned with movement and transport were those which raised issues concerning the lack of capacity of the A28 and the problems of access to junctions 9 and 10 of the M20 and to the expected increase in traffic in general. The congestion currently experienced on the A28 is seen as a problem that needs to be overcome before the development goes ahead in order to prevent a worsening of the situation. Early scheduling of these improvements is considered essential.
263. The Highways Agency and Kent County Council have made representations regarding the ability of the strategic highway network to accommodate the proposed development, including at M20 junction 9 and the need to monitor traffic generation and flows as the development progresses. However, it should be noted that Representation 508 from the Highways Agency states that it has no fundamental objection to development at Chilmington Green.
47 264. The shelving of public funding for the proposed M20 junction 10a and the amount of traffic on the A28 between the proposed development at Chilmington Green and junction 9 are considered to be major problems. The John Lewis at Home Store proposed opposite the Drovers roundabout is also considered likely to add to congestion.
265. Existing congestion on the A28 results in drivers taking ‘rat runs’ on more minor roads particularly the road through Great Chart and long queues of cars on the A28 pump out harmful fumes.
266. Some objectors (153 and 257) consider that although the A28 is to be dualled between the Matalan and Tank roundabouts, the railway bridge is unlikely to be dualled until after the completion of the development. The provision of road transport infrastructure should come before the development.
267. The Orchard Way link from the A28 to the M20 is considered by some of the objectors to be vital to help relieve pressure on the A28.
268. Representation 292 supports policy CG11 ‘Highways and Access’ since it clearly articulates the access strategy for Chilmington Green and the funding arrangements to deliver wider off site highway improvments.
General Response
269. Accessibility and inclusiveness are at the core of the design for Chilmington Green, and this is reflected within the AAP. Measures incorporated into the AAP include: • Locating the large majority of dwellings within a short walk of a bus route; • A circular transport loop within Chilmington Green providing easy access to any part of the development. • Reducing the demand for travel by designing higher density district and neighbourhood centres; • Utilisation of, and integration with existing routes as Green Lanes, with new roads designed to take the majority of vehicle traffic; and • The incorporation of priority routes for public transport.
270. These measures will reduce the need for travel by car and together with the upgrading of existing roads, will reduce the likelihood of traffic congestion arising as a result of the development.
271. Specific responses on the range of traffic and transportation issues raised in the representations are considered below.
a) Congestion on the A28
9 – Rita Hawes 61 – Wood 99 – Mc Cort 19 – Steve Falden 72, 73, 85, 87 – Daniel 142 – Sarah Stanfield 55 – Paul Roughton Hammett 144 – Donald Fagg 60 – John Ley 98 – Spencer Dorey 150 – Sally Gathern
48 153 – Cllr Andrew Mortimer 268 – Mason Brannan 492 – Save Great Chart 160 – James Eberlein Design Action Group (Ian 178 – Fiona Birrell 397 – Valerie Joynson Wolverson) 228 – Independence & 439 – J R Carpenter 516 – Robert Hughes Access Matters 471 – Great Chart with 522 – Cllr Winston Michael 249 – Gordon Roberts Singleton 523 – Nicholas Chaplen 257 – Central Ashford PC (Linda Hedley) and Eleanor Jeffrey - Community Forum (Emily 479 – Kingsnorth PC Chaplen Neighbour) (Dorothy Alsop) 265 – Margaret Cook
272. Concern over congestion on the A28 were raised in representations 397, 9, 19, 55, 60, 61, 72, 73, 85, 87, 98, 99, 142, 144, 153 (Cllr Andrew Mortimer), 160, 178, 228, 249, 257 (Central Ashford Community Forum), 265, 268, 471 (Great Chart with Singleton Parish Council), 516, 522 (Cllr Winston Michael) and 523. In particular, representation 268 states that development should not be reliant on travel along the A28. Representations 72, 439 and 492 (Save Great Chart Action Group) seek commitment on the timing of improvements to the A28. Representation 479 (Kingsnorth Parish Council) requires the proposed works to the A28 to be ‘set in stone’ to avoid future reneging on the proposals. Representation 85 refers to the effects upon the residents of Singleton from the increased traffic on the A28 until such time as works to increase capacity are carried out. Representation 150 considers that unless recycling facilities are provided to serve the new development, queues for the existing site will be worse than they are already and these currently back up onto the A28. Provision of facilities at Chilmington Green would also prevent residents having to drive unnecessarily long distance to recycle.
Response
273. There has been extensive traffic modelling work carried out to identify the potential traffic impacts on the A28 from the Chilmington development and the mitigation required to offset these impacts and potentially, provide a ‘net’ improvement from the current position.
274. Dualling of the A28 between the Matalan and Tank roundabouts is included within the Local Transport Plan and an assessment will be made by KCC Highways as to when this upgrade is required. The restriction contained in policy CG11, preventing occupation unless sufficient capacity is available on existing roads, can be used to balance the development against the necessary road improvements. If planning permission is subsequently granted, suitable restrictions will be embodied in the accompanying legal agreement. KCC representation 500 accepts that capacity of the A28 may constrain development but expects the improvements to the A28 to achieve a better ‘net’ position in order to avoid a harmful impact on other parts of the highway network. KCC is promoting strategic improvements that will provide a more beneficial end result than ‘nil detriment’.
b) Capacity of junction 9
185 – Andrew Anselmi 208 – Ashford Green Party 228 – Independence & (Steven Campkin) Access Matters
49 249 – Gordon Roberts 510 – Highways Agency (Kevin Brown)
275. The queues on the road links out of Ashford to the motorway are considered to be unbearable already, this point is raised in representations 185, 208 (Ashford Green Party), 228 and 249. Representation 510 is from the Highways Agency and warns that extra capacity at M20/junction 9 may be used up before Chilmington comes on stream.
Response
276. Junction 9 of the M20 and the Drovers roundabout have both been substantially improved in the last year. The additional capacity generated at both junctions was designed to be sufficient to accommodate the traffic generated from the developments identified in the existing Core Strategy. As far as Chilmington Green is concerned, the AAP now proposes a reduced scale of development below that indicated in the Core Strategy and thus there should be additional capacity ‘headroom’ at both junctions.
277. Policy CG11 contains commitments which need to be fulfilled in order for the development to go ahead. The final clause in CG11 is that occupation of the new development may be restricted by condition or a 106 agreement unless it can be demonstrated that sufficient off-site capacity on the A28 and other parts of the primary/secondary network is available based on at least ‘nil detriment’. This would include access to junction 9 of the M20. This policy is a safeguard which would prevent the development from going ahead without addressing the capacity of the existing off-site road network.
278. In response to the Highways Agency’s representation, the council agrees that it will need to monitor new developments as they come forward to ensure that sufficient strategic highway capacity remains available but it is unrealistic to suggest that all the additional capacity at Junction 9 / Drovers roundabout will be used up prior to the Chilmington development commencing.
279. In any event, paragraph 9.15 of the AAP points out that the Council expects improvements to the strategic network to be funded from a variety of sources including CIL and specific 106 contributions. Paragraph 9.24 explains that any Transport Assessment associated with an application will need to assess the phasing of the development against the implementation of various off site highway improvements.
c) Delay in provision of junction 10a
70 – Lionel Goddard 228 – Independence & 265 – Margaret Cook 208 – Ashford Green Party Access Matters 471 – Great Chart with (Steven Campkin) 249 – Gordon Roberts Singleton
280. Delay in the provision of junction 10a was raised in representations 70, 208, 228, 249, 265 and 471. Representation 70, had concerns that the existing J10 would be unable to cope with increased traffic if J10a wasn’t implemented before the development.
50 Response
281. The delay in the funding of the ‘preferred route’ scheme for J10a by the Government has no impact on the proposals for the Chilmington Green proposals as they lay too far from the junction. Motorway access from Chilmington would be expected via the A28 and Junction 9, hence the importance of the capacity and upgrading of that corridor.
d) Travel to and from Tenterden and congestion on the A28
457 – Wittersham PC 522 – Cllr Winston Michael
282. Representation 522, is concerned with traffic going in the Tenterden direction and the proposed development at Tenterden. Representation 457 (Wittersham Parish Council) is concerned that additional traffic on the A28 would have a seriously harmful effect on local people who use this route and also increase congestion in Tenterden High Street.
Response
283. The highway modelling work for the Chilmington development has considered the potential proportion of traffic from the development going south on the A28 towards Tenterden. This indicates that only a minor percentage of traffic is likely to head in this direction with the vast majority heading north towards Ashford town centre or the motorway.
284. Of the traffic that heads south, only a proportion of that would pass through Tenterden and so the actual impact there is likely to be very minor indeed.
285. Conversely, Kent Highways are fully aware of the proposed TENT1 development at Tenterden and have taken this into account in their assessment of the works necessary to improve the flow of traffic on the A28. As with objections above policy CG11 will provide a safeguard and KCC are proposing improvements to the A28 which will be better than ‘nil detriment.’
e) The use of ‘rat runs’
23 – Peter Williamson 464 – CPRE Ashford 492 – Save Great Chart 73 – Daniel Hammett 471 – Great Chart with Action Group (Ian 313 – John Holland Singleton PC (Linda Wolverson) 315 – Zoe Snazelle Hedley) 457 – Wittersham PC 479 – Kingsnorth PC (Yvonne Osborne) (Dorothy Alsop)
286. Concern over the use of ‘rat runs’ to avoid congestion on the A28 were raised in representations 23, 73, 313, 315, 464 (CPRE), 457 (Wittersham Parish Council), 471 Great Chart with Singleton PC, 479 (Kingsnorth Parish Council) and 492.
51 287. The representations from CPRE and Kingsnorth PC are concerned that the proposed road through Discovery Park will be used as a ‘rat run’ to junction 10 of the motorway. There is also concern that Magpie Hall Road will be used as a ‘rat run’ creating a south Ashford Orbital. Mock Lane is seen as a potential ‘rat run’ where drastic narrowing is considered to be required and details necessary. The Road through Great Chart is already one which needs to be addressed. Representation 492 also raises the issue of ‘rat runs’ and Wittersham PC considers that villages will suffer as they are used as ‘rat runs’ to circumvent congestion on the A28.
Response
288. The use of so called ‘rat runs’ is inevitable where traffic congestion is known to occur. Measures such as the upgrading of the A28 and the provision of new roundabouts giving access to the development, together with positive planning to encourage walking, cycling and use of public transport will reduce the demand for use of ‘rat runs’. Policy CG11 (c) calls for the delivery or funding of off-site highways works to Magpie Hall Road and the road which runs through Great Chart village. Traffic flows are to be monitored after road improvements have been carried out and developers are required to fund any further works necessary should traffic flow from the development exceed an agreed level. Such works are likely to be in the form of traffic calming measures which would slow and potentially deter use of these routes as ‘rat runs’.
289. It is intended that Mock Lane (paragraph 9.34) will remain a rural lane north of the District Centre. Internal roads leading back to the A28 or Brisley Farm, are likely to provide easier routes to Ashford Town Centre. Potential problems with commercial vehicles using this route can and should be mitigated by appropriate signage and road engineering.
f) Dualling of the railway bridge is likely to be delayed or result in problems for pedestrians
176 – Ashford Independent Party Executive 423 – J R Carpenter 522 – Cllr Winston Michael
Response
290. There is no reason to believe that the dualling of the bridge should be delayed and even if it were, then the provisions of policy CG11 of the AAP would mean that the development would need to be restricted until that issue was overcome. The proposed re-design of the bridge accommodates pedestrian movements.
g) Lack of ‘Orchard Way’
271– Peter Webb
291. Representation 271 is concerned with the lack of the new route described in the GADF as ‘Orchard Way’ as a link from the A28 to the M20.
52 Response
292. In response to representation 271 paragraph 9.9 explains that the successful delivery of the Chilmington Green urban extension is not reliant upon the delivery of a strategic Orchard Way link (linking the A28 in the west with the M20 to the north east) to the east and no such link has been assumed in the background traffic modelling although the development allows for this to happen in the future. Were such a link needed in the future, the proposed movement network for the development could form the western section of such a link. This is an issue which will be further explored as part of the formal review of the Core Strategy.
h) The effect of the anticipated additional number of vehicles on the local road network in general.
20 – David Lay 228 – Independence & 34 – John Emms Access Matters (Francoise 409 – Lesley Bourne 53 – P G Churcher Montford) 414 – Sharon Kelly 56 – Raymond Woodcock 249 – Gordon Roberts 423 – JR Carpenter 64 – Chris England 253 – Yolanda Barker 454 – Kenardington PC 65 – Michael Dowsey 255 – Little Chart PC (Jane (Mrs Emily Neighbour) 93 – Daniel Hammett Ladds) 457 – Wittersham PC 97 – Dunster 257 – Central Ashford (Yvonne Osborne) 99 – Mc Cort Community Forum (Emily 461, 471 – Great Chart 103 – Jacky Watts Neighbour) with Singleton PC (Linda 145 – Brian Parritt CBE 265 – Margaret Cook Hedley) 146 – Mr T R Lacey 268 – Mason Brannan 492 – Save Great Chart 147 – Mr David White Design Action Group (Ian 153 – Cllr Andrew Mortimer 269 – Adrian Williams Wolverson) 183 – DA Craib MIET 513 – Highways Agency 186 – Frederick Westwood 270 – Sophie Walkden (Kevin Bown) 208 – Ashford Green Party 276 – Cllr Peter Davidson 522 – Councillor Winston (Steven Campkin) 313 – John Holland Michael 210 – Nigel Christian 337 – JA and MR Morris 523 – Nicholas Chaplen 225 – Lillian Brooks 378 – L Kemp and Eleanor Jeffrey - 226 – Shirley Ambrose 385 – Brenda Hedley Chaplen
293. The above representations are concerned with the volume of additional traffic associated with the development. Representation 513 from Highways Agency (Kevin Bown) supports the AAP and welcomes the opportunity to continue to work with ABC as the AAP progresses. Brian Parritt supports the plan but makes 2 suggestions regarding routing. The remainder raise objections.
294. Objectors have suggested that between 10,000 and 15,000 additional cars would be added to the local network. Objector 423 has calculated that at the rate of 8 traffic movements per day per dwelling, this would be 46,000 extra traffic movements per day. There is concern that additional commuters will cause problems on the roads at peak times and that the additional traffic will cause excessive wear and tear on roads and footpaths, which are already in poor condition (this concern was also shared by
53 representations 313 and 454). The location of the development to the south of Ashford is considered likely to add to traffic problems particularly in the south. Assurance is sought on how this development can be achieved with nil detriment resulting from the connection of Chilmington Green with Coulter Road. Wittersham Parish Council is concerned that the money for road improvements will not be forthcoming.
295. The additional traffic is considered by objectors to be likely to spoil local villages with noise pollution and volume of traffic, to add to the amount of traffic including HGVs using rural lanes and cause damage to listed buildings, danger to walkers, cyclists and horse riders. Construction traffic could be a problem for the 25 years or more that it takes for the development to be built. An increase in traffic is considered likely to lead to an increase in the amount of litter strewn along country roads.
296. There is concern that access to Mock Lane from the development will lead to congestion at Singleton Hill and danger at Tithe Barn Lane. Objectors consider that the HGV traffic associated with a potential Pyrolosis plant at the top of Singleton Hill should be added into traffic modelling. The development at Chilmington Green is considered to be unsustainable due to its distance from any amenity. The link via Coulter Road is objected to because it would result in an increase in traffic travelling through a residential estate.
297. Lack of parking at the station and in the town centre is also cited as a problem that would be exacerbated by an increase in traffic.
Response
298. The issues raised by these representations are important and relevant. Focus on mitigating traffic impacts should not only be focused on the strategic network. Inevitably it is harder to predict precise impacts in any traffic modelling exercise but particularly on different local roads which play different local roles.
299. In general, car trip generation rates are influenced by many factors but the potential for the use of other modes of transport and the availability of day to day services and facilities locally are especially important. It is also necessary to recognise that congestion only tends to occur during the morning and evening peak hours as people leave for and return from work.
300. Modelling carried out by consultants Jacobs for Kent County Council covers the town centre, the town’s urban area, M20 junctions 9 and 10 and the villages of Great Chart and Stubbs Cross. Main arterial roads in Ashford are included in the model and traffic from smaller roads is loaded onto the network at defined points.
301. The resulting table 1 in WSP’s Transport Strategy Overview shows predicted vehicle movements during the two busiest periods of the day 0800 – 9000 hours and 1700 – 1800 hours. The figures in this table are based upon the proposed number of dwellings, jobs, amount of retail floor space and education floor space. The number of vehicle trips resulting from the development is predicted to be less than 7000 in the two peak periods
54 combined. The movements are broadly similar for am and pm except for school arrivals which are concentrated in the morning. This model suggests that during morning peak times the additional traffic would be in the order of just over 3,000 additional vehicle movements and in the afternoon peak time just under 3,000 additional movements. The difference in morning and afternoon peak times is accounted for by the fact that the school day usually ends before the afternoon peak.
302. The estimates by the objectors are of an additional 10,000 to 15,000 vehicles on the road appear to be based more on average car ownership rates across the development and an assumption that most, if not all, residents will travel by car in and out of the site several times per day. However, such assumptions are not borne out by evidence from actual sites which form the bases for the traffic model’s assumptions.
303. In Chilmington Green’s case, the AAP strongly promotes the early establishment of a fast and frequent bus service to the town centre and the provision of a range of local facilities, including schools and shops. These will be mitigating factors on the need to travel off site by car.
304. The link to Coulter Road will provide a route to the east and to south Ashford from phase 2 of the development but will also provide a convenient link for existing residents of southern Ashford to the new facilities at Chilmington Green. The traffic modelling work has considered the likely impact of future traffic using this link and the impact will need monitoring over time to ensure the surrounding network remains suitable.
305. It is acknowledged that construction traffic can be noisy and inconvenient and a strategy for dealing with this over the course of the development will be required to be agreed between the developers, KCC and the council, as reflected in Para 11.43 of the AAP.
i) Public Transport Issues
03 - Mr Hopkins 208 – Ashford Green Party 423, 441 – J R Carpenter 09 – Rita Hawes (Steven Campkin) 457 – Wittersham PC 56 – Raymond Woodcock 209 – Elizabeth Eyre Yvonne Osborne 70 – Lionel Goddard 210 – Nigel Christian 496 – Save Great Chart 73, 74, 78, 86, 89, 90 – 228 – Independence & Action Group (Ian Daniel Hammett Access Matters (Francoise Wolverson) 105 – Sarah Keaveney Montford) 501 – Kent County Council 140 – Richard McN. 246 – Joanne Brand (Tim Martin) Beaugie 257 – Ashford Community 511, 512 – Highways 147 – David White Forum (Emily Neighbour) Agency (Kevin Bown) 170 – Stagecoach 276 – Cllr. Peter Davison 519 – Sarah Dacre 176 – Ashford Independent 293, 294, 296 – 523 – Nicholas Chaplen Party Chilmington Green and Eleanor Chaplen 184 – Sarah Keaveney Developers (Bob Sellwood) 533 – G&M Richardson & 313 – John Holland Ransley
306. Representation 03 supports the plan and agrees that all efforts should be made to maximise access to the town centre without use of the private car.
55 307. Representation 09 supports the plan and seeks early provision of bus services into Ashford especially early buses to the station.
308. Representation 296 supports the location of the Park and Ride.
309. Representation 56 feels that public transport will be needed to reduce the need for private vehicles.
310. Representation 70 considers the park and ride should be up and running before the Chilmington Green development is allowed to proceed.
311. Representation 73 considers that public transport (and community facilities) must arrive at the same time as occupation of the first development phase.
312. Representations 74, 209, 208 (Ashford Green Party), 246, 313 and 423 refer to an overloaded rail system, railway company should be consulted to find out what saturation figure is and when this is likely to occur. Similarly, 176, 208, 209 and 276 feels the development will put extra strain on the commuter rail system, already filled to capacity, especially at peak times.
313. Representation 78 consider the public transport schemes being proposed to be fairly mundane, and feel a rail link to Tenterden would be radical and serve the working households better and would be ‘ambitious’.
314. Representation 89 considers disruption of existing bus routes at Tithe Barn Lane and Knoll Lane.
315. Representation 90 question whether residents of other Ashford areas receive similar incentives to switch to public transport?
316. Representation 140 question why the development can not be put at the end of Steeds Lane, where it is isolated and has a bypass and a new railway station.
317. Representation 147 considers the new development to put catastrophic pressures on public transport links.
318. Representation 170 (Stagecoach in East Kent) support the plan but note that bus stops in the District Centre have not been mentioned and these should be closer to the centre than car parking points. This is an opportunity to avoid unusable bus stops that have not been properly considered early enough.
319. Representation 208 states that despite statements about public transport being provided, a caveat is being used to justify continued use of private cars. The Green Party believes this will be used to limit the provision of public transport at a later date.
56 320. Representations 184, 209, 210, 228, 313 and 246 consider the car parking at local stations (Ashford) is insufficient to cope with a large number of additional commuters.
321. Representations 246, 423 and 519 consider fares to already be expensive, and rising, and can be afforded by only the best paid commuters.
322. Representation 294 (Chilmington Green developers group) have requested some re- wording of paragraph 9.46 to reflect their concern that the current wording, with regard to incentives, is too open ended.
323. Representation 257 is concerned over lack of progress with Smartlink,
324. Representations 228, 257 and 86 state that Smartlink has been axed. A bus link which starts later than is necessary to catch an early morning train and stops before commuters return home in the evening, doesn’t run at weekends, is not going to help reduce car journeys to the station.
325. Representation 293 (Chilmington Green developers) support the content of CG12 but consider it needs to be changed to reflect their funding of the difference between operating costs and revenue for an agreed period.
326. Representations 313, 423 and 519 believe the Chilmington Green development will become a dormitory town for commuters, and add nothing to the local economy.
327. Representation 441 questions whether subsidised bus fares need to be cleared with competition authorities/Brussels?
328. Representation 457 (Wittersham Parish Council) questions whether the service provided instead of Smartlink will be good enough to coax people from their cars.
329. Representation 533 considers Chilmington Green to have poor transport links, no rail connection and a proposed rail halt for Park Farm that never materialised.
330. Representation 496 states that paragraph 9.43 is based on surmise without figures, occupants of the first and second phases will not be assured of reaching the station rapidly. Where has the figure 20% modal share come from?
331. Representations 511 and 512 (Highways Agency) support the plan but seek appropriate evidence at the time of the application to show that there will be sufficient modal shift to avoid an unacceptable impact upon the strategic road network. The requirement for a Travel Plan should be set out in the AAP. In addition the AAP should contain suitable targets such that appropriate monitoring, and management in the event of targets not being met, can occur.
332. Representation 523 considers that one of the 'key elements' for a sustainable community is the provision of 'a good public transport' system but that this needs improvement in the
57 road infrastructure prior to the building of the development to be able to work efficiently because of the weight of traffic, e.g. a lack of bus lanes, bus stopping places and the design of the estate roads as residential rather than arterial roads.
333. Representation 501 (KCC) all dwellings not just 80% should be within 400m walking distance of a bus route. Trigger point for providing bus services should be brought down to the 50th occupied dwelling to ensure that the opportunity to form habits of public transport use are not lost at the beginning.
334. Representation 105 sets out that the development will impact on public transport and car parking.
Response
335. In response to representation 03, 09, 56, 86,147, 228, 257 and 457: Paragraph 9.40 of the AAP indicates that the bus service will be provided to the town centre and the station at an early stage of development and sets out the frequency of the service at peak and off-peak times. These are in line with the expected frequencies for the ‘Smartlink’ network that is referred to in the Core Strategy.
336. 70: The need for the park and ride facility is related to development in the town centre rather than development at Chilmington Green. It will be assessed as part of the review of the Core Strategy, the proposed site is to be safeguarded for this use at least until the assessment has been carried out and a decision made on its future need.
337. 74, 176, 208, 209, 246, 276, 313 and 423: Overcrowding on trains is recognised as a problem relating to travelling from Ashford, mainly at peak times, but also on certain off- peak services. Network Rail is fully aware of the planned expansion of Ashford. Network rail uk publishes http://www.networkrail.co.uk/uploadedFiles/networkrailcouk/Contents/Publications/Route_ Plans/Network%20Specification%202011%20Kent.pdf
338. The document recognises that following the completion of the programme for 2009 - 2014, high peak capacity on the ‘classic’ routes to/from the capital will be at or very near maximum. There will be additional demand emanating from major housing developments in the southern Thames Gateway corridor and Ashford. Network Rail claim that 2014 – 2019 will see a financially sustainable railway with more seats, shorter journey times and greater passenger satisfaction. An industry plan up to 2019 maps out what needs to be done to deliver a better and more sustainable rail network.
339. 73, 90, 441: Complaints regarding subsidised bus fares are likely to be unfounded. Paragraph 9.43 explains that a subsidy will be required from the developers to support the early introduction of a specific bus service from Chilmington alongside the capital expenditure on bus priority measures until such time as the revenue meets or exceeds the operating costs of the service provided. Such funding cannot be expected to be provided for bus services unrelated to the development. Paragraph 9.43 recognises that a
58 service is unlikely to be commercially viable in the early phases and this is why a subsidy is required. This is a very common scenario. In any event, the intention is to grow bus patronage rather than divert existing patronage and liaison with the bus operator will ensure that this occurs (as it is to their benefit too).
340. A ‘quality bus partnership’ is an agreement between the principal bus company, Kent County Council and the district or borough council. There is such a partnership between KCC, local bus companies and Ashford Borough Council.
341. 78, 533: the Park Farm development is some considerable distance from the Chimington Green development. The proposals set out in the AAP would require the creation of much better public transport links to the Chilmington Green area than are available at present.
342. A new railway branch line linking Ashford to Tenterden is not a feasible or viable proposition.
343. 89: Whilst there would be some disruption during the works to provide bus priority measures at Tithe Barn Lane/Knoll Lane, these measures would be beneficial to existing bus services as well as those travelling from Chilmington Green. Paragraph 9.40 describes how the service would operate via the A28, Tithe Barn Lane, Knoll Lane and Victoria Way into the town centre.
344. 140: Development in the vicinity of Park Farm was considered and dismissed by the Inspector during the Core Strategy examination in 2008.
345. 170: It is agreed that the positioning of bus stops in the District Centre is an important aspect of the detailed layout for this area and will be addressed at a more detailed stage of the planning process as part of the Public Transport Plan.
346. 105, 208: The provision of an efficient frequent public transport system is a key part of the AAP and will remain so. It is also in the developers’ interests as traffic monitoring will identify if additional traffic from the development would generate the need for additional highway improvements. Policy CG12 requires a Public Transport Plan to be agreed as part of any Section106 agreement. The transport plan is to include a toolkit of measures to promote use of the service during the life of the development. It is of course unrealistic to expect the private car not to be used.
347. 105, 184, 209, 210, 228, 246 and 313: There is some capacity in the car parks surrounding the station at present and, over time, if passenger numbers increase, additional capacity will be planned with the railway operator and Network Rail. Of course, the opportunity will be there for residents at Chilmington Green to use the proposed frequent high quality bus service to the town centre that is a requirement of the development.
348. 246, 423 and 519: Train fares are a matter for the railway operators and the Rail regulator.
59
349. 249: In response to the developer’s concerns regarding the re-wording of paragraph 9.46 this is considered reasonable. Please refer to the schedule of proposed minor amendments.
350. 293: It should not be the role of the AAP to predict how long subsidy may be required for the bus service in advance of knowing what incentive measures are to be put in place to encourage bus patronage and the respective detailed costs of running the service. However, the principle that the frequency and quality of the service should be retained should remain as part of the AAP and underpin the incentive for the developer to help promote the service. Therefore, no change is proposed.
351. 313, 423 and 519: noted but this is a matter of speculation. The additional spending power of the new residents at Chilmington Green can however be expected to bring benefits to the local economy.
352. 496: The goal of achieving a 20% modal split in paragraph 9.38 is based upon the fact that the development is planned as a sustainable community where travel by bus will be a more attractive option than is currently the situation in most residential parts of the town or in the villages. It is ambitious but use of public transport will be encouraged by ensuring that most of the properties are within 400m of a bus route to enable ease of access. Subsidized fares will be offered to encourage a pattern of bus use. A frequent and efficient service is to be provided so that travel by bus is a realistic alternative for trips to the town centre and station.
353. 501: The Kent Design Guide seeks all properties to be within 400m of a bus stop, but in the case of a large development such as Chilmington, some of the peripheral properties may lie slightly outside that distance. Whilst bus routing could be amended, it would make bus journeys longer and more tortuous and the overall impact would be reduce the attractiveness and viability of the service as a whole. Therefore, the AAP aspiration as set out in para. 9.41 is a reasonable compromise.
354. Similarly, establishing a good bus service early in the development is key to establishing travel behaviour of the new residents. KCC seek an earlier trigger for the bus service than proposed in the AAP for this reason. Conversely, a bus service that actually serves a very small potential patronage is not necessarily the most effective or efficient use of the developers subsidy and can undermine the marketing of a new service. This can be a difficult balance to strike and it is felt that the AAP position of the occupation of the 200th dwelling represents a sensible position for the introduction of the bus service that will enable a reasonable prospect of patronage occurring from day one.
355. 511, 512: In response to the Highway Agency’s comments, it is not clear what sort of ‘Travel Plan’ is being referred to. The AAP already requires a Public Transport Plan to be delivered that will monitor patronage and modal split and on-going monitoring of trips will be required to ensure that the highway network is not over capacity at any given point. It is expected that a planning application would encompass a ‘Travel Plan’ that embodies
60 these elements from the AAP. The Highways Agency’s request for suitable targets to be included in the monitoring section is reasonable and it would be pertinent to make an alteration to the table in the Monitoring and Review chapter 12. Please refer to schedule of proposed minor amendments.
356. 523: agreed – it is important that proper provision for bus services is designed into the development from the start (with input from the bus operators themselves) and sufficient highway infrastructure is available for services to operate at the timetabled frequency.
j) Cycling and Walking
3 – Mr Hopkins 273– Ashford Clinical 383 – Kent Wildlife Trust 68 – Nanibabu Magar Commissioning Group (Miss Debbie Salmon) 228 – Independence & (Roger Pinnock) 464 – CPRE access matters 295 Chilmington Green Developers (Bob Sellwood)
357. Representation 295 supports policy CG13 as it provides an appropriate level of policy guidance on the creation of a network of strategic and local pedestrian, cycle and equestrian routes.
358. Representation 3 agrees with the approach that every effort should be made to link the CG development with the Town Centre. This will ensure people will have an alternative to using the private car, and relieve congestion on the local roads.
359. Representation 68 supports the plan but a footpath and cycle path should be provided to link Singleton Hill residents with the supermarket, park and other facilities at Chilmington.
360. Representation 464 (CPRE) considers access into the surrounding countryside is important and needs to be addressed
361. Representation 228 considers that there is no indication in the document that cycle /pedestrian paths are separated. Shared use is not possible for older/disabled people especially those with impaired eyesight.
362. Representation 383 Kent Wildlife Trust (Miss Debbie Salmon) supports the provision of an integrated cycle and walking network, providing this is balanced by an appropriate area of natural habitat for wildlife.
363. Representation 273 Ashford Clinical Commissioning Group (Roger Pinnock) supports the provision of a series of differing lengths of routes accessible to the public as footpath and/or cycle routes, linking green spaces. Where possible the start and finish points of these routes should link with public transport.
61 Response
364. Existing and proposed footpaths and cycle paths exist between Singleton Hill and the site of the proposed Discovery Park. The re-routed Greensand Way extends part of the way between Singleton and the District Centre. The proposed movement framework shown on Strategic Diagram 2 is not exclusive and links such as those suggested between Singleton and facilities in Chilmington Green can be accommodated in the development.
365. Access to the surrounding countryside can be built into the development at the more detailed design stage allowing routes through the built development to link with existing pathways into the surrounding countryside.
366. The design of footpaths/cycleways is a level of detail which will be addressed later in the development of the master plan. Similarly, the linkages between these routes and the public transport network can be planned in more detail at a later stage but the principle of integration is established in the AAP through the strategic movement diagrams.
k) Bridleways
492, 497 – Save Great Chart Action Group (Ian Wolverson).
367. 492 and 497, these representations question whether bridleways are necessary for this development.
Response
368. Bridleways and byways are minor public highways for which Kent County Council has the responsibility of management. As highways they cannot be closed or diverted without taking the legal steps required. However, riding is an increasingly popular sport and this is evidenced by the number of both private and livery stables in the area. There are very few public bridleways and riding on the roads can be dangerous and difficult for horse and rider as well as vehicular traffic.
369. The existing bridleways shown on Strategic Diagram 2 Movement Framework – c of the AAP are incorrect and are actually far less extensive than shown. The AAP will be amended to rectify the situation, please refer to schedule of proposed minor amendments. It remains the intention that some new provision will be made which will help to provide safer and more pleasant routes for horse riders. An existing short stretch of bridleway crosses the A28 via a bridge and continues as a bridleway for some distance on the northern side of the A28. New links with the existing path will therefore provide access to a more extensive route.
l) Impact of transport routes upon wildlife / Discovery Park.
346, 380, 382, 400 – Kent Wildlife Trust (Miss Debbie 464 – Hilary Moorby 479 – Kingsnorth Parish Salmon) Council
62
370. These representations are concerned about the fragmentation of the green corridors by roads, which block migratory routes and increase mortality rates. They request specific wildlife corridors to be included.
Response
371. It is acknowledged within the AAP that the route through Discovery Park should be designed in a way that does not dominate the setting of the park or create unnecessary severance. This link provides essential access to the District Centre for residents of Brisley Farm. The specific design of the road, which will include crossing points for pedestrians and cyclists may include tunnels for wildlife if sufficient need can be demonstrated. The details will need to be considered as part of the planning application process.
372. The Landscape and Visual Impact Assessment 2012 background study has helped to influence the development footprint and considered rights of way into and through the site. Due to its topography, paragraphs 7.13 and 7.15 suggest that the northern part of Discovery Park will provide opportunities for informal recreation and wildlife whereas the southern part of the site will be more suited to sports pitches. These distinctive uses will help reduce the impact of the road separating parts of the park.
373. The existing green necklace which encircles most of Ashford is itself intersected by a number of roads. It is necessary to put in place a road network which will help the whole development to function as a sustainable community. Much of the road network is already in place and it may be possible to preserve some of the existing roadside hedges. As there will be a number of water channels forming part of the Sustainable Drainage System, where roads cross over water channels they will provide an opportunity for wildlife crossing points.
374. Paragraph 9.50 refers to links between the District Centre and the countryside to the south of Discovery Park in the east and that these will be focused around the strategic green links which permeate the built up area. These links will naturally provide wildlife habitat. Paragraph 9.50 also requires that detailed sections of these links will need to be approved as part of the process of establishing the quality of the public realm.
m) Parking
56 – Raymond Woodcock 253 – Yolanda Barker 480 – Great Chart with 100 – Stuart Akers 273 – Ashford Clinical Singleton Parish Council 105 – Sarah Keaveney Commissioning Group 499 – Save Great Chart 178 – Fiona Burrell 432 – J R Carpenter Action Group 228 – Independence & 456 – Howard Matthews (Ian Wolverson). Access Matters
375. Representations 178 and 253 feel that there should be sufficient parking for residents at their homes, rather than parking on street and ‘falling out with neighbours’.
376. Representations 56, 273, 432, 456, 480 and 499 all raise issues about suitable parking being provided within the District centre and other areas of the development. Some feel that parking is not dealt with adequately by the AAP.
377. Representations 100, 105 and 228 feel that there will be an impact on the parking facilities in the Town Centre which are already overcrowded.
Response
378. In response to 178 and 253, the council has adopted its own SPD addressing residential parking standards. This guidance will be expected to be followed in proposals for the Chilmington development.
379. In reply to 56, 432, 456, 480 and 499, non-residential development will also require parking and provision will be made for this at Chilmington Green (paragraph 5.34) in accordance with the prevailing KCC standards or any subsequently adopted Borough council standards. Paragraph 5.27 requires that the High Street in the District Centre will be wide enough to incorporate parking bays. This requirement is spelled out in policy CG3 (c) Paragraph 5.34 states that parking will also be available in the District Centre Square. Parking for the strategic park is addressed in paragraph 5.81. Paragraphs 6.16 and 7.16 address parking provision for sports pitches and indoor sports buildings, this is supported in policy CG9.
380. 100, 105 and 253: There is some capacity in the Town Centre car parks at the present time. Core Strategy policy CS15 suggests a new Park and Ride facility in the Chilmington Green area as part of the wider parking strategy for the town. Paragraph 9.54 explains that as part of the review of the Core Strategy, the approach to accommodating the parking demands for the town will be reviewed. This may reinforce the need for a third Park & Ride facility at Chilmington or suggest an alternative approach.
n) Only one route going east
492 – Save Great Chart Action Group (Ian Wolverson).
381. Representation 492 considers that as the development spreads from west to east more road capacity will be needed to take traffic in an easterly direction.
Response
382. The development is planned with the district centre, secondary school and one of the local centres situated in the west of the site. It is expected that once the A28 has been upgraded, this will be the quickest and shortest route into the town and the chosen route for the majority of residents. Traffic moving eastwards can use the existing Magpie Hall Road or the new link across Discovery Park to Coulter Road.
64 o) Miscellaneous Transport comments
72 – Daniel Hammett 457 – Wittersham Parish 471 – Great Chart with 313 – John Holland Council Singleton PC (Linda 439 – J R Carpenter 454 – Kenardington Parish Hedley) Council
383. There were several miscellaneous points raised relating to the following issues:- • Wear and tear on roads and footpaths; • lack of money for road improvements; • the proposed Pyrolysis plant at Singleton Hill and KCC waste site at Cobbs Wood.
Response
384. In answer to representations 313 and 454, wear and tear on roads and footpaths would continue to be funded by KCC as it is at present.
385. In response to representations 72, 457 and 439 regarding lack of money for road improvements, the developers will be required to contribute to off site road improvements such as those required to facilitate bus traffic, improvements to the A28, and traffic calming measures, which are required as a result of the proposed development. There has already been a certain amount of forward funding in order to allow other developments to go ahead. Contributions from developers will be combined with KCC and Highways Agency funding in order to make the necessary highway infrastructure improvements. Policy CG11 requires the restriction of occupation until sufficient highway capacity exists.
386. In response to representation 471 relating to the Pyrolysis plant and KCC waste site upgrading at Cobbs Wood. With reference to the proposed Pyrolysis plant, the screening opinion under Regulation 5 issued by KCC under reference AS/0528/2011 states that a planning application for the Pyrolysis development would need to be accompanied by a Traffic Impact Assessment. Such an assessment would be carried out in the knowledge of the proposed residential and other development at Chilmington Green and would be assessed accordingly. Access to the Cobbs Wood and Pyrolysis sites, are not developments that the Chilmington Green developers can be expected to fund but improvements carried out to the A28 would be beneficial to other developments such as these.
65 THEME 7: EDUCATION PROVISION, SOCIAL AND COMMUNITY FACILITIES
Representations were received from the following consultees:
7 – Jonathan Barton 186 – Frederick 297, 299 – Chilmington 9 – Rita Hawes Westwood Green Developers Group 15 – Michelle Parsons 187, 188 – The Theatres 386 – Kent Wildlife Trust 19 – Steve Faldon Trust 402 – Kingsnorth Medical 34 – John Emms 189 – Philip Norris Practice 39 – Ward Member for 225 – Lillian Brookes 414 – Sharon Kelly Park Farm South 226 – Shirley Ambrose 423, 444 – JR Carpenter 53 – P G Churcher 228 – Independence & 458, 459 – Wittersham 54 – J A Churcher Access Matters Parish Council 56 – Raymond Woodcock 250 – NHS Kent and 472, 473– Great Chart 59 – Roger Coker Medway with Singleton Parish 60 – John Ley 253 – Yolanda Barker Council 105 – Sarah Keaveney 254 – St. Marys Great 477 – Kingsnorth Parish 141 – P Purnell Chart with St. Marys in Council 142 – Sarah Stanfield Singleton 503 – Kent County 144 – Donald Fagg 257 – Central Ashford Council 147 – Mr David White Community Forum 505 – Ian Wolverson 148, 149 – Sally Gathern 273 – Ashford Clinical 523 – Nicholas Chaplen 166 – Yvonne Carole Ho Commissioning Group and Eleanor Jeffrey – 178 – Fiona Birrell Chaplen
a) Main Issues Raised
387. One of the main concerns for respondents was that the proposed development may put pressure on existing local services including schools, and there was concern about additional competition for school places (representations 34, 39, 53, 54, 56, 59, 60, 105, 141, 142 144, 148, 186, 189, 225, 226, 228, 257, 414, 458 and 523). Conversely, representations 15 and 166 felt there were enough schools, supermarkets already without more being built.
388. Representation 53 questioned how many schools the developers could afford to build. Representation 178 queried how future schooling needs could be accurately predicted. Representation 253 had reservations about new schools opening when other schools in the area have spaces.
389. Representation 9 expressed the need for the primary schools to be built during the early phases at the District Centre. Representation 472 felt that school places should be planned across the Borough as a whole and objected to the obligation and burden being placed solely on the proposed Chilmington Green development.
390. Representation 459, 458, 472, 253 and 149 sought assurances that if a ‘free’ school was delivered (as considered by the developer consortium, paragraph 10.9) that the school places would be accessible. Representation 297 considered policy CG15 to not
66 accurately reflect paragraph 10.10 in that schools may be operated by either KCC or an alternative provider.
391. Representation 503 (KCC) object to the wording of policy CG15 as they consider it results in KCC having to forward fund the project if the school is required in the short to medium term. Representation 503 also objects as they consider the wording to cause KCC to have to secure contributions towards secondary land costs if not transferred at nil cost. Representation 503 anticipate further need above the 6FE / 8 ha proposed within the AAP to be addressed as part of the Core Strategy Review as well as forming part of the Borough’s CIL Charging Schedule as more than five sites will be contributing.
Response
392. In response to representations 34, 39, 53, 54, 56, 59, 60, 105, 141, 142, 144, 148, 186, 189, 225, 226, 228, 257, 414, 458 and 523: this issue has been responded to under Objection Point 3 in the standard 9 point representation letter (see theme 1 of this paper - above) and is not repeated here.
393. In response to representations 15 and 166 the new development at Chilmington Green will significantly increase the population of Ashford which in turn will require the delivery of new infrastructure and facilities critical to creating a sustainable development. This is a requirement of Core Strategy policy CS18.
394. In response to representations 53, 178, 253, 472 and 9 the requirement for new schools set out in Policy CG15 has been worked up alongside KCC education officers, supported by KCC’s modelling work. The scale of development at Chilmington Green will generate significant demand for new primary and secondary school places. Secondary school provision is mainly dependent on the anticipated number of pupils passing through the primary school system across the whole of Ashford, of which Chilmington Green is only a part, in the short to medium term. There are four primary schools being proposed within the development boundary as these will need to directly meet the needs generated by the new development. The first school is proposed to be delivered within the District Centre to support early development there. It is difficult to accurately predict demand for school places over the longer term, so the AAP is flexible in its approach and will be able to respond to demand for places as it is generated. Careful attention has been given to the deliverability of the scheme as a whole, ensuring that the cumulative obligations and policy requirements for key infrastructure set out in the AAP are viable and deliverable, inline with the NPPF.
395. In response to representations 459, 458, 472, 253 and 149 children within Ashford Borough already attend a number of independent schools outside those managed by the local education authority and the potential creation of new ‘free’ schools may influence where pupils are educated and the level of spare capacity in the LEA sector. Free schools will determine their own entry criteria within certain designated parameters. Funding for school provision therefore comes from a variety of public and private sources and the council should not be prescriptive in the AAP in this respect.
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396. In response to representation 297 and to ensure clarity and consistency, it is proposed to amend Policy CG15, please refer to the schedule of proposed minor amendments.
397. In response to representation 503, paragraph 10.10 of the AAP refers to the need to transfer the school sites to KCC (if it is they who will be the education provider) in line with their requirements, which are then footnoted. Detailed transfer arrangements should be negotiated between the parties either as part of a Section 106 Agreement or as a bilateral agreement between landowners. It is open for KCC to recycle any education contributions already banked to offset any forward funding issues. Any additional education requirements will need to be met through allocations outside the AAP boundary.
b) Social and Community Facilities
398. A number of respondents felt that the proposed development would put pressure on existing local services including hospitals, doctors, dentists, and there was concern about additional competition for hospital beds and medical treatments (representations 7, 19, 34, 39, 53, 54, 56, 59, 60, 141, 142, 144, 147, 178,186, 225, 226, 228, 257, 402, 414, 423, 523, and 458).
399. Concern was raised about lack of policing (representations 59, 141, 142, 186, 225, and 226).
400. Representation 402 consider the requirement of policy CG17 to accommodate social and community facilities as part of a combined community ‘hub’ to pose logistical problems with regards to the flexibility to cope with expansion, and infection control in the case of a potential flu pandemic. Conversely, representations 273 and 250 support the approach to co-locate community and primary health care facilities with social care providers, within a single community hub building or in separate facilities in close proximity within the District Centre.
401. Representation 250 (NHS Kent & Medway) suggest suitable space be available for up to 8 GPs to serve the eventual population of Chilmington Green, and provide specific space requirement details for health facilities. Representation 444 considers a maximum of 6 GPs to be insufficient for the potential population size. Representation 402 feels that there is a need to allocate a one acre site for the provision of primary and community health care services close, but not within the community hub.
402. Representation 178 questions where all the medical staff are going to be sourced.
403. Representation 250 supports paragraph 10.27 for the phased delivery of space where demand builds up over time, including reserving land to enable potential for the extension of premises at a later date. Representations 273 and 250 consider it important that there is a phased approach to when health services are on site delivering care to local people and support the District Centre being built at an early stage to accommodate these services.
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404. Representation 273 consider the plan does not reflect additional requirements placed upon local community services from development, such as district and specialist nursing, health visiting, or allied health professionals such as podiatry, physiotherapy and speech therapy. Representation 250 highlight that health services can include GPs, Dentists, Pharmacists, Optometrists and other community and secondary care services. Representation 250 expects the development to accommodate 1 – 2 dentists, and 1 – 2 pharmacies as part of the primary care provision. 273 want assurances that sufficient space will be available for primary care services, including car parking.
405. Representations 273 and 250 states that it is important to recognise that local health commissioners want to provide a wider range of services in the community and will need to ensure that community facilities are flexible to meet service changes. Representation 250 support the development of a multi-tenanted site, for health services.
406. Representation 299 expressed support for Policy CG17 stating that it provided an appropriate level of policy guidance on the type, amount and location of social and community facilities at Chilmington Green.
407. Representation 473 consider there to be no evidence to suggest in the form of business plans that these services can be funded. They don’t want development to proceed until a firm guarantee has been given by the NHS that funding is available to obtain full services in support of the development. Representation 523 consider the AAP to have made no provision to accommodate new health centres, and are concerned that health provision would be funded by the NHS and therefore outside the control of either the Council or the developer and was also concerned that if there is no interest by service providers to deliver planned amenities, such as schools, surgeries, cricket pitches, and badminton courts etc. the land will be used for houses. Representation 228 queried where the major infrastructure required to serve the development (noting health, schools, social care, transport, roads etc) was to come from.
408. Representation 477 would like to see the community aspects that are not currently being provided in the Brisley Farm and Washford areas, enhanced as part of the provision.
409. Representations 187 and 188 want the word ‘cultural’ to be in policies CG16 and CG17 to reflect the Sustainable Communities Strategy.
410. Representations 254, 473 and 505 think it is important that provision is made for a Place of Worship.
411. Representation 386 believes that education, indoor sport, community leisure, social and community facilities would lend themselves to the provision of extensive green roofs, walls and balconies to attract wildlife.
69 Response
412. In response to representations 7, 19, 34, 39, 53, 54, 56, 59, 60, 141, 142, 144, 147, 178,186, 225, 226, 228, 257, 414, 523, and 458 this issue has been responded to under Objection Point 3 of the standard 9 point representation letter.
413. In response to representations 402, 273 and 250 locating different health services under the same roof will be convenient in terms of access for service users, and will allow for more efficient and viable use of space. This general approach has been regarded as the best and most efficient model for provision of primary health services and has been successfully delivered elsewhere. It also provides the opportunity for links with related services such as social services. It is agreed that health provision will need the ability to expand as the different phases get built out. Paragraph 10.27 of the AAP addresses this issue and requires the phased delivery of space, including the need to reserve land to enable the potential for extension of premises at a later date.
414. In response to representations 250 and 444 primary health care or surgery catchments are not easily planned or necessarily self contained within the Chilmington Green development. The AAP’s approach is not to identify the minimum requirement for accommodation but allow additional community space to be used for this purpose towards the end of the development should the need arise. Paragraph 10.27 requires a phased delivery of space and policy CG17 further supports this flexible approach by requiring any expansion of GP services in the long term to be made available at the Local Centres. This should provide enough flexibility to ensure suitable space provision for health services and associated facilities within the development as it progresses into the long term.
415. In response to representation 178 it will be for the market to determine where medical staff for the health facilities are sourced - this is not a planning matter.
416. In response to representation 250 and 273 the plan has set out the requirement for the development to include health provision. It is not necessary at this point to include specific detailed space requirements for health as these will need to be determined as part of the planning application process. Health provision needs to be flexible and policy CG17 encourages health facilities to be shared by different service providers. This is supported by paragraph 10.27 which requires on-site space to allow flexibility for use by different services.
417. In response to representations 228, 473, 523 policy CG17 makes provision for community and primary health care facilities to be provided within the AAP area, including accommodation for at least a 6 GP practice. The Council has been working jointly with key health service providers to ensure the needs from development are met in the preparation of the AAP. It is recognised that the delivery of services is a matter for the service provider themselves (in this case, the NHS) but these are matters determined outside of the council’s control. As set out within Policy CG17 ‘the phasing and delivery of social and community facilities and / or funding to support such services shall be agreed
70 with the relevant service providers and included in an appropriate Section 106 Agreement’ and this should provide assurances that appropriate health / service provision will be delivered. Policy CS5 (d) of the Core Strategy makes it clear that development at Chilmington Green should be ‘developed at a rate which is supported by the delivery of infrastructure and the elements required for a balanced, mixed community. Chapter 11 supported by Appendix 3 of the AAP sets out the main development and infrastructure requirements that will be delivered as part of the Chilmington Green development. Policy CG1 (b) has been written to ensure that each main phase of the development will be sustainable in its own right, through the provision of the required social and physical infrastructure.
418. In response to representation 477, it is not lawful in planning terms to place obligations on new developments for the intention of countering any deficit in provision elsewhere. The Council is only able to ensure that development meets its own needs.
419. However, the Council’s approach towards service delivery is to encourage as much integration with the surrounding area and nearby communities as possible, so that any provision can benefit as wide a catchment as possible.
420. At Chilmington Green, the existing residents at Brisley Farm and neighbouring areas are well placed to benefit from the extensive range of services and activities which are planned to come forward at Discovery Park. They will also benefit from the extensive new services and facilities which are planned at the District Centre, with an early pedestrian link being proposed which will increase the connectivity between these areas.
421. In response to representations 187 and 188 this is a point that relates more to the borough as a whole, rather than a small part of it and is something for the Core Strategy review to address - no change necessary.
422. In response to representations 254, 473 and 505 places of worship could be included as one of the potential range of community facilities which the plan has made generic requirements for within policy CG17. Any specific need for a place of worship will need to be set out and justified in order for it to be given a specific space requirement within the AAP. However, it is agreed that places of worship are important and therefore should be listed among shared space and community facilities.
423. Comment made by 386 is noted - detailed guidance on issues of design will supplement the AAP at a later stage to ensure the principles of high quality design and sustainability objectives set out within the vision are met. Policy CS10 of the Core Strategy encourages major development to maximise gain to biodiversity through design and this will be a consideration within the detailed guidance to support any planning application.
71 THEME 8: INDOOR SPORT AND COMMUNITY LEISURE BUILDINGS
Representations were received from the following consultees:
141 – P Purnell 298 – Chilmington Green 526, 529, 530 – Sport 187, 188 – The Theatres Developers England (Dale Greetham) Trust (Rose Freeman)
a) Supportive comments
424. Sport England has made a number of supporting representations (530) relating to the provision of indoor sport facilities provided in policy CG16. Representation 526 emphasises that it is essential to provide for indoor sport to meet the needs of both new and existing communities, and therefore supports the identification of the sports facility in relation to on-site and off-site requirements. Representation 529, 530 also welcomes the use of the Sports Facility Calculator to estimate the amount of demand for key community sports facilities by the given population, and have provided further guidance and ‘toolkits’ to assist with this process.
425. Policy CG16 is also supported by the Chilmington Green Developers, representation 298.
Response: Supportive comments are noted.
b) Main Issues Raised
426. Representation 141 does not feel that Ashford Borough has adequate provision of community facilities in general and that people need an ‘improved way of life’. Representations 187 and 188 request that the word ‘cultural’ be added to policy CG16 to reflect the Sustainable Community Strategy.
Response 427. In response to representation page 141, the Chilmington Green development will deliver a wider variety of community facilities which will significantly add to the offer available in the town which will help contribute for an improved way of life for residents.
428. In response to representations 187 and 188, the principle of delivering cultural uses at Chilmington Green is already covered by Core Strategy Policy CS18 which lists culture as a use which helps meet the needs of the community. There is no need to repeat this position in the AAP and hence an addition to the text is not needed. In addition, the central message of Policy CG16 is to deliver flexible space which can be used for many uses, including sport, community and leisure. In this context, these buildings could equally provide space for a variety of cultural uses, if required. There is certainly nothing in the AAP to suggest that cultural uses would be inappropriate, as a point of principle.
72 THEME 9 – AFFORDABLE HOUSING
Representations have been received from the following consultees:
70 – Lionel Goddard 266 – Margaret Cook 474 – Great Chart with 208 – Ashford Green 281, 300 – Chilmington Singleton PC Party Green 504 – Kent County 232 – Christine Rees Developers Group Council
Main Issues Raised
429. Representation 70 suggests that the national affordable housing level should be increased to 50%.
430. Representation 232 states that affordable homes are only 20% cheaper than an average market home. They believe the average house price is £500,000, and therefore the affordable homes will cost £400,000 and will be unaffordable for first time buyers. They also state that the borough already has a number of empty ‘affordable homes’.
431. Representations 266 and 474 believe the current affordable housing proposals are weak with too much flexibility. They believe the ‘claw back’ element in later phases could cause all phases to deliver a short fall in affordable homes.
432. In response to representation 208 due to the long build out period of the site and the change in National Guidance, this policy could change during subsequent reviews of the Core Strategy/Local Plan and the AAP. However, there are restrictions and safeguards in place on affordable housing provision which would ensure that this important part of the housing stock cannot simply be purchased by buy-to-let landlords. Affordable housing would include social housing, intermediate rental and shared ownership, where an owner occupier could buy half of the property and rent the rest of the property from the registered social landlord.
433. Representation 281 welcomes the recognition of viability assessment to ensure the maximum viable level of social and physical infrastructure in each phase. However, they are concerned with the concept of ‘claw back’ in later phases as it will cause financial uncertainty, and wish the policy to remain that no phase provides more than 30% in line with the Councils current policy. Request the deletion of paragraph 1.24 under viability and references in this chapter.
434. Representation 300 from the developer consortium requests changes to policy CG18 which would remove the ‘claw back’ mechanism and the minimum and maximum percentages for affordable housing in each phase. Instead, it is proposed that the policy for affordable housing is either based on a single viability exercise at the start of the development or at the start of each main phase but with no prospect of clawing back any under-provision at a later stage.
73 435. Representation 474 questions if people that purchase affordable homes would be required to pay a levy.
436. Representation 504 request the term ‘wheelchair accessible housing’ be added to the end of paragraph 10.43.
Response
437. In response to representation 70 the affordable housing element is set through Core Strategy policy CS12 and therefore has already been through the Public Examination. The Council also has an adopted Affordable Housing SPD. In addition to this, a strategic housing market assessment and housing needs assessment carried out in 2010 both affirmed the policy. The Government has updated the approach to affordable housing and the SPD will be amended to reflect this. However, it will substitute one form of housing for another and not increase the total level of provision.
438. The council disagrees with representation 232. The average house prices in Ashford sourced from the House Price Survey 2010 are £332,919 in the rural area and £201,634 in the urban area. This is significantly below the £500,000 average price mentioned in this representation, and therefore the price of affordable housing quoted is not accurate. In any case, the affordable element offers a part rent - part buy scheme, and therefore first time buyers would not be required to pay the full market price. The housing department has confirmed that there is no significant amount of empty affordable homes. If they are empty, they are usually being repaired or are going through the sale process. It would not be in the Councils or any part owners interest to have vacant homes.
439. In response to representations 266 and 474 the plan is flexible as it is covers a long timescale for development and will need to be suitable in varying circumstances. However, Para 10.36 does state that if a different amount of affordable dwellings are proposed then it will need to be verified by a 'robust and independently verified viability assessment'. It also says that the council would expect reasonable 'claw back' in the subsequent phases. If not, the developer would be required to contribute to off- site affordable housing. Therefore, although the overall policy is flexible, the requirement for providing the affordable housing for the completed development is robust. The issue of whether some affordable housing could be provided off-site is mentioned as an option in the flexible approach, as well as leaving areas in the early phases vacant with affordable housing being built later.
440. In response to representation 208 due to the long build out period of the site and the change in National Guidance, this policy could change during subsequent reviews of the Core Strategy/Local Plan and the AAP. However, there are restrictions and safeguards in place on affordable housing provision which would ensure that this important part of the housing stock cannot simply be purchased by buy-to-let landlords. Affordable housing would include social housing, intermediate rental and
74 shared ownership, where an owner occupier could buy half of the property and rent the rest of the property from the registered social landlord.
441. The Council disagrees with representations 281 and 300. The AAP policy CG18 is drafted to give the best chance of securing the Core Strategy requirement for affordable housing (30% of the total development) whilst acknowledging the long timescale for the delivery of the development and the inevitable fluctuations in the economic cycle and consequent viability that will occur during that time.
442. For this reason, it would be inappropriate to base any viability case for the duration of the development solely on the situation at the beginning of the development. In the current economic climate, this could result in a significant shortfall in affordable housing being ‘set in stone’ for the whole scheme irrespective of future market changes.
443. The alternative option promoted by the developers, whilst accepting that viability should be re-assessed at the start of each main phase, makes no allowance for rectifying any shortfall in provision of affordable housing from previous phases. This would also have the effect of consolidating any previously justifiable under-provision in perpetuity.
444. The principle of a ‘claw-back’ in developer contributions is well established in Ashford and has been reflected in several planning permissions in recent years. This accepts that short-term viability issues should not necessarily constrain development getting underway but if market conditions improve, then deferred contributions would be triggered. This is a suitable and flexible approach especially where development will be delivered over a prolonged period.
445. Policy CG18 specifically recognises that affordable housing can play a major part in establishing viability for a development and allows considerable flexibility both in terms of the percentage and type of affordable housing to be sought. The provision of a minimum and maximum percentage within any one phase ensures that there is a balanced and mixed community without creating a ‘ghetto’ in any one location which would undermine the character of the whole development. This approach is also consistent with the NPPF para.50 which advocates such policies being flexible to take account of changing market conditions over time.
446. In answer to representation 474, Policy CG10 details the wider governance arrangements and suggests a trust arrangement. Should this occur the details including who will be required to pay the levy will be determined at this stage. The AAP does not include this detail to increase flexibility.
447. Representation 504 – The council agrees with the comment and will add ‘wheelchair accessible housing’ to the end of paragraph 10.43
75 THEME 10: SUSTAINABLE DESIGN AND CONSTRUCTION
Representations were received from the following consultees:
14 – KTI Energy Limited 388 – Kent Wildlife Trust 454 – Kenardington 62 – Martin Carter 423 – J R Carpenter Parish Council 91 – Daniel Hammett 425 – Adams Hendry 460 – CPRE Ashford 257 – Central Ashford Consulting Ltd on behalf 487 – Ian Wolverson Community Forum of South East Water 488 – Save Great Chart 301 – Chilmington Green 445 – J R Carpenter Action Group Developers Group
Main Issues Raised
448. Representations 257 and 454 are concerned about the long term shortage of water in the area.
449. Representation 257 seeks assurances that all properties and public buildings are sustainable with water collection and recycling, renewable energy and energy-saving technologies.
450. Representation 14 considers the AAP not to conform with (i) EN-3 Renewable Energy Infrastructure NPS or (ii) the NPPF. They state that EN-3 advises an energy developer to locate his/her renewable CHP station where it may receive its blend of wood pellets, wood chips, SRF, agricultural residue and energy crops by rail or water. Sections 95, 96 and 97 of the NPPF advises that local authorities should identify the opportunities for supplying green electricity and heat to a community and enter the generation site(s) into its Local Development Framework.
451. Representation 91 has concerns about the use of solar gain (paragraph 10.50) as a design aim.
452. Representation 445 has concerns about the cost of applying sustainable design and construction to development and question whether people will be prepared to pay more for ‘sustainable’ housing.
453. Representations 487 and 488 have concerns that policies CG19 and CG22 make no reference to build standards and quality of materials used, such as durable resilient materials to reduce maintenance costs.
454. Representations 301 and 388 support the policy aspirations for development to be carbon neutral in accordance with policy CS10 of the Core Strategy. However, representation 301 objects to policy CG19 as written as they consider it to be inflexible and prescriptive as the policy states that an alternative to Combined Heat and Power (CHP) would only be acceptable ‘should an independently verified financial assessment prove that such a network is not financially viable’. This is considered unsound by 301 as they feel this prevents the developer adopting the most effective solution/s to achieve policy CS10.
455. Representation 425 states that Policy CG19 does not specifically refer to incorporating sustainable design measures in new development. Representation 425 supports the requirement for new development to achieve Level 4 of the Code for Sustainable Homes, and BREEAM environmental standards. However, they are disappointed that Policy CG19 does not specifically refer to water efficiency measure and have requested amendments to the policy wording.
456. Representation 62 commented that at a public display of plans they were told the development would be the most eco-friendly development utilising the latest technology, yet when pushed regarding rainwater harvesting systems, there was a lack of knowledge about the technology. Similarly, representation 460 consider rain water harvesting to be essential, and feel that simple provision of water butts to each house is not sufficient. Representations 62 and 460 fear that if the plans go ahead there will be a huge additional burden on increasing scarce water supply.
457. Representation 423 states that the Environment Agency have confirmed that sewage and water from the development will have to be pumped over the Greensand Ridge to the Bybrook Treatment Plant, and feel that this situation does not sit well with the carbon-neutral aspirations set out in the AAP.
Response
458. In response to representations 62, 257, 454 and 460 this issue has been responded to under Objection Point 8 of the standard 9 point objection representation.
459. In response to representations 257 policy CS10 of the Core Strategy is in place to ensure all new major developments within the Ashford Borough are carbon neutral and built to high standards of sustainability. Policy CG19 confirms that this will apply to the proposed development at Chilmington Green. Paragraph 10.47 of the AAP states that residential development at Chilmington Green will need to achieve Code level 4 of the Code for Sustainable Homes, with non-residential development needing to achieve an overall BREEAM rating of Excellent environmental standard, as well as reducing carbon emissions from development by 30%. These are challenging standards and the developer will need to implement an array of measures, such as reducing the need for energy through site layout and design, using energy efficiently by incorporating thermal efficient glazing, insulation, energy efficient appliances, and will need to install ‘on-site sustainable energy technologies’ or renewable energy to reduce energy consumption by at least 30%. The policy approach is not just focused on energy, the Code for Sustainable Homes and BREEAM consider the overall sustainability of the development, and requires water efficiency, the use of materials which have a low environmental impact, the consideration of waste and recycling, and maximising biodiversity gain for wildlife.
460. In response to representation 14 the Council disagrees Chilmington Green is not a major energy project so EN-3 Renewable Energy Infrastructure NPS does not apply. The plan is consistent with the NPPF in that it supports the delivery of renewable and low carbon energy and associated infrastructure.
461. In response to representation 91 passive solar gains through orientation of buildings is a sensible way to achieve significant potential energy efficiency savings. The AAP is not implying that photovoltaic (solar) panels should also be routinely fitted as this might have adverse design consequences. Guidance set out within the Sustainable Design and Construction SPD addresses the issue of excessive passive solar gain by considering the use of such measures as natural ventilation, providing vegetation and private outdoor space wherever possible.
462. In response to representation 445 it will be for the market to determine the final purchase price of properties. Implementing policy CS10 of the Core Strategy has a number of benefits for future residents, including the building fabric being energy efficient, promoting water and energy efficiency, limiting CO2 emissions and therefore running costs arising from the operation of a dwelling, as well as making the properties more adaptable to the effects of climate change. 77
463. In response to representations 487 and 488 the Council gives great weight to good quality design when determining planning applications. Policy CS9 of the Core Strategy requires development proposals within the Borough to be of a high quality design that must demonstrate a positive response to the richness of detail, which includes the use of materials. The vision within the AAP, policies CG1 and CG2, set out the aspirations for high quality design standards across the development.
464. In response to representations 301 and 388 support for carbon neutral development is welcomed.
465. In response to representation 301 the evidence base for the AAP suggests that a CHP solution in and around the District Centre represents the optimum solution to meet the requirements of policy CS10 of the Core Strategy for the reasons set out in paragraphs 10.52 and 53 of the AAP. Supporting paragraphs to policy CG19 will be slightly amended to make them more consistent and clear, please refer to the schedule of proposed minor amendments. If a more effective on-site energy generation system is subsequently found by the developers, neither CG19 nor the supporting text prevents such an alternative occurring.
466. In response to representations 62, 425 and 460 no change is necessary. The mandatory water consumption requirement for Code for Sustainable Homes Level 4 is less than 105 litres of potable water consumption per day, this is illustrated within the Chilmington Green Water Strategy (March 2012). This is significantly lower than 160 litres that the standard person uses each day. This can be achieved through the use of water efficient fittings, appliances and recycling systems but it will be for the developer to decide what measures to install to reach the target consumption level. Amending the policy wording would not add to this point, as 'on-site design measures' are already referred to within Policy CG19 wording.
467. Comments made by representation 423 are noted, however the principle for major development at Chilmington Green was set out in the adopted Core Strategy in the knowledge that the Bybrook works would be destination for sewage and wastewater from the site. This has been planned in conjunction with the EA.
78
THEME 11: FLOODING AND SUSTAINABLE DRAINAGE
Representations were received from the following consultees:
237 – Natural England 341 – Environmental 464 – CPRE 267 – Margaret Cook Agency 475 – Great Chart with 277 – Linda Cleaves 352, 391 – Kent Wildlife Singleton Parish Council 302 – Chilmington Green Trust Developers Group
Main Issues Raised
468. Representation 302 supports policy CG20 as it provides essential strategic guidance on avoiding development in the 1 in 100 year flood plain with a series of flexible criteria for the locations of SuDs. Representation 237 also supports policy CG20 but would like detailed consideration given to water quality during the construction phases and thereafter, particularly in relation to on-site habitats and species.
469. Representation 391 also supports the provision of SuDs and the vision to combine this network with the creation of ecological networks relatively free from public pressure, and support the long term management and maintenance of the habitats created. Representation 391 stress that due to the presence of Great Crested Newts and other amphibians, the networks need to be designed sensitively (listing key requirements).
470. Representation 391 stresses that the water entering the watercourse will need to be filtered to ensure there are no contaminants such as oil, salt or heavy metals that may cause deterioration to water quality and recommend that the need for water filtration either through provision of an artificial filtration system or ideally through natural methods such as reed beds be specified preferably within policy CG20. In this context, they have suggested changes to policy CG20 and paragraph 10.62.
471. Representation 352 recommends minor changes to paragraph 4.2 (v) to ensure forward planning is incorporated into Chapter 4 with regards to drainage.
472. Representation 464 welcomes the plan to manage flood risk but suggest that a more precautionary approach than a 1:100 year flood risk be used, against the uncertainty of climate change and impermeability of the underlying clay.
473. Representation 341 would like to see consideration of the objectives of the South East River Basin District Plan and the Thames River Basin District Plan when planning SuDs and any works in or near watercourses, with the aim of restoring or enhancing watercourses, including re-creating natural morphology and river and floodplain habitats.
474. Representation 475 and 267 states that as Chilmington Green sits on Wealden Clay, and water runs down from the escarpment to the low-lying parts of Mock Lane, Bartlett Lane and Chilmington Green Road, there is concern that developing the downward slope may exacerbate the drainage problems leading to increased flooding. Representation 277 wants reassurances that the introduction of the SuDs feature to the south west corner of the AAP will not have an adverse impact on either flood risk, or general ground conditions, in the surrounding area.
79 Response
475. Supportive comments noted.
476. The Council agrees with representation 237 and propose a minor amendment to the AAP, see the schedule of proposed minor amendments.
477. With regards to representation 352, it is not considered necessary to alter the AAP as suggested. Paragraph 4.2 (i) ‘ecology’ already makes it clear that the storage areas to the south of the development will play a key role in ecological terms and therefore this point doesn’t need to be repeated.
478. In response to representation 464, the requirement in the NPPF is that inappropriate development in areas at risk of flooding should be avoided and in this context refers (through the technical guide) to land within Flood Zones 2 and 3; or land within Flood Zone 1 which has critical drainage problems. Therefore it is not justified to apply the 1 in 1000 year rule, as has been suggested. In any event, the Chilmington Green Flood Risk Assessment identifies that the majority of the development area is located within Flood Zone 1, and therefore has less than 1 in 1000 annual probability of river or sea flooding in any year.
479. With regards to representation 341, the aims and objectives of the South East River Basin District Plan and Thames River Basin District Plan will be considered through the detailed planning of the SuDs areas. The Council’s recently adopted Sustainable Drainage SPD requires development to avoid impacting existing watercourse and associated corridors, and this will need to be demonstrated through any SuDs Strategy that supports a planning application.
480. In response to representations 475, 267 and 277, Policy CS20 of the Core Strategy, alongside the Councils recently adopted Sustainable Drainage SPD requires development to incorporate appropriate SuDs for the disposal of surface water, as well as to avoid any increase in flood risk to other areas or impacts on water quality. The SPD goes further and actually provides applicants with guidance through best practice examples and engineering advice on installing the most appropriate SuDs method. This will be debated through the planning application process.
481. In response to representations 391, no change is required to either Para 10.62 of the AAP or Policy CG20. Para 10.62 already states that any new sustainable drainage channels should be appropriately designed in accordance with the objectives and principles of the adopted Sustainable Drainage SPD. This SPD provides extensive guidance to ensure that the design of SuDs seek to enhance both wildlife and ecology, as well as help to protect the environment.
80 THEME 12: ECOLOGY AND LANDSCAPE
Representations were received from the following consultees:
9 – Rita Hawes 303; 304– Chilmington 423; 426; 446 –JR 143 – R M Hayward Green Developers Carpenter 167– C Craib Group (Bob Sellwood) 460, 466– CPRE 176 – Ashford 346; 349; 352; 364; 366; Ashford (Hilary Moorby) Independent Party 367; 374; 377; 380; 382; 476, 481 – Kingsnorth Executive 391; 393; 400 - Kent Parish Council 234; 236; 238; 240– Wildlife Trust (Debbie 495; 498 – KCC (Tim Natural England Salmon) Martin) 277, 514 – Linda 417 – JP Palmer 519 – Sarah Dacre Cleaves 543 – Mr & Mrs Olds
a) Landscape
482. Representations 466 and 481 support that the development intends to bring the countryside into the development by “green fingers” and its desire to retain most of the existing network of narrow roads and hedgerows, making them integrated with the design.
483. Representation 303 outlines that policy CG21 is supported since it provides clear guidance on the approach to ecological matters and the need for the preparation of an ecological enhancement mitigation strategy.
484. Representation 460 states that this is a major development in the open countryside and it is imperative that the boundary of the site is strictly defined and not allowed to expand further into the open countryside. Representation 423 reaffirms this view and urges that development should not spill over the ‘greensand’ ridge into the Weald.
485. Representation 426 states that it is nonsense to suggest that undulating land and a few trees and hedgerows will screen a development of this size and representation 519 feels that the conversion of rural land into urban land, will surely lead to maximum destruction and damage to the landscape. Representation 417 suggests the development will completely spoil the landscape that exists now. Representation 476 highlight that landscaping should not be the same as delivered at Park Farm, as this would be detrimental to residents. Representation 519 outlines the important landscape features that can be found in the Chilmington Green development area, although doesn’t state specifically how development would affect them.
486. Representation 167 suggests that many people live at Chilmington Green, because they want to live in a rural environment. Not only would there be a loss in terms of the environment that the current residents enjoy and a loss of wildlife habitat, there could also be a knock effect for tourism. Representation 176 also makes the point about tourism as they consider its surrounding countryside as Ashford's main attraction, with the area of Chilmington Green, with its ancient history and rolling landscape with arable and grazing land interspersed with wooded areas, seen as a prime example.
487. Representation 143 states that once the building at CG is underway, what other green field sites have Ashford Borough Council earmarked for development? Will the Grasmere Road area of Kennington be allowed to remain unscathed. Will the open, green space in the vicinity of the shops at Bockhanger be concreted over?
81 Response
488. In response to representations 277, 460, 423, 514 and 519 the proposed extent of the development is set out spatially, through the AAP’s policies map. This clearly shows the proposed extent of the southern boundary. This position has been based on an extensive evidence base, which includes assessments of landscape and visual impact, as well as various ecological and SuDs strategies. The outcome of this work supports the proposed development area of Chilmington Green (as established in the AAP), ensuring the built footprint, and policy approach in the AAP results in a development which respects a variety of existing features, including Greensands Ridge and those features present in the south western area of the site.
489. In response to representations 426, 519, 417 and 476, the AAP does not suggest that landscaping will completely screen development at Chilmington Green. The purpose of the policy is to ensure that attractive and appropriate transitional areas are delivered to help provide an attractive edge to the development, as required by the adopted Core Strategy. The AAP proposes a variety of policy approaches in differing areas (such as different landscape proposals and design aspirations for development fronting the southern boundary of the development, compared to the edge to Discovery Park) in order to achieve this ambition. It is in this context which the policy approach must be judged.
490. In response to comments 167 and 176, the Council acknowledges that the countryside around Ashford is a resource that is enjoyed by many, including tourists. However this must be balanced with the need for Chilmington Green. In addition, the development will deliver a key destination in the form of Discovery Park, as well as providing attractive routes through the development which will connect the countryside with the urban area, in an attractive and accessible way. In this context, it could be argued that this area will become more of a ‘destination’ for people.
491. In response to comment 143, the matter of future potential development sites is not an issue to be dealt with by the AAP. The formal review of the Core Strategy and subsequent site allocation plans will deal with this issue.
b) Ecology
492. Representations 364, 366, 367, 391 and 393 (from the Kent Wildlife Trust) support; the planting and landscaping that will be provided in the hamlet and southern boundary character area, the green corridors which provide habitat and biodiversity links with Discovery Park and the countryside beyond the development boundary, the provision of SUDs, especially for the use as an environmental mitigation, the work done so far in regards collecting base line evidence and formulating an overall mitigation package.
493. Representation 234 welcomes the ecological survey work and the commitment to avoid building on or directly adjacent to the most ecologically sensitive areas, as proposed in the AAP.
494. Representation 380 supports the deflection of cars from the rural lane and road network, as these corridors are likely to become important migratory routes for wildlife.
82
495. Representation 352 (KWT) have requested additional wording to be added to paragraph 4.2 (i) to ensure that forward planning for ecology is incorporated into the Achieving the Vision and Objectives chapter.
496. Representation 304 suggests there is inconsistency between the final sentence of paragraph 10.83 and policy CG21. The word ‘perpetuity’ needs to be replaced with ‘long-term’, as they have different meanings.
497. Representation 393 (KWT) sets out that table 4 from the ecology strategy should be used instead of table 3 as table 3 only details the area needed to compensate the habitat that is to be lost or degraded whereas, Table 4 sets out what habitats will be enhanced, delivered and managed as part of the ecological mitigation and enhancement strategy.
498. Representation 349 outlines that the aim of the AAP and CG21 is not only to protect existing habitat features, but to also to enhance habitats to achieve net gain for wildlife. Therefore, additional wording should be added to the vision regarding habitat enhancement and achieving net wildlife gain.
499. Representations 238 and 346 highlight that the length of the build-out period, as well as the large number of dwellings being proposed, mean that the long-term monitoring of impacts on Natura 2000 sites will need to be considered. Representation 346 specifically highlights Dungeness SPA, Ramsar Site and SSSI as an example, and that joined-up working with neighbouring authorities on assessing visitor numbers and impacts will need to be undertaken at the Core Strategy Review stage.
500. In addition, representations 498 and 234 also state that because of the lengthy build out period, environmental surveys and monitoring will continually need to be undertaken. This will help to inform the design of each phase and indicate how key species will be catered for throughout the development.
501. Representation 495 (KCC) outlines that Great Crested Newts (GCN) have been identified in three ponds on the Brisley Farm edge. Further consideration needs to be given to the presence of GCN within this area to ensure the development does not result in the GCN population becoming isolated from the surrounding area.
502. Representation 519 provides an extensive range of issues which cover a number of themes, as follows: - Natural England: NE runs a full directory of endangered species, so there is no excuse for not being aware of the various detailed rulings regarding planning around sensitive habitats. This includes gaining an EPS licence - Bats in the Hamlet Character Area: It states that due to the levels of development there won’t be enough foraging areas for them to feed. Artificial lighting, will also encourage the bats to roost longer, further reducing their feeding times and breeding. Artificial lighting will also affect other nocturnal species. - Habitats: The development will result in the destruction of many natural habitats, specifically hedgerows. It is not clear whether hedgerow replacement has been incorporated into the plan, as per ecological mitigation and enhancement strategy. - Human Behaviour: cycling, dog walking, driving will frighten species and distract them from breeding and feeding. - Pollutants: Over time, the background levels of unnatural chemicals, pesticides, automotive engine aerosols will negatively impact on the local ecosystem. - Noise: Higher noise levels will disturb species.
83 - New communication and utility infrastructure: The transmission of electricity and the supply of a mobile phone services will raise levels of ambient, low frequency emissions and electromagnetic radiation, which can damage navigation systems in birds, bats and insects.
503. Representations 346, 367, 380; 382 and 400 highlight the need for safe crossing routes for wildlife, for example, where roads intersect the green corridor. This will prevent high wildlife mortality rates. Representation 380 specifically states that Coleman’s Kitchen wood would require particular attention and protection as it seems to have become surrounded by roads. Representation 9 sets out that the Green 'gaps' (mentioned in paragraphs 4.2(vii) and 4.4) need to be sufficiently wide to allow for hedges/trees to act as wildlife corridors. Small gaps between gardens become incorporated into gardens very quickly and the corridor is lost.
504. Representation 236 comments highlights that the adequacy of the compensatory habitats depicted in Table 3, depends on the quality of habitats created and the appropriateness of their management. It states that these matters need to be secured through specific consents, conditions, funding and management arrangements.
505. Representations 374 states that strategic natural links to connect up the woodlands and hedgerows throughout Discovery Park and the Southern mitigation land should be secured. Representation 240 states that it is important that processes are put in place to ensure that: - the AAP proposals are reflected in the specification of each phase of development (notably the character and function of necessary new habitats) and in subsequent planning consents, conditions and agreements, - environmental benefits are of appropriate quality and any necessary funding, monitoring and management are in place - design parameters for how the SUDS features should be designed and delivered for environmental mitigation and enhancement purposes (representation 391 establishes a range of relevant parameters)
506. Representations 346, 377 and 393 (KWT) state that involvement of volunteers and community trusts managing ecological habitats will need training. Representation 393 adds that specialist ecological advice will need to be supplied to farms and the Community Development Trust, if this option is to be pursued.
507. Representation 446 asks what assessments will be undertaken to assess the likely increase in cat population and Representation 519 states that the new households here will introduce a number of new predators including cats and dogs into the countryside, to the detriment of wildlife.
508. Representation 143 sets out that school children, including primary school children, are being taught about endangered species and how to care for the environment, but you, the people who should be safeguarding the health of the planet for them, are setting a very bad example.
509. Representation 543 comment highlights that for the last 5 years a resident has been rescuing sick and injured hedgehogs on behalf of a local sanctuary. They have concerns that due to the new housing being built, there will no longer be anywhere to release the hedgehogs back into the countryside when their health or injuries have improved, if development at Chilmington Green goes ahead
84 Response
510. Supportive comments noted.
511. The Council disagrees with representation 352. Paragraph 4.2 of the AAP sets out ecology as an issue which has influenced and shaped the built footprint, with particular reference to the southern boundary. In addition, the importance of ecological networks is established within Policy CG1 ‘Development Principles’ (e) and (f).
512. In response to representation 304, the Council accepts this point and propose a minor amendment, see proposed minor amendment schedule.
513. With regards representation 393, the Council agree that enhancement is an important part of any wider ecological strategy for Chilmington Green. However, this position is already reflected in Para 10.77 in the AAP which states that ‘these areas are sufficient in size and scale to suitably mitigate and enhance a number…
514. In addition, what constitutes enhancement is often difficult to quantify (particularly at this early stage in the process) as it relates to qualitative and quantitative factors. The exact details of what measures will be needed will be determined through the detailed planning application stage which will need to be supported by up to date ecological assessments and surveys. In light of the above, it is not deemed appropriate to introduce table 4 of the Ecological Strategy, as has been suggested.
515. With regard representation 349, the Council disagree that additional words are necessary. Policy CG21 clearly links to Policy CS11 of the Core Strategy which refers to enhancement of ecological and wildlife areas, wherever possible. In addition, Policy CG1 ‘development principles’ makes it clear that ecological and wildlife are importance factors when planning the Chilmington Green development.
516. In relation to the points about the Natura 2000 sites (representations 238 and 346) the impact of these have already been assessed through the Appropriate Assessment which supports the Area Action Plan. Potential impact was also assessed as part of the Appropriate Assessment that supported the Core Strategy (which proposed more development at Chilmington Green, as well as an expanded Town Centre area and second growth arm at Cheeseman’s Green). It is accepted however that any future plans for the Borough (which manifest themselves through a formal review of the Core Strategy) will need to also be assessed, in relation to impact on Natura 2000 sites.
517. In response to comments 498 and 234 The Council agrees that additional criteria could be added to paragraph 10.83 and also policy CG21, to ensure that the Ecological Mitigation and Enhancement Strategy required by the developers includes a section on future monitoring, as this will make the approach more robust. These changes should also be reflected in Chapter 12 ‘Monitoring and Review’ of the AAP. Please refer to the schedule of proposed minor amendments.
518. In response to representation 519, a number of these points relate to the principle of development at Chilmington Green. On this the Council accepts that development here, as with most developments will have an impact in terms of disturbance, noise and increased human activity. Please refer to the Council response to theme 1 (response to objection point 4).
519. On the more detailed points raised, the AAP policy approach (including the extent of development, the size of mitigation and enhancement land and the approach advocated in Policy CG21) is supported by an extensive range of evidence that has 85 included various ecological surveys, taking into account both protected and not protected species and habitats. In addition, the policy approach requires additional and up to date surveys to be conducted to support the detailed planning of any areas and that any area required for mitigation is suitably established before development can take place. Combined the policy approach in the AAP is considered suitably robust in terms of ecological considerations.
520. With regards representation 495, this comment is noted. However the detailed planning of these areas will come forward as part of the planning application process and this is where any further consideration will be needed. Any approach advocated will need to be supported by up to date evidence. In terms of the AAP, the ponds are proposed to remain in situ (as reflected in the various strategic diagrams) and they will also be located next to Discovery Park and proposed green corridors. In addition, some of these ponds are already surrounded by a built form and yet the newts appear to have remained in situ. Based on these factors, it is unclear why the approach in the AAP is unsound. Therefore no amendments are proposed at this stage.
521. In response to representations 236, 240, 346, 367, 374, 380, 382, 400 and 9, these comments are noted. The issues raised by these representations will be explored through the detailed planning application process as they issues which are not necessary to deal within the AAP, and could result in a more inflexible policy approach.
522. With regards to representation 374, the policy approach advocated in the AAP will ensure that important and strategic natural links are incorporated within any agreed ecological strategy that is required to support the planning application.
523. The Council notes representation 446. However, future cat population levels are difficult to ascertain with any certainty. Nevertheless, Para 10.79 does touch on this issue, and suggests that the area set aside for sky lark breeding, should be far enough removed (or can include specific measures) to ensure this issue is not significant to cause undue harm.
524. Representations 143, 346, 377, 393, 543 are noted.
86
THEME 13: MONITORING, PHASING, DELIVERY, DESIGN, AND INFRASTRUCTURE DELIVERY PLAN (IDP)
Representations were received from the following consultees:
23 – Peter Williamson 258 – Margaret Cook 460 – CPRE Ashford 88, 93, 94 – Daniel 272 – Southern Water 461, 482– Great Chart Hammett 278 –Bethersden Parish Parish Council 145 – Brian Parritt CBE Council 476 – Kingsnorth Parish 176– Ashford 305, 307– Chilmington Council Independent Party Green Developers 489 – Save Great Chart Executive 394, 395 – Kent Wildlife Action Group 237, 238, 239, 240 – Trust 490 – Ian Wolverson Natural England 424, 437, 447, 450 – J R 257 – Central Ashford Carpenter Community Forum 442 – South East Water
a) Phasing and Delivery
525. Representation 394 supports the phasing approach taken in the AAP.
526. Representation 442 supports Chapter 11 in relation to water provision detailed within the WRMP.
527. Representation 278 lists a number of objections and suggests proposed changes to the phasing plan of the development, as they do not believe that existing settlements have been fully considered. A map was included with the representation to show this. These suggestions include Phases 1 and 2 being re-evaluated in terms of development mix, the removal of Phase 3 completely as it is an unjustified incursion into the countryside and redefining Phase 4 once the outcomes of Phase 1 & 2 evaluation has taken place. They believe that this would create a mix that allows the development to be completely self-sufficient with improved local employment.
528. Representation 23 asks specific questions about phasing details relating to an existing property in Chilmington area.
529. Representations 258, 424 and 461 raise concerns over the delivery of the development in the current economic conditions and object to the developers being able to reconsider timings and provision of the infrastructure. They feel that both these issues could lead to parts of the development remaining unfinished. Representation 424 feels that there is no guarantee that the site will be finished and it will be a building site for 25 years which will put off prospective residents and businesses. All of these representations fear that the development could be left without sufficient infrastructure, which would be unacceptable for the existing residents. Representation 424 states that there are no concrete plans for infrastructure beyond the first phase.
530. Representation 240 requests that further details are included in Policy CG22 relating to the character and function of necessary new habitats in each phase and in subsequent planning consents etc; that environmental benefits are of appropriate quality and monitoring and management are in place; and advanced landscape and habitat protection and formation takes place when required.
87 531. Representation 305 requests a change to the first paragraph of Policy CG22 wording relating to the demonstration of availability of the relevant Infrastructure if development proceeds faster than the IDP. They feel that the extra condition of ‘or can be made available’ should be included here.
Response
532. Representation 278: the Core Strategy has set the broad targets for the amount of development at Chilmington Green which has now been refined in the AAP. Phases 1 and 2 as marked on the attachment to this representation include the district centre, where it is envisaged that the majority of jobs at Chilmington Green will be provided. The retail evidence carried out shows that this is the correct mix of uses, and will not impact on Ashford Town Centre. The provision of additional employment or retail development at the expense of residential is not likely to be deliverable and would be likely to result in additional peak hour travel movements to and from the development. In addition, the development will create strong transport links with the town centre, and the International station (see para 9.5 of AAP) which will enable new residents of Chilmington Green to access the job opportunities arising elsewhere in the town.
533. Phase 3 includes a large proportion of the ecological enhancement and mitigation land to the south and without this the overall scheme would not be deliverable or sustainable.
534. With regards to redefining phase 4, this area contains significant areas of the strategic park, the sports centre, ecological mitigation and a local centre. If the housing is removed, or the mix of uses changed, without balance within the previous phases, it would make this phase unsustainable, and therefore not deliverable.
535. Representation 23: The area in question will be developed in Phase 3, The Southern Phase. Until a planning application is submitted for this phase, the exact location and type and design of properties is unknown. However, the houses opposite this property will be in the Hamlet character area which will need to meet the requirements set out in the Chilmington Green Hamlet Character Area – Policy CG5. A primary school is also proposed in close proximity to this area.
536. Representation 258, 461 and 424: The AAP provides a clear indication of the on-going and cumulative infrastructure requirements needed to support the development over its entire construction period and it is equally clear that this infrastructure will need to be provided in advance or alongside development, as necessary. What no Plan can guarantee is that the development will come forward in whole hence the need to ensure that individual phases are sustainable in terms of infrastructure in their own right. The need to have some flexibility in respect of some forms of infrastructure provision is made clear in the NPPF and current Government guidance.
537. Representation 240 – Policy CG11 already sets out the requirement for a detailed ecological enhancement and mitigation strategy to be agreed with the council. This will include measures for implementation, management, phasing and maintenance in the long term. Qualitative monitoring is important and should form part of the long term maintenance and management arrangements. No change to policy CG22 is necessary.
538. Representation 305 – The policy position in the AAP is purposefully worded to ensure a relatively structured development is delivered, reducing the need for new infrastructure in isolated locations to serve the development. A reference to ‘or can be
88 made available’ in the policy would be too open-ended and would encourage development to come forward in advance of its necessary supporting infrastructure.
b) Construction Strategy
539. Representation 88, 93,145, 176, 257 and 437 all raise concerns about the construction strategy, in particular the construction traffic. Representation 437 references paragraphs 8.15, 11.41 and 11.42 of the AAP which details the steering group for the construction management issues and enquires who these local people will be that comprise this steering group, and asks if existing residents would be required to play a role in this, even if they do not support the plans.
540. Representation 88, 93 request that the AAP includes explicit mention of roads that will be prohibited to construction traffic, namely Singleton Hill and other local roads. Representation 145 suggests that construction should enter the site via Bartlett Farm.
541. Representation 237 requests that consideration be given to water quality and on-site habitats and species during the construction phases and thereafter.
Response
542. Representation 437: It would be beneficial for new and existing residents to be involved in the construction management strategy as they would be able to put forward any ideas using their local knowledge, and influence the outcomes. However, residents would only be involved on a volunteer basis and there would be no requirement for them to participate.
543. Representation 88, 93: Para. 11.43 of the AAP sets out the issues that will need to be addressed in any agreed construction strategy for the development. Routes for construction traffic will be specified at the time when planning permission is granted and will be covered by planning conditions or s106 agreements. This is the only effective way to deal with routing construction traffic as it is perfectly legal for traffic to use whichever route is open to it. This point is already covered in general by bullet 2 at Para 11.43, of the AAP
544. Representation 237: the Council agrees with this point and proposes an amendment to the bullet list at 11.43, see schedule of proposed minor amendments.
c) Detailed Design and Quality Control comments
545. Representation 94 enquires as to whether ABC has sufficient resources to oversee the development and enforcement of design, quality and national guidelines. It also asks how ABC has learnt from previous developments (i.e. Singleton) to ensure the interests of new and existing residents are high considerations when progressing the Chilmington development.
546. Representations 489 and 490 comments on the poor quality of design, materials and build standards on other new development sites, the possibility of reviewing the building materials used to make the development more sustainable, and architectural design making building difficult to maintain. They would like these issues covered within CG19 or CG22. 482 comments that no references have been made regarding the quality of the build, which they feel should be integral to the AAP, with low cost maintenance built in.
89 547. Representation 447 questions how the quality aspirations established in the AAP and referred to in CG22 can be delivered and maintained over a 25 year period, and also asks if the Council will accept lower standards in the future, if no developer wishes to build to the ones set in this AAP.
Response
548. Representation 94: ABC has dedicated urban design professionals as part of the Planning & Development Unit. Liaison with other officers, including building control officers, will form a key aspect of handling the proposals and the monitoring of the development as it progresses. It will also be important maintain a constant channel of communication with local residents as development occurs to enable any emerging issues to be addressed.
549. The AAP includes a number of strategies to ensure that the local residents are included within the planning, design and construction phases of the development. These include creation of a site-wide design code, phasing masterplans, and a steering group comprising of local representatives, politicians, ABC officers and the developers that will oversee and monitor the practical construction issues. This will ensure local involvement and make sure the impact on the local people during the construction period is minimised.
550. Representations 482, 489 and 490: design guidance is provided within each character area section, which also states that a detailed design strategy will be prepared for each area. Design codes are detailed in chapter 11 (11.39) and this will include public consultation. Low cost maintenance is not mentioned at this stage as it would be too detailed. This is something that would be dealt with through the design code planning and strategies mentioned above.
551. Representation 447 - Once the AAP is adopted, all relevant planning applications will need to meet the standards and policies set within it. The only way these could be reduced is with a formal review of the AAP, or new Supplementary Guidance that supersedes those standards. In either of these cases the document would undergo formal consultation procedures and evidence gathering. If economic conditions decline and no developer wishes to build then the development will not proceed, or will be built over a longer time period than indicated here. The phasing plans make this acceptable as each phase needs to be sustainable in its own right, and therefore if only 2 phases are built, there will be no loss of infrastructure for those existing residents.
d) Monitoring and Review
552. Representation 460 and 476 suggest that 5 yearly reviews to monitor the AAP would help delivery by ensuring good public engagement with existing and new residents.
553. Representation 238 recommends that due to the long development period the potential impact of pending phases on the N2K sites may need to be monitored and any impacts recognised would need to be addressed. Representation 239 suggests that the indicators should include monitoring of the delivery of green infrastructure. Representation 395 feels that the indicator in the monitoring table for public open space is inconsistent with tables 3 and 4 in CG22 and the ecology strategy.
554. 450 questions what sanctions are available if the monitoring process highlights that certain targets have not been met.
90 Response 555. In response to representations 460 and 476 the Council agrees that having a review period of between 5 to 7 years is appropriate and will aid the flexibility of the Plan. Please refer to the schedule of minor amendments. Doing so would mean this approach is in line with the indicative phasing timeframe indicated in the IDP. Each phase is expected to take between 5 and 7 years. The first phase is expected to take 6 years and there is likely to be some time between the AAP being adopted and work commencing on site. A review of the plan between 5 to 7 years will be in line with the end of phase 1 development, and therefore can be fully assessed. The Annual Monitoring report will assess every indicator annually and will highlight any concerns in relation to this development.
556. In relation to representation 238, the Council agrees with this comment and has inserted a new paragraph to explain that the ecology and enhancement strategy will include monitoring requirements that will be carried out by the developers in consultation with Kent Wildlife Trust. Please refer to the schedule of proposed amendments.
557. Representation 239: Implementation and management of green infrastructure can be made subject to planning conditions or agreements in which case monitoring is carried out as part of the process of implementing conditions/agreements. The monitoring table is in chapter 12 and includes public open space some of which will contribute significantly to the amount of Green Infrastructure.
558. In response to representation 395 the council disagrees with this comment. The figures in the monitoring and review section are in accordance with the recreational public open space to be provided in line with policy CG8 and are not designed to include any of the areas identified for ecological mitigation (see response to 238 above which indicates an amendment to monitor ecological enhancement strategy separately).
559. With regards to representation 450: Chapter 12 outlines that the plan’s targets will be monitored annually and interventions can take place if the monitoring process highlights any problems. These interventions are also mentioned in Chapter 11 - quality control, but are not listed. Until a problem arises it will be difficult to predict what the solution will be, but as Chapter 11 details, there are a number of ways the Council is planning to limit any problems occurring during the plan process.
e) Infrastructure Delivery Plan – Appendix 3
560. Representation 272 requests an amendment to all phase sections of Appendix 3 to include provision of foul drainage in accordance with the Utilities Appraisal summary and water cycle study. Representation 307 requests an addition to the wording in Quantum/Trigger point column of Phase 1 table, section c) 1) to ‘Northern access prior to commencement of development on the rest of the site.’
Response
561. With regards to representation 272 the council agrees and proposes to add the suggested amendment to each part of appendix 3 that will insert sewerage connection criteria as recommended by Southern Water, see the schedule of proposed minor amendments. This would link to Policy CG22 and thus provide policy support for the delivery of on and off site sewerage.In response to representation 307, the Council agrees and proposes a form of wording to clarify this position, see the schedule of proposed minor amendments. 91 THEME 14 – BOUNDARY OF THE AAP
Representations were received from the following consultees:
1, 2, 268 – Mason 277 – Linda Cleaves 477 – Kingsnorth Parish Brannan Design (c/o D Jarman, Hobbs Council Partnership Parker) 485 – Janet & Sara 151– KCC (Wendy 278 – Bethersden Furnival Rogers) Parish Council 493 – KCC (Tim Martin) 211 – Catherine 313 – John Holland 514 – Linda Cleaves Stevens 317, 321 – Hallam Land 523 – Nicholas Chaplen Management and Eleanor Jeffrey- 462 – CPRE Chaplen
a) Boundary of Discovery Park
562. Representation 317 (Hallam Land Management) requests reconsideration of the eastern boundary of Discovery Park and questions why it stops at Long Length whilst representation 321 believes that Discovery Park should include a residential element, the deletion of which is a consequence of the tight eastern boundary of the park along Long Length. This would not provide for the long term vision set out for Discovery Park as established through the GADF process. They specifically dispute Para 2.13 (v) which points to land ownership as influencing the development footprint when owners of Court Lodge have cooperated throughout the process.
Response
563. In response to representation 317 the objector is the promoter of land to the east of Long Length known as Court Lodge Farm. This area was put forward for primarily residential development in the Core Strategy but was unsuccessful. Policy CS18a of the Core Strategy states that the size and detailed boundaries of the new strategic open spaces for Ashford, which include Discovery Park, will be determined in the relevant site DPDs in the context of local assessments of the existing and future demand for those facilities. Therefore, it is the role of this AAP and not the GADF or Core Strategy that should set the boundary of Discovery Park. The evidence base makes clear that the open space and sporting needs generated by the Chilmington development can be comfortably accommodated within the area of land identified for the Park in the AAP which is consistent with its wider strategic role for the town. As such, there is no quantitative need to extend the boundary of the park east of Long Length at this point. Long Length forms a ready-made and appropriate boundary but it need not form a hard or permanent edge. A decision on future expansion of the Park should form part of the Core Strategy review alongside any consideration of future development in the Court Lodge area.
b) Area proposed for Park and Ride
564. Representation 485 promotes Blue Barn Farm, adjacent to the A28, as an alternative location for the Park & Ride facility or associated development such as a petrol filling station.
Response
565. In response to representation 485 an area of land to the west of the A28 has been safeguarded for future use as a Park and Ride site should the future need for such 566. a facility be justified (identified on Strategic Diagram 1 of the AAP). This area of land is within the developer consortium’s control. The AAP site is preferable as it is located at 92 one of the new intersections with the A28 and the main access into the Chilmington development. The long term need for a Park & Ride on the A28 to the south-west of Ashford will be considered as part of the Core Strategy review.
c) Extension to Brisley Farm
567. Representation 211 objected to housing built up against where she lived and felt that the extension to Brisley Farm should instead be an extension to Discovery Park. 568. Representations 462 and 477 both objected to the extension to Brisley Farm on the basis that a previous application for housing had been dismissed on appeal, the area had previously been described as open space and proposed as woodland to provide a transition to the countryside and that it was no longer necessary as housing numbers had been reduced. Representation 477 additionally wanted to see community aspects provided that were not currently available to residents of Brisley Farm and Washford Farm estates.
569. Representation 313 refers to two main concerns expressed to the author whilst they were the Borough Councillor for this area, namely ( 1 ) the suggested link road adjoining these estates with the proposed new development which in turn could be a ‘’rat-run’’ through to Kingsnorth village and the town, this concern was mainly from the residents of Brisley Farm and, (2) New development being uncomfortably close to the southern edge of the residential properties, currently excluded by a condition made in 2005 by an Inspector at a public inquiry. These two large estates were developed without any amenities such as shops, leisure or allotments and it is questioned where these facilities will be located.
Response
570. The current Brisley Farm housing estate presents a visually harsh and unstructured urban edge to the countryside to the south and the proposed extension to the estate represents an opportunity to improve the urban edge in this location. This is important as it will be an edge to Discovery Park and the facilities that will located there with much greater public footfall than is currently the case.
571. In viability terms, it is also understood that a limited scale of development here can be achieved without significant new service and utility provision which will enable the developers the funding to deliver new infrastructure, services and connections elsewhere in phase 1. It will also be the catalyst for providing an early pedestrian and cycleway connection from Brisley Farm to the District Centre at Chilmington Green where new services and facilities will be located. In addition, the progressive emergence of new community and sporting facilities at Discovery Park will greatly improve the access of existing residents at Brisley Farm and surrounding estates to these facilities as well as a major new area of public open space.
572. The previous appeal decision is acknowledged but the context for that decision was significantly different as there were no firm proposals for the Chilmington Green urban extension identified at that time. The Core Strategy Growth Area Diagram (Fig. 2) also suggests that development south of the existing Brisley Farm development should form part of the urban extension, indeed, to a much greater scale than proposed in the AAP.
93 d) Heritage assets and the development
573. Representations 151 and 493 (Kent County Council) state that the heritage of CG is of sufficient importance to merit a specific policy and guidance in the AAP. This policy should promote sustainable development, encourage the beneficial reuse of heritage assets, seek appropriate conservation, enhance heritage assets and encourage development to take account of and reflect local character and distinctiveness.
574. They suggest that some of the local heritage at Chilmington Green is of national importance and there is potential for as yet unknown heritage assets at the site. Archaeological fieldwork within the Chilmington Green site has highlighted some potentially significant archaeological sites and the process of gaining a reasonable understanding of the archaeology through fieldwork is on-going.
575. The representations state that AAP should reflect guidance set out in the NPPF (para 17 and 126) by reflecting the pursuit of sustainable development and by considering that the historic environment should be a material consideration in achieving that goal.
576. Representation 523 states that the proposed development would destroy the historical richness of the area (i.e. Iron Age, Roman, Mediaeval, Bronze Age etc) and destroy our heritage. For example this development extends over the Greensand Way which is an historic footpath. Ashford should be celebrated and promoted for its rich history (i.e. archaeological and industrial).
Response
577. It is agreed that heritage matters are important but does not believe a specific policy on heritage is needed in the AAP. The matters raised by the objector are covered either elsewhere in the AAP, Core Strategy or in the NPPF. Policy CG1 (f) already requires development to positively respond to distinctive landscape character and assets of the site, which could include heritage assets. In addition, the proposed policy approach in the AAP takes the known heritage and landscape assets of the site into account. For example, it advocates a layout which would amalgamate the former Chilmington Green ‘runway’ into the development, promotes sensitive treatment around Coleman’s Kitchen Wood, and also promotes a sensitive policy approach for development around the hamlet, through Policy CG5, where a number of listed buildings are present. The route of the Greensand Way is proposed to be primarily retained on its existing alignment (see Strategic Diagram 2 c).
578. This position is clearly reflected under Para 4.2 (ii) and (iii) of the AAP. Point (iii) also makes in clear that developers will need to submit appropriate desk-based assessments and where necessary undertake appropriate field evaluation works to support any detailed planning applications.
579. In addition, Policy CS1 (B) of the Council’s adopted Core Strategy would also apply to future proposals within the Chilmington Green AAP area. This policy stresses the importance of ensuring the conservation and enhancement of the historic environment and built heritage.
580. Combined, it is considered that the approach in the AAP is not inconsistent with the NPPF approach, as has been suggested. In addition, no evidence has been presented which would suggest that an alternative approach is needed, or where any ‘nationally significant’ finds are located. In light of this, no amendments to the AAP are suggested.
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e) The impact on Bethersden
581. Representation 1 states that the “significant challenge” has not been properly addressed and the effect on neighbouring communities has not been seriously considered. Bethersden Parish Council has not previously been given the chance to formally comment on these proposals. There should be formal proposals within the Action Plan policies to protect the welfare of existing communities and mitigate against adverse impact.
582. Representation 278 suggests that, as part of the reviews, fuller recognition should be given to local opinion and a greater opportunity provided for early consultation with local Parish Councils.
583. Representation 2 wants to add the following additional requirement (h) to policy CG1. “To positively consider the overall impact on the neighbouring Parish of Bethersden and introduce measures to minimise the visual impact to the existing rural countryside, and to mitigate against local housing availability, job opportunity and general economic development in the Parish over the full 25 years of the Action Plan’.
584. Representations 268 and 278 also set out the following points: - The proposal for 5,750 homes and only 1,000 jobs will create an unacceptable imbalance which will impact on the existing community in Bethersden to the detriment of local employment opportunity. - No account taken of impact on existing villages e.g. impact on water, schools, road traffic. Nor has the effect on existing rural schools, shops and services been analysed. - If any development is to take place it should be fully considered in relation to existing settlements and substantially reduced in scale and composition so it is essentially self sufficient with improved local employment. - We would propose that phases 1 and 2 be re-evaluated in terms of development mix. With regard to phase 3 we would suggest this is not required and is an unjustified incursion into the countryside. With regard to phase 4 this should be fully redefined with reference to the lessons learnt from phases 1 and 2.
Response
585. As referred to elsewhere, it is the Core Strategy that set out the potential development quantums for growth at Chilmington Green and the Parish Council have been and were, fully involved in the formal processes for that document. There is no evidence put forward of potential specific impacts on Bethersden village or the parish (the village lies some 2 – 3 miles to the south west of the AAP area and would not be visible from the village at all). It is hard to understand why the provision of over 1,000 jobs at the proposed development at Chilmington Green would have a detrimental effect on residents of Bethersden seeking employment.
586. The impacts on roads, local services and water have been assessed as part of the AAP preparation process and there is no evidence that suggests that there will be any adverse impacts on Bethersden.
587. The redefinement of the phases proposed would result in a development fundamentally different to that identified in the Core Strategy and would not therefore be sound. 95
f) The extent of the southern boundary
588. Representations 277 and 514 both set out concerns about the impact on Possingham Farmhouse (from the landowner and agent acting on behalf of the landowner). They make a number of observations relevant to this argument.
589. They are concerned that the AAP does not have regard to the landscape, especially to the southwest. The master plan shows that the southern boundary is very exposed and has a much smaller landscaped mitigation zone compared to that bordering Tally Ho Road and Shadoxhurst. Representation 277 highlights view 25 and figure WT34 and WT35 of the landscape strategy to reinforce these points.
590. In addition, they state that the development comes too close to the woodland in the southwestern corner of the master plan and this could have an impact on ecology. In this context they question why no buffer zone is shown to ascertain where any needed mitigation or enhancement areas might be required.
591. They also suggest that - whilst other areas along the southern boundary are shown on Strategic Diagram 3 as being less than 10 dph - the south western area is not. This doesn’t appear to be justified, and is also not consistent with Policy CG6.
Response
592. Possingham Farmhouse lies just outside the AAP boundary but approximately 450 metres from the proposed edge of the built footprint on the southern boundary of the development. There would be an open area that is identified for ecological mitigation (i.e. without new buildings) between the farmhouse and the nearest new property. The detailed ecological mitigation and enhancement measures needed to support the development in this area will be determined through the detailed planning application stage
593. In context, figure WT35 of the Landscape Strategy shows the broad location of a number of landscape characteristics which - in a strategic context - help inform the Visual Impact Assessment, which primarily explores the impact of the development on the wider area. It is not the intention of this assessment to provide a very detailed assessment of localised landscape characteristics which should be applied literally, as the objector appears to be doing.
594. The primary intention of Policy CG6 ‘Southern Fringe Character Area’ is to set out a number of criteria to which development should adhere to in order to establish and attractive and clear physical and natural limit to the southern extent of the development. In this context it suggests low density development.
595. In addition, the residential densities on Strategic Diagram 3 outside of the main Character Areas tens to indicate an average density – in this south-western area it suggests an average of 21dph but development on the extreme edge of the development may be less dense, as these are likely to be premium properties.
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THEME 15: MISCELLANEOUS COMMENTS
Representations were received from the following consultees:
7 – Jonathan Barton 186 – Frederick 423,430,431,436 –JR 10 – Joy Thornton Westwood Carpenter 20 – David Lay 208 – Ashford Green 454 – Kenardington 23 – Peter Williamson Party Parish Council 34 – John Emms 225 – Lillian Brookes 454 – Kenardington 53 – P G Churcher 226 – Shirley Ambrose Parish Council (Mrs Emily 54 – J A Churcher 228 – Independence & Neighbour) 56 - Raymond Woodcock Access Matters 457, 459– Wittersham 59 - Roger Coker (Francoise Montford) Parish Council 65 – Michael Dowsey 246 – Joanne Brand 461, 473 – Great Chart 68 – Nanibabu Magar 248 – Kath Carr with Singleton Parish 70 – Lionel Goddard 249 – Gordon Roberts Council (Linda Hedley) 71, 80, 82, 92 Daniel 253 – Yolanda Barker 466 – CPRE Hammett 258 – Margaret Cook 481– Kingsnorth Parish 97 – Dunster 275 – Cllr Aline Hicks Council 104 – UKIP Ashford 282, 306 – CG 484 – Alice Frohnsdorff (Norman Taylor) Developers Group 486 – Howard and Sandra 105 – Sarah Keaveney 315 – Zoe Snazelle Franks 142 – Sarah Stanfield 329 – Ian Procter 494 – KCC (Tim Martin) 144 – Donald Fagg 331– Carol Procter 502 – Save Great Chart 146 – Mr TR Lacey 332 –Ross Procter Action Group (ian 150 – Sally Gathern 335 – Alexandra Procter Wolverson) 153 – Cllr Andrew 337 – JR and MR Morris 522 – Cllr Winston Mortimer 372, 398 – Kent Wildlife Michael 176 – Ashford Trust 523 – Nicholas Chaplen Independent Party 385 – Brenda Hedley and Eleanor Jeffrey- Executive 414 – Sharon Kelly Chaplen 178 – Fiona Birrell 417- JP Palmer 538, 540, 541, 542 – Kent 183 – D A Craib Police
a) Capacity at William Harvey Hospital
596. Representations 7, 20, 23, 34, 53, 54, 65, 97, 144, 146, 208, 225, 226, 228, 249, 315, 337, 414, 473, 484, 486, 522 all raise concerns about the current and future capacity of William Harvey Hospital (WHH), stating that there are no plans for the hospital mentioned within the in AAP, and that the hospital is currently at capacity and has overstretched resources. The additional strain placed on the hospital by Chilmington Green will place undue strain on this facility. Representation 146 suggests that the Council’s own evidence proves there is an issue of capacity at the hospital and cites the Sustainability Appraisal.
Response
597. The principle of significant development at Chilmington Green has been debated for a number of years since the production of GADF in 2004. Throughout the evolution of this work, the relevant service providers (including the Primary Care Trust and NHS Kent and Medway) were aware and involved in the emerging plans.
598. At the time the Core Strategy was being produced (2005 preferred options, 2006 submission), the Primary Care Trust were consulted on the emerging plans for the town, including Chilmington Green. At the time these emerging plans suggested over 5,750 homes at Chilmington Green, alongside significant growth in the Town Centre 97 and a second growth area at Cheeseman’s Green. They raised no concern over the capacity of the hospital.
599. In addition, the Primary Care Trust has also been consulted on the Chilmington Green Publication Version of the AAP. Although they have made representations on the AAP, they have not made any comments about the hospital.
600. In response to representation 146 it is correct that the council has made a statement in the SA: Stage B Assessment of Reasonable Alternatives which states ‘The increased population will also put increasing demands on existing strategic services off site such as the William Harvey Hospital’. (Table 18: Secondary or indirect effects column). This is an entirely factual statement. It is self evident that any increase in population, (whether this is at Chilmington Green or elsewhere in the Borough) will increase demand for services. However, this statement does not say that this demand cannot be met, or there are any issues over capacity at the hospital.
b) Incentives / Blight / Infrastructure / funding comments
601. Representations 23, 56: How much money will ABC get for each house approved? Could it be the financial benefits from the Governments Housing Bonus scheme? Or could it be section 106 possibilities?
602. Representation 23, asks what compensation will the local residents receive for all of the upheaval and stress caused by this huge development over 20 years?
603. Representation 146: It is not precisely clear how the costs of the infrastructure would be shared between the participants. 431 questions who is going to provide the financial contributions for off-site infrastructure?
604. Representations 329, 331, 332, 335 have concerns that “off-site” investment is likely to be de-prioritised as a cost control measure. Off-site investment in infrastructure and local services, especially in the initial stages, is probably more important than on-site to ensure that the lives of people in surrounding areas are not blighted by the on-going development. It is recognised that this would add to the front loaded costs.
605. We are fearful that the cost to the public of any frontloading for this scheme in the immediate future could have a serious long term detrimental impact on Ashford and the surrounding areas.
606. Representations: 176, 457, 258, 461 There is no guarantee that sufficient funds will be available. For example, is there money available for highways improvements. The Smartlink bus service has already been scrapped.
607. Representations 258, 461 It is unsound to allow developers to reconsider timing of infrastructure, cheaper ways to deliver infrastructure or to reduce policy requirements. This could result in key elements of the scheme, remaining incomplete for extended periods of time. This is unacceptable for residents of Phase 1 and subsequent phases, nor for residents of surrounding areas impacted by construction mess, noise, traffic etc.
608. Representation 436 Proposals for Discovery Park seem highly speculative. Seems developers must pay for part of it but remain it remains to be seen who pays for the rest. What guarantee is there that ABC will ever have the money? Development is being sold on the basis of facilities like Discovery Park when there no guarantee this will ever be delivered. 98
609. Representation: 523 The Community Infrastructure Levy needs to be set at a sensible level so as to provide real benefit for the Community and reflect the resultant destruction of the green belt. In contrast this levy could be relaxed in the urban environment thus providing an incentive for developers to build on brown field sites, such as Charter House, Park Mall, Railway Works, Gas Works, Elwick Road, Victoria Road etc and thereby help regenerate the rapidly decaying and unattractive town centre. This would benefit all the residents of Ashford as a whole and hopefully encourage business, commerce and visitors to come to the town.
610. Representation 178: As demographics change and financial resources diminish, the development will be left half undone and become a blight on the landscape.
611. Representation 417: I would suggest the attraction of extra business rates revenue for ABC from the said development is at the forefront, as they are not receiving as much rate revenue from the empty units in the town centre.
Response
612. In response to representation 23 and 56, the new homes bonus scheme which has been recently introduced is likely to apply to development at Chilmington Green. Section 106 agreements will also be used to deliver various infrastructure, required to support the development. However, to suggest these are the reasons why development at Chilmington Green is going ahead, is disingenuous. Chilmington Green has been a proposal for a long before the new homes bonus was introduced. In addition, the 106 money will go towards providing infrastructure which meets the needs of the development, for the benefit of the community. In addition, there will be no compensation offered to residents in relation to blight as the NPPF does not include directions for compensation packages and blight (or perceived blight) is not a material consideration in planning terms.
613. With regard to representations 146 and 431, infrastructure will need to be delivered to support the development, as the AAP clearly stipulates in a variety of locations. Without such provision (for example highways improvements) the development will not be able to proceed. Most of the needed provision will be funded by the development itself, as part of S106 obligations or Section 278 (Highways Act) Agreements and be agreed between the relevant authorities.
614. The Council notes representations 329, 331, 332, 335. The development will need to provide both on site and off-site investment in infrastructure to support the development. For example, sufficient funds will be needed to deliver off-site improvements to the highway network and these will need to be in place to release enough capacity so that the development can progress at various stages (176, 457, 258, 461). There is no evidence to suggest, at this stage, that any of this infrastructure will not be forthcoming or de-prioritized, as has been suggested.
615. In response to representations 258 and 461 the AAP makes it very clear that the relevant social and physical infrastructure needed to support the development will be delivered at the right time, so that each phase of the development can be considered sustainable in its own right. However, the AAP also makes it clear that there is an element of flexibility in the approach, to take account of market forces. This – in itself - does not equate to non-delivery, as has been suggested. In the current market conditions, and given the length of the development, this flexible approach is entirely justified and ensures that the development will not be undermined by lack of provision.
99 616. With regards representation 436, the possible funding and future management arrangements for Discovery Park are set out under Para 7.20 – 7.24. This clearly shows that a flexible approach will need to be taken, at this stage. A large proportion of the Park will be delivered by the development, in order to meet their recreational needs. However, there will remain an area which will need to be delivered by another party. This could be the Council, or a trust type arrangement (see Chapter 8 of the AAP). In addition, the Council’s recently published Public Green Spaces and Water Environment SPD requires development around the town to contribute to the ongoing delivery of ‘strategic parks’ – of which Discovery Park is one.
617. The Council notes representation 523. The Councils CIL schedule will be brought forward alongside the first review of the Core Strategy and is not covered by the AAP.
618. Representations 178 and 417 are both noted.
c) Design
619. 178 Your statement “The Council is committed to ensuring Chilmington Green is a development of real quality…” is simply spin. The roads will become one huge car park and the landscape left to become overgrown and unsightly as there is no money in the budget for maintenance.
620. 80, 454 There have been recent experiences of poor development quality in Ashford. This goes further with a seeming emphasis on style over substance: decorative features made from poor quality materials that require constant (and expensive) upkeep. High housing density leads to taller houses which are also expensive and difficult to maintain. These development standards discourage people from looking after their houses and maintaining the appearance of their neighbourhood.
621. 178, 523 Chartfields is an example of a badly designed estate. Chilmington Green will become the same, but on a larger scale
622. 253 Mixed-use will lead to anti-social behaviour
Response
623. In response to representations, 80, 178, 454 and 523, the Council are committed to ensuring that Chilmington Green becomes a place of real quality, and this message is at the heart of the policy approach in the AAP. Chapter 11 sets out a number of steps (in terms of process) which will ensure that good quality design is delivered throughout the process, including the need for design codes, phased masterplans, involvement of the Regional Design Panel, workshops and exhibitions, as well as a formal review of the AAP approach.
624. Representations 253 is noted, although it is unclear why mixed development – in itself will lead to anti-social behavior.
d) Maps
625. Representation 282 considers the secondary school and Park and Ride not shown correctly on proposals map.
626. Representation 306 considers there to be inconsistency between the Proposals Map and the Key. The ‘extent of development’ should be redrawn to include the sites of the Secondary School and the Park and Ride site. 100
627. Representations 372 and 398 felt that to ensure consistency with the Ecological Mitigation and Enhancement Strategy, all proposed linkages should be shown on the strategic diagram.
628. Representations 466, 481: The mitigation and enhancement land shown in white on the Proposals Map, should be coloured green like the strategic diagram, to reflect the location of ecological enhancement and mitigation land in the south. This will help to prevent any attempt to put further development on this southern area.
Response
629. In response to representation 282, the Council agrees that the Secondary School and Park and Ride site aren’t shown correctly on the Proposals Map and will be amended. Please refer to the schedule of proposed minor amendments.
630. In response to 306, the Council agrees that the ‘extent of development’ should be redrawn to include the Secondary School and Park and Ride Site. Please refer to the schedule of proposed minor amendments.
631. The Council disagrees with representations 372, 398, 466 and 481. Annotating the map in this way would lead to an inflexible and rigid approach. The finer details of needed ecological mitigation and enhancement areas will manifest themselves through the planning application process and will need to adhere to the policy approach advocated in the AAP.
e) Impact on emergency services
632. Representations 70, 92, 186, 208, 226, 484: With public services already stretched and facing further cuts we can see no plans for A&E, fire services, ambulance and police. An increase in local population will add even greater demands on already overstretched local services. 538, 542, 541 outline that the growth in population will particularly impact on police services. 186 has concerns that due to the population rise police will not be able to control the area. 70 adds that a development of this size would need a new local fire station
633. Representations 59, 92, 142, 423: There is already a lack of policing (due to funding cuts) to deal with another development in Ashford. 423 adds that the magistrates court in Ashford has been closed, as have the custody suites at Ashford police station. 90 also mentions the closure of the custody suites.
634. Representations 538, 540 and 542 these Kent Police representations state that in order to maintain an effective and efficient policing service to the residents of Ashford Borough and the rest of the County Kent Police would seek developer contributions/ClL for the new infrastructure requirements as a result of this proposal.
635. They calculate this sum as: For 3,350 new dwellings the level of contributions necessary would be £1,442,058. For 7,000 new dwellings the level of contribution would be £3,012,523 (both subject to adjustment for social/affordable housing). Such funding is supported by both Ashford Borough Councils current local policies and the NPPF. Please note the majority of the Kent Police infrastructure provision would be 'off site'. £2,474,366 required by police if 5750 dwellings built with adjustments for affordable housing.
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Response
636. In response to the representations above, these statements could be applied to any form of growth and are not specifically related to Chilmington Green. However, it is accepted that more development in an area, will place more demand on services. All the relevant service providers are responsible for planning how to cater for demand in various areas and likely population growth. On this, the proposed Chilmington Green development has been in the public domain since the early stage of the Core Strategy (2003) with the relevant service providers engaged in the debate at various stages since this date (including the publication of the Chilmington Green Area Action Plan).
637. In response to specifically 538, 540, 542, the requirements for appropriate developer contributions for policing are noted. These will be considered in the light of national policy considerations and will be discussed through the appropriate S106 channels. In addition, it is unclear why this would apply solely to Chilmington Green, as such an approach has not been replicated in any other site allocation document produced by the Council to date, and there have been no changes to the national thinking since this time. Therefore, if evidence of the need for such contributions can be shown, it would probably be more appropriate to deal with through either the first review of the Core Strategy or perhaps the Generic DC DPD which the Council is yet to produce.
f) Employment
638. Representations 183, 246, 385, 454, 502: We are constantly told that large scale developments such as this one create employment. However, most of the jobs will be short-term, for example construction jobs during the duration of the building or low paid. 454 adds that this will probably be carried out by migrant workers not the local unemployed. 385 the building of the development would use little in the way of "local' labour. Representations 142, 225 and 430 what to know how the job creation materialise? Jobs – where and what are they? 430 How is it possible to give such precise figures for jobs at this stage?
639. 502 Singleton, with over 2500 dwellings was developed without a link to jobs/employment. Kings Hill in West Kent only has 3% of the residents working on the site. Surely we must recognise we will be a commuter town first. Employment will rise as entrepreneurs see the right personnel living here. We are streets ahead of Milton Keynes where it took 18 years before commuters inwards overtook commuters outwards.
640. 183 In other similar developments it has been found that most of the highly skilled workers are imported from elsewhere and there is therefore no benefit to the local community.
641. Representation 82 Para 4.16 is contradicted by para 4.17.
Response
642. In response to comments 142, 183, 225, 246, 385, 430, 454, 502, job creation at Chilmington Green will manifest itself in various ways and this is reflected in Table 1 of the AAP. These figures do not take into account the likely number of jobs created through the construction of the development and the figures are based on national standards and best practice.
102 643. In response to representation 502, please refer to the Council’s response to Theme 1 of this response paper (response to Objection point nine).
644. With regards to representation 183, there is no evidence to suggest that highly skilled and professionals jobs at Chilmington, will be taken by people that live outside the local area.
645. In response to representation 82, Paragraphs 4.16 and 4.17 do not contradict each other, as has been suggested.
g) General comments
646. Representation 275: £30 million of new funding has been put forward by the Government to provide financing where groups of self-build homes are built together, and that last year self -builders built more homes that many of the major developers in this country, have we made sufficient provision in the AAP for self-building, considering this is a fairly new funding stream?
647. Representations 105 and 150 CG will impact on waste and recycling facilities. 150 adds I can find no mention anywhere in the AAP of recycling facilities. The current provision at Brunswick Road is woefully inadequate already with long queues of. A proper site needs to be provided at Chilmington to prevent extra burden being placed on existing facilities and to ensure the residents of Chilmington don’t have to drive silly distances to recycle.
648. 249 I understand that a new refuse disposal unit is being built just off of Chart Road, with a large amount of lorries travelling to and from it (even though they are being asked to use the new small road). How do they get to the new road? They can’t just drop out of the sky. They’ll have to enter it from the A28, M20 junctions at Hythe Road, Willesborough.
649. 459 Many local parishes in the Borough, including Wittersham are developing their own community led plans. In the spirit of the localism agenda, it is vital that these are given appropriate weight in the outcome of the Consultation.
650. 494 KCC draw attention to the Kent Minerals and Waste Local Plan (KMWLP), which is currently being prepared. They also state that the AAP could be affected by the Minerals Safeguarding Strategy, which safeguards minerals of economic importance against development that would prevent the excavation of the economic minerals in the future. They outline a building stone outcrop of Bethersden Marble, will be safeguarded and the development at Chilmington Green could affect this. Early work with developers and the mineral industry may be needed early on to extract the mineral before commencement of development.
651. 23 What phase is anticipated for the land behind my bungalow, it was supposed to be phase 3 but someone with a vested interest has suggested phase 1. What type of homes - 3 bed, 4 bed, flats, will border my bungalow?
652. 104 Closing date for consultation is 11 June. What is the process after this date?
653. 153 It is too large in scale, the ABC Planning department is not resourced for such a large project.
654. 248 Sets out a poem that is against the development.
103 655. Rep 68: Supports the development at Chilmington Green, as a principle.
656. Representation 10 questions who were the community representatives mentioned in paragraph 1.4 of the AAP? It questions whether the representatives were a fair representation of the community and how did these community representations test the plan and what were the outcomes? The representation states that the Council are not listening to the majority of residents who are strongly opposed to this development.
657. Representation 71 agrees that the public and their representatives have been extensively involved in the planning process over the years, but would like to make it clear that the only input allowed was on the features, quality and disposition of the development and not whether it should happen or not. As shown by local parish Council elections, local residents are not in support.
Response
658. In response to representation 275, the AAP doesn’t preclude the ability of self builds to come forward. Primarily this is a matter between the developers and interested parties at the more detailed stage. Provided any self build development accords to the principles and policies within the AAP (and any subsequent design codes), they is no reason why they couldn’t come forward.
659. With regards to representation 105 and 150, Ashford’s currently recycling facility is planned to be expanded shortly.
660. As identified by comment 249, planning Permission has been granted for improved waste and recycling facilities off Chart Road. A condition attached the planning permission ensures that the traffic movements generated by the development could be accommodated without detriment to highway safety.
661. In response to comment 459, the Council fully acknowledge and support the creation of neighbourhood plans, in principle.
662. Further discussion with KCC has established that no amendments need to be made to the plan following representation 494. Further detailed mapping provided by KCC has identified that land containing Bethersden Marble is not contained within the CG development boundary.
663. No amendments to the AAP need to be undertaken following comments 23 and 104. The authors of the representations have been contacted directly to answer their personal questions.
664. The Council disagrees with representation 153, the planning department is appropriately resourced to deal with proposals at Chilmington Green and dedicated planning officers have been appointed to deal with increased workload.
665. In response to representations 10 and 71, a community stakeholder working group was established at the early stages of the drafting of the AAP and has met at regular intervals. This group has provided a cross section of the local community with the opportunity to shape and evolve the detailed planning of Chilmington Green. However, it has always been clear that participation in this group has not been dependent on whether the representatives support the principle of Chilmington Green or not.
666. Representation 68 is welcomed. Representation 248 is noted.
104 Addendum 1 – Standard letters
Standard letter - 9 point letter
I am writing to object to the plans outlined for Chilmington Green in the recently published Area Action Plan. I object to the principle of development for the following reasons:
1. An overwhelming majority of the people who live in the areas affected by these plans have signed a petition opposing the development of the area. Clearly, the plans do not have the support of the local community.
2. Development of green field sites is environmentally irresponsible when brown field sites have not yet been developed. When the Growth Area development started in Ashford it was agreed that development was to be “central” and “concentric”; yet Ashford Borough Council is planning to build a new satellite town in the countryside before brown field land in the town centre has been redeveloped. There are still large brown field sites in the town centre with planning permission awaiting development.
3. The proposed development is so large that it would place significant additional pressure on the services and infrastructure of Ashford and the surrounding areas. I doubt that any central government development funding that is made available as a result of building additional houses, or the financial contributions from the developers, would pay for the increase in public services and infrastructure that an enlarged Ashford would require.
4. The development would cause severe environmental damage, destroying the habitats of water voles, door mice, great crested newts, brown hares, snakes, badgers, deer, cuckoos, woodpeckers and bats. The fields around Chilmington Green have been productive for centuries and building on them would be a loss of agricultural capacity and valuable biomass.
5. We are told that Ashford’s borough councillors only acquiesced to the construction of 30,000 new homes because the council leader at the time stated that failure to do so would result in the establishment of a New Town Commission under the control of Whitehall. The Chilmington Green scheme was therefore devised under duress. Since that time, the South East Development Plan has been scrapped and all government development targets have been abolished. Therefore, Ashford no longer has any obligation to be a growth town and can no longer justify the Chilmington Green development on these grounds.
6. Ashford has suffered from excessive development over the past decade that has led to falling house prices, lower average household incomes, increased unemployment, traffic congestion and stretched public services. The overdevelopment of Ashford resulted in house price falls of 13% in 2011 – the third greatest decline anywhere in the UK. Since the year 2000, approximately 6,000
105 new houses have been built in Ashford Borough. In addition to this, it was revealed under the Freedom of Information Act in October 2010 that Ashford Council had granted permission for 6,300 houses to be built which had not yet been constructed owing to weak demand. The council also stated that it intended to grant planning permission for a further 3,000 houses since that time. That equates to a 75% increase in Ashford’s housing stock over the past decade and excludes the proposed South Ashford New Town development at Chilmington Green. Ashford already has enough unused capacity to build 500 houses every year for the next 18 years without any development at Chilmington Green.
7. It is unwise to construct a new town with a high street that will compete with Ashford Town Centre. Shop vacancy rates in Ashford Town Centre have increased dramatically over recent years and the proposed development at Chilmington Green would ensure that Ashford Town Centre continued to decline.
8. The planned growth of Ashford has been predicated on additional water supplies being made available from Bewl Water and the construction of an entirely new reservoir at Broad Oak. The Broad Oak reservoir scheme appears to have been abandoned and Bewl Water is in a state of crisis with water levels at historic lows for the time of year. Given that a drought has been declared in Kent and the water companies have already introduced restrictions based on their inability to meet Ashford’s existing demands, how will they cope if Ashford increases in size by circa 15% following the construction of a New Town at Chilmington Green? The introduction of water restrictions appears to be an admission by the water companies that there is not enough water. Pushing ahead with development without increasing water supplies will have severe consequences for everyone who lives in Ashford.
9. The Core Strategy states that the development of Chilmington Green will result in 7,000 houses and 1,000 jobs. The plans appear to suppose that there will only be 1 additional job per 7 additional households. If there are 2 people living in each new house, there will only be 1 local job per 14 people. As there is no industry or business in Ashford that wishes to recruit large numbers of additional staff, the construction of a new town will make it significantly harder for local people to find jobs and cause unemployment to increase.
For these reasons, I urge Ashford Borough Council to abandon or reject any plans or proposals, either now or in the future, to permit new building on Chilmington Green or the surrounding countryside.
106 Standard Letter – 5 point letter
I am writing to object to the plans outlined for Chilmington Green in the Local Development Framework, the Greater Ashford Development Framework and the Core Strategy. I object for the following reasons: 1. An overwhelming majority of the people who live in the areas affected by these plans have signed a petition opposing the development of the area. Clearly, the plans do not have the support of the local community.
2. Development of green field sites is environmentally irresponsible. When the Growth Area development started in Ashford it was agreed that development was to be “central” and “concentric”; yet Ashford Borough Council is planning to build a new satellite town in the green belt before regenerating brown field land in the town centre.
3. The proposed development is so large that it would place significant additional pressure on the services and infrastructure of Ashford. I doubt that any central government development funding that is made available as a result of building additional houses would pay for the increase in public services and infrastructure that an enlarged Ashford would require.
4. The development would cause severe environmental damage, destroying the habitats of water voles, great crested newts, brown hares, snakes, badgers and bats. The fields around Chilmington Green have been productive for centuries and building on them would be a loss of agricultural capacity and valuable biomass.
5. We are told that Ashford’s borough councillors only acquiesced to the construction of 30,000 new homes because the council leader at the time stated that failure to do so would result in the establishment of a New Town Commission under the control of Whitehall. The Chilmington Green scheme was therefore devised under duress. Since that time, we have had a general election. The new government scrapped the South East Development Plan and has written to councils informing them that all government development targets are to be abolished and that, until they are, councils are to ignore them. Therefore, Ashford no longer has any obligation to be a growth town and can no longer justify the Chilmington Green development on these grounds.
I urge Ashford Borough Council to abandon or refuse any plans or proposals, either now or in the future, to permit new building on Chilmington Green or the surrounding countryside.
107 Addendum 2 – Full list of representations received on the draft (reg 19) version of the Chilmington Green Area Action Plan
*Members please note, this file is too large to circulate for Cabinet (a hard copy will be available to view on the evening of the 11th October and a hard copy has been placed in the members room prior to this meeting).
In any event, all of the representations received on the draft version (regulation 19) of the Chilmington Green Area Action Plan can be viewed publically, on the Council’s website. Please visit www.ashford.gov.uk/consult and follow the links to the Chilmington Green Area Action Plan.
Alternatively please call 01233 330 229 to speak to officers of the planning policy team.
108
Addendum 3 – Index of representations received
109
110
111
112
113
114
115
116
APPENDIX B: Schedule of proposed minor amendments to the Regulation 19 Version of the Chilmington Green Area Action Plan
Amendment AAP section / Proposed Minor Amendments Number Paragraph or Policy number 1 1 – Introduction Amend text to Paragraph 1.9: Paragraph 1.9 The AAP is also supported by a Proposals Policies Map that ‘fixes’ key elements of the Chilmington Green development. These include; the extent of the AAP boundary and therefore where the policies in this AAP apply, the extent of the development (see paragraph below), relevant saved policies from the Ashford Borough Local Plan (2000) constraints, including Ancient Woodland, listed buildings and the location of the 1 in 100 year floodplain, the principal vehicular access points for the site, as well as the location and size of both Discovery Park and the secondary school (both are strategic infrastructure that will be delivered as part of Chilmington Green). 2 1 – Introduction Amend sentence 2 of Paragraph 1.18: Paragraph 1.18 In addition, the AAP is intended to be formally reviewed at least every five to seven years to ensure the wider policy position is up to date.
3 3 - Vision & Objectives Add text to Paragraph 3.2: Paragraph 3.2 This vision was expanded upon during the evolution of the Chilmington Green Masterplan and meets the first core land-use planning principle of the NPPF. Furthermore, the NPPF states that in terms of delivering a wide choice of high quality homes, this can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Suburbs. It suggests that such opportunities might provide the best way of achieving sustainable development and should be explored by working with the support of their communities.
The remainder of existing paragraph 3.2 is moved to paragraph 3.4 (see amendment 4 below)
4 3 - Vision & Objectives New Paragraph 3.3: New Paragraph 3.3 This idea is explored further in work undertaken by the Town and Country Planning Association (TCPA), which published a report in May 2012, entitled “Creating garden cities and suburbs today – policies, practices, partnerships and model approaches”. The TCPA believes that the ideas of the Garden Suburb movement remain highly relevant in the 21st century, providing a crucial foundation for high quality inclusive places and the creation of new jobs and truly sustainable lifestyles. The Council’s aim is to establish a new development at Chilmington Green based on these principles, and this is reflected in the policies within this AAP. The commitment to pursuing quality is at the heart of the Council’s policy framework for Chilmington Green as expressed in the Cabinet’s 2030 Framework and the adopted Core Strategy.
5 3 - Vision & Objectives Move text from existing paragraph 3.2 to create new paragraph 3.4: 3.2 & New Paragraph The result below has been formulated by local people, Councillors, the developers and designers as a 3.4 basis for moving forward through the planning and delivery of a strong, successful and sustainable new community at Chilmington Green.
6 5 – Character Areas Replace Paragraph 5.4: Paragraph 5.4 Planning Policy Statement 4 defined District Centres as locations which ‘usually comprise groups of shops often containing at least one supermarket or superstore and a range of non-retail services, such as banks, building societies and restaurants as well as local public facilities such as libraries’.
The NPPF makes it clear that in order to promote healthy communities there should be opportunities for all sections of the community to interact. This requires the positive planning for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities. The District Centre at Chilmington Green will accommodate many of these functions.
7 5 – Character Areas Amend Table 1: Table 1, Page 31 Amendment to read – B1 (c) within and on edge of Local Centre 1,750 1,700
8 5 – Character Areas Amend Paragraph 5.27: Paragraph 5.27 Amend last sentence to “..have their primacy primary pedestrian access…”
9 5 – Character Areas Amend Figure 8: Figure 8, Page 45 The listed buildings shown incorrectly on the diagram, amendment needed to reflect correct position.
10 6 – Meeting the Replace Paragraph 6.29: recreational needs of the At Chilmington Green however, the ‘Strategic Parks’ provision will be met through the Development delivery of an additional part of Discovery Park, as this is one of the three strategic Paragraph 6.29 parks identified within the Core Strategy (policy CS18a) to support the wider town.
At Chilmington Green however, it is expected that this ‘‘Strategic Parks’ contribution will be met through the spatial delivery of part of Discovery Park, in lieu of solely making a financial contribution.
11 7 –Discovery Park Insert New Paragraph after 7.6: Paragraph 7.6 The Discovery Park Masterplan will also need to examine how to achieve the suitable integration of the proposed link road (linking Chilmington Green with Brisley Farm – intended to come forward in phase 2) with the wider proposals for Discovery Park. For example, how street lighting along this route is delivered without eroding the landscape qualities of the area (existing and planned) will require careful consideration. Any proposals will need to be balanced with the necessary highway requirements, so that all users of this route (both vehicular and non-vehicular) can do so in a safe way, during the day and night.
12 7 –Discovery Park Insert New Paragraph after 7.17: Paragraph 7.17 Accessible links between the proposed extension to Brisley Farm (intended to come forward in phase 1) and Discovery Park will also need to be delivered in the first phase of the development. This will improve accessibility to the Discovery Park area for the new community, as well as the existing residents of Brisley Farm.
13 9 – Transport Replace Paragraph 9.46 with a new Paragraph 9.46: Paragraph 9.46 The developer will be expected to proactively incentivise use of the public transport service, including through the issue of free or subsidised season tickets, with a ‘toolkit’ of measures and further incentives identified that can be applied subsequently should there be risk that the target 20% mode share will not be achieved. The developers will be expected to proactively incentivise the use of the public transport service by new residents. This could include such measures as a ‘welcome pack’ with free or subsidised tickets for an initial period. A toolkit of further measures and incentives should be identified, and implemented should the target of 20% public transport modal share not be achieved.
14 10 –Topic Policies Amend the last sentence in the first paragraph of Policy CG15: Policy CG15 – The site will be made available for transfer to the relevant education authority or provider at the request EDUCATION of the county council. PROVISION 15 10 – Topic Policies Move text in bullet 2 under Paragraph10.21 to create two new bullet points: Community Leisure • At the Local Centres, dedicated community space is envisaged (500 sqm GIA at each Local provision, paragraph Centre), to support their local neighbourhood and ensure that these Centres become focal 10.21 points. • Community space (250 sqm GIA) is also envisaged as part of the pavilion proposed to complement the cricket pitch, envisaged near the hamlet. • In addition (as stipulated above) 500 sqm (GIA) of bespoke community space (in addition to the 4 court badminton area) is envisaged at the indoor sports hall to complement its role and the indoor sports activities that will be based there. In line Policy LE8 of the Local Plan, ‘community space’ should be flexible (to cater for varying scales of community activity) and be available for general community use for most of the day and evening.
16 10 – Topic Policies Add text to end of Paragraph 10.43: Special Needs An appropriate level of supported housing will need to be agreed with the Council, including extra care Accommodation, sheltered housing, supported care for young people and wheelchair accessible housing. Paragraph 10.43
17 10 – Topic Policies Amend last sentence of paragraph 10.53: Sustainable Design and As such, a district heating network should be delivered is the Council's preferred approach at the Construction, Paragraph District Centre to take advantage of the relatively higher density of residential development and mix of 10.53 uses that will be delivered there.
18 10 – Topic Policies Amend paragraph 10.55: Sustainable Design and If, through a detailed and independently assessed financial viability assessment, adopting a district Construction, Paragraph heating network is demonstrated not to be viable in it’s own right, based on reasonable market 10.55 assumptions the Council will require that appropriate and alternative low and zero carbon technology can be delivered instead and that these solutions generate equal or better carbon savings for the development as a whole. 19 10 – Topic Policies Amend the 3rd and 4th sentences of paragraph 10.83: G) Ecology, Paragraph It will also need to demonstrate the anticipated timeframe required for mitigation and enhancement 10.83 areas to become properly established in order to genuinely mitigate or compensate impacts resulting from development, in addition to setting out a clear approach to future monitoring to ensure the aims of the strategy are being met. Planning conditions and / or suitable S106 Agreement will be used to define a deliverable management strategy, in perpetuity the long term.
20 10 – Topic Policies Add a new sentence to paragraph 2 in Policy CG21: Policy CG21 - An ecological enhancement and mitigation strategy will be needed, to be agreed with the Council, prior ECOLOGY to the approval of planning permission. This strategy will confirm how any required ecological enhancement and mitigation measures are to be implemented, managed, phased and maintained in the long term as well as setting out long-term ecological monitoring procedures for the site.
21 11- Phasing, Insert new bullet points to 11.43: Implementation and • An assessment of the impact on water quality, habitat management and aftercare of assets. Quality control C) Construction Strategy • Measures to minimise impacts on biodiversity, including habitats and species along with connections Paragraph 11.43 with the wider environment.
22 11- Phasing, Amend second sentence of Paragraph 11.45: Implementation and Not only will This approach will ensure that each component part of the development works as a whole Quality control and is consistent with the aspirations of the AAP, the standards established through the Building for Life D) Quality Control process, as well as ensuring and the Council’s locally determined planning policy approach. This Paragraph 11.45 includes the – such as clear drive for quality placemaking, as established through the Council’s promotion of suitable residential space and layout standards, alongside suitable arrangements for residential parking. Are at the heart of good place making.
23 11- Phasing, Insert New Paragraph after 11.46: Implementation and Quality control In addition, the Council and the Chilmington Green development consortium are currently preparing a D) Quality Control Quality Agreement which will shortly be signed by both parties. This Agreement will underpin the Paragraph 11.46 detailed planning for Chilmington Green and support the site-wide design code. It will be a firm commitment – from the outset – that quality will be at the heart of development at Chilmington Green. It will build upon the objectives, vision and policies contained within this AAP and will also take on board the garden suburb principles, particularly in terms of the need for a clear and legible street hierarchy, the importance of well-designed green spaces and strong tree provision in a variety of different forms and with an appropriate variety of scale that supports hierarchical place-making and helps soften and complement street character and built form.
24 12 – Monitoring and Insert new paragraph after 12.4: Review An ecological enhancement and mitigation strategy will be agreed with the Council prior to the approval of planning permission. This strategy will set out long-term ecological monitoring procedures for the site that will be undertaken by the developers in consultation with Kent Wildlife Trust.
25 12 – Monitoring and Amend second box down, target column: Review, Table on Page 1,750 1700 sqm (GIA) 122 26 12 – Monitoring and Amend fourth box down, target column: Review, Table on Page 20% modal share achieved by the end of the development 122 20% modal share target to be monitored every 3rd year
27 12 – Monitoring and Amend paragraph 12.6: Review, Paragraph 12.6 The AAP will be formally reviewed at least every 5 to 7 years to ensure the wider policy position is up to date. This will include a consequential review of the monitoring indicators and targets set out above.
28 Proposals Map Amend Map: The ‘extent of development’ boundary will include the Secondary School and the Park and Ride.
29 Glossary, p136 Remove ‘Green Corridor or ‘necklace’’ from the Glossary
Green Corridor or ‘necklace’ - The links between green spaces within the urban area - known as the green 'necklace' - that will make use of the existing 'Green Corridors' through Ashford. The Green Corridors are defined on the Proposals Map, and are protected by policies in the Local Plan 2000 and the emerging Green Spaces and Water Environment SPD.
30 Appendix 3, IDP Amend 3) outdoor sports space: page 147 The 1.85h of space, comprising the cricket pitch, will be included in the ‘Quantum’ and ‘Cumulative Quantum’ columns
31 Appendix 3, IDP Amend c) Movement Network part 1): page 148 Change wording in Quantum/trigger point column to: Northern access completed prior to the commencement of development on the rest of the site.
32 Appendix 3 - IDP Insert sewerage connection criteria to all 4 phase tables: Type of Provision Quantum/Trigger Point Cumulative Quantum
Sewerage – connection to Prior to occupation sewerage network (off-site) at point of adequate capacity as defined by Southern Water 33 New Appendix 4 Insert New Appendix 4: Housing Trajectory See below
34 New Appendix 5 Insert New Appendix 5:
Schedule of Ashford Borough Local Plan Policies affected
None of the remaining 'saved' Ashford Borough Local Plan policies will be deleted on the adoption of this AAP, as those affected by this AAP all remain relevant outside the AAP boundary.
Specifically, Ashford Borough Local Plan saved policy S20 - Singleton is superseded within the AAP boundary, but continues to apply outside the AAP boundary, namely in the Urban Area (where it is preserved in force by the Urban Sites & Infrastructure DPD 2012).
Generally, paragraph 7 of the Introduction to the Ashford Borough Local Plan defines "Ashford" as including the planned major developments around it, and "The countryside" as the area outside "Ashford". Following the adoption of this AAP, the area to which this AAP applies becomes a "planned major development" and no longer part of "The countryside". The remaining saved Ashford Borough Local Plan policies relating to The countryside will be interpreted accordingly.
Amendment 33 - Chilmington Green Area Action Plan Housing Trajectory 2014 – 2038 2014 - 2025 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 TOTAL
150 225 250 275 275 275 240 240 240 240 240 2,650
2025 - 2038 2025 – 2029 1150
2030 – 2034 1030
2035 – 2038 920
TOTAL 3,100
Factual Updates and Consequential Changes required to the AAP:
Amendment AAP section / Proposed Minor Amendments Number Paragraph or Policy number 32 Footnote 16, page 26 The report referred to as the Chilmington Green Economic Assessment 2011 will be amended to Chilmington Green Employment Report.
33 9 – Transport Insert key to the figure 12 Figure 12, page 75
34 9 – Transport Amend text within Figure 13: Figure 13, page 77 ‘Victoria Road’ should be referenced as ‘Victoria Way’.
35 9 – Transport Insert key to the figure 14 Figure 14, page 79
36 Glossary, page 136 Amend District Centre definition: Planning Policy Statement 4 defined District Centres as are locations which usually comprise groups of shops often containing at least one supermarket or superstore and a range of non-retail services, such as banks, building societies and restaurants as well as local public facilities such as libraries. In this development it will include the Chilmington Green High Street which will include a range of services, whilst also being the primary route through the new development for vehicular traffic, pedestrians and cyclists. 37 Glossary, page 137 Amend Localism Bill / Act definition: The Localism Bill was given Royal Assent in November 2011, becoming an Act. The Localism Act includes five key measures that underpin the Government's approach to decentralisation, including neighbourhood planning and housing.
38 Chapter 12 – Monitoring Amend table in the monitoring chapter to ensure that the figures line up with the text correctly. and Review
39 Proposals Map Secondary school and the Park and ride are marked incorrectly on proposals map key and will be swapped.
40 Strategic Diagrams 2c Bridleways marked on Strategic Diagram 2c and figure 15 will be amended to reflect the correct and Figure 15 position 41 Various: All references to the ‘emerging / Green Spaces and Water Environment SPD’ amended to Paragraph 6.2 ‘adopted / Public Green Spaces and Water Environment SPD’. Table 2 footnote
Paragraph 6.8 Paragraph 6.12 Footnote 25 on page 57 Paragraph 6.16 Paragraph 6.27 Paragraph 6.28 Policy CG8 – Paragraph 8 Paragraph 7.8 Glossary – Green corridor (necklace) Glossary – Green Spaces and Water Environment SPD
42 Various Consequential Changes of changing Proposals map to Policies Map
Contents Page PROPOSALS MAP POLICIES MAP
1.9 The AAP is also supported by a Proposals Policies Map that ‘fixes’ key elements of the Chilmington Green development…
1.10 There are a number of existing properties (both residential and commercial) and small landholdings4 which fall within the ‘extent of development’, as shown on the Proposals Policies Map.
4.3 Based on the above factors, the extent of the built development has been identified and fixed on the Proposals Policies Map.
5.43 … Several Grade II listed buildings are present within and adjoining this Character Area, as shown on the Proposals Policies Map.
7.9 The area of Discovery Park, as allocated within the AAP (see Proposals Policies Map), is broadly consistent with the indicative area shown on the Core Strategy Figure 2.
10.60 Despite this, only a small part of the Chilmington Green site lies within a 1 in 100 year flood risk area51 - this area is outlined on the Proposals Policies Map that accompanies this AAP. Further information can be found in the Water Cycle Strategy Report52.
11.32 This AAP includes a Proposals Policies Map which seeks to fix some key aspects of the development, such as the extent of the development area (see section 1), the AAP boundary and the locations of both the secondary school and Discovery Park – both strategic infrastructure delivered by the development.
11.36 AAP policies, Proposals Policies Map and illustrative masterplan
Site-wide design code
Phase Development Masterplans and supporting area design codes
CG2: Proposals for development at Chilmington Green will deliver up to 5,750 homes and at least 1,000 jobs. The built footprint of the development (with exception of any buildings in Discovery Park) will be contained within the ‘extent of development’ area shown on the Proposals Policies Map.
CG9 As shown on the Proposals Policies Map that supports this AAP, land to the east of Chilmington Green is allocated for the creation of a strategic open space, sport and recreational area, currently referred to as Discovery Park.
CG11 (d) The closure to traffic of Chilmington Green Road at a point close to its junction with the A28, in accordance with the Proposals Policies Map.
CG15 One minimum 6 form entry secondary school (on a minimum 8 ha site) shall be provided as part of the Chilmington Green development, in accordance with the allocation shown on the AAP Proposals Policies Map. The site will be made available for transfer to the relevant education authority at the request of the county council.
Glossary- Development Plan Document: ….. DPDs include the Core Strategy, site-specific allocations of land, Area Action Plans and the Proposals Policies Map……
Proposals Policies Map - An essential component of a Local Development Framework, showing the location of proposals in all current Development Plan Documents on an Ordnance Survey base map.
43 Various Consequential paragraph number changes to take on board a number of changes referred to in the schedules above.
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a Site Access Point 0 0.25 0.5 1 Kilometre P 1:10,000 p Chilmington Green Road Closure APPENDIX C - Chilmington Green AAP Consultation Events
Date Event Details Attendees Appendix
2007
Jan 24 Stakeholder This was the first Chilmington Green workshop 41 Attendees - 1.1 Workshop – which involved representatives from the public, Ashford Borough Council inc. Charter House, private and voluntary sectors, Borough Council representatives from Planning, Ashford members from the area and the Local Cultural, legal, Environmental Development Framework Task Group. It was and Housing services. Kent arranged to initially start the consultation process County Council representatives of the Issues and Options stage. The final Issues from Highways, Strategic and Options Report was then consulted on from planning, Property, health and the 28th September 2007 until 2nd November Education departments. 2007. Ashford’s Future Officers. This workshop was an interactive session designed to encourage debate on a number of themes. The morning event started with an exercise in which all attendees independently wrote down the key issues which they felt needed further discussion. Following the collation of issues into themes, including design, transport, landscape and housing, All workshop attendees were then able to discuss these issues in greater detail in small groups and to identify options for tackling these issues. The outcomes of this workshop were circulated to all attendees.
Feb 26 Chilmington Green To engage local representatives in the future 24 Attendees 1.2 Parishes Meeting development of Chilmington Green, a meeting was held for the local parish councils - Great Chart with Singleton, Kingsnorth and Shadoxhurst - and a number of Chilmington Green and Great Chart residents. It was an opportunity for local residents to raise their issues.
Date Event Details Attendees Appendix
2008
Sept 30 Stakeholder The 30th September 2008 saw an independently Over 40 attendees took part in 1.3 Workshop facilitated one day workshop held at the Singleton the workshop, including Environment Centre to provide over 40 key Councillors and officers from stakeholders with an update on the Area Action Ashford Borough Council, parish Plan. It also gave participants an opportunity to council representatives, put their initial views and ideas across about how community groups, Ashford’s the area should be developed. Topics for Future, and Kent County Council discussion included; density planning and land representatives. SMARTLINK, take, connectivity and public transport, Discovery The Environment Agency, The Park and the distribution of green space and the Land Restoration Trust, Ashford location and form of the High Street. Ramblers and The Green and Blue Grid were all represented along with local landowners and developers.
Oct 28 - Community This community stakeholder group was set up to Initially comprised of 18 2.1 to 2.20 ongoing Stakeholder help create a strong dialogue between local individuals (excluding Ashford Meetings representatives, Borough Councillors, the Borough Council and Ashford landowners/developers, council planners and Future staff). A letter was sent by Ashford’s Future company. ABC Planning in August 2010 to It provides an opportunity for an informal but 52 properties within and focused debate on key points of concern to the bordering the Chilmington Green local community, so that their views can help site boundary, explaining the shape emerging plans for Chilmington Green. It is AAP process and informing local a mechanism that helps with information flows to people how they could find out local people, with messages being dispersed via more. Each letter was tailored to the Parish Council and the local action group. the Parish within which the It is a means of ensuring continuity over a project property lay. This resulted in the with a long timescale of masterplanning and group increasing to 36. delivery, so that local community representatives can play a really effective role.
Date Event Details Attendees Appendix
See appendix 2.1 to 2.20 for details of these meetings.
These are ongoing events which have been held on the following dates: Appendix 2.1 28 October 2008 2.2 15 January 2009 2.3 12 March 2009 2.4 18 June 2009 2.5 03 September 2009 2.6 13 October 2009 2.7 23 November 2009 2.8 18 May 2010 2.9 16 June 2010 2.10 10 August 2010 2.11 16 September 2010 2.12 16 November 2010 2.13 20 January 2011 2.14 16 March 2011 2.15 21 June 2011 2.16 17 August 2011 2.17 18 October 2011 2.18 22 November 2011 2.19 25 January 2012 2.20 29 February 2012
Date Event Details Attendees Appendix
2009
Feb 4/5 Stakeholder Design The purpose of this workshop was to reflect Around 80 delegates participated 1.4 Workshops - collectively on the key issues from the previous in the workshop, including Holiday Inn, workshop of 30th September 2008, and work with councillors and officers from Ashford a number of expert consultants to develop high Ashford Borough Council and level options which will help move forward the Kent County Council, masterplanning process (to occur at a later representatives from the Parish stage), in accordance with the principles set out in Council and local community the Core Strategy and GADF. The event groups, Ashford’s Future, the combined a series of short plenary and group local Primary Care Trust, the 'learning presentations' by the expert Environment Agency and South consultants, together with detailed discussions Kent Police. Also in attendance and design workshops on a number of key were consultants bringing themes. expertise for specific aspects of the Plan. Feb 5 Public Exhibitions – The two day event held on the 4/5 Feb concluded ABC planning led exhibition 1.5 at Shadoxhurst with two public exhibitions held in the local 60 attendees at Shadoxhurst and Village Hall and community at Great Chart Primary School and 40 attendees at Great Chart Great Chart Shadoxhurst village hall. Primary School. Primary School This was an open evening which gave members of the public the chance to view and comment on initial plans and drawings that will shape the Chilmington Green and Discovery Park Area Action Plan. Feb 27 Debrief on 2 day Debrief session held with Ashford’s Future on the 7 Attendees design workshop 2 day Design Workshop held earlier in the month. May 18 Great Chart with The annual (general) community meeting included 40 Attendees 1.6 Singleton Parish a presentation by Richard Alderton – Head of Council Annual Planning and Development at Ashford Borough (General) Council, on the Chilmington proposals. Drawings Community and plans of the initial considerations were on Meeting display for people to see.
Date Event Details Attendees Appendix
2010
June 2 Sir Terry Farrell’s Public event arranged by Ashford’s Future where Ashford’s Future led event 1.7 Design Vision architect Sir Terry Farrell, appointed design Event – Ashford ambassador for Ashford, unveiled his unique International Hotel vision for how Ashford can become a nationally recognised centre of design excellence and quality.
In addition, businesses and residents saw an exhibition of the exciting new building developments, transport connections and community spaces planned for the town.
July 6 Meeting with A meeting was held with residents, in order to Not known 1.8 Chilmington Hamlet discuss masterplanning proposals. A follow up residents letter was sent to those residents and all 52 properties identified in the immediate area. July 22 Stakeholder A stakeholder workshop to present the emerging Around 80 delegates participated 1.9 Workshop – masterplan options in the workshops including Ashford elected Members, International Hotel representatives from Ashford Borough Council, Ashford’s Future, Great Chart with Singleton, Kingsnorth and Shadoxhurst Parish Councils, Kent County Council, Kent Highways, church groups and local residents. The consultant team appointed by the Chilmington Green landowners consortium also participated and assisted in facilitating the workshops.
Date Event Details Attendees Appendix
Sept 16 Sir Terry Farrell’s Key landowners, developers and stakeholders As well as Sir Terry Farrell, the 1.10 Design Workshop involved in the development of Chilmington Green workshop was attended by Judith met with Sir Terry Farrell to discuss the vision for Armitt, Managing Director from Ashford’s first urban extension. Ashford’s Future, Richard Alderton, Head of Planning & The event, on the 16th September, was held at Development at Ashford Borough the London offices of the internationally renowned Council along with key architect. landowners and developers involved in the development of Sir Terry has been working with Ashford’s Future Chilmington Green. and Ashford Borough Council to create a design vision for the town that will help deliver the highest possible design standards in new homes, businesses and communities.
This workshop considered the vision for the Chilmington Green urban extension and discussed how the ambition for design excellence in Ashford can be realised in this new development.
Sept 21 Landowners & Clare San Martin, a partner at John Thompson & AF / ABC led event 1.11 Developers Forum Partners, provided an overview of the emerging 30-40 Attendees masterplan and vision for Chilmington Green, Local landowners, developers, International Ashford’s first urban extension. agents House, Ashford
Sept Community A Chilmington Green Community Planning An event hosted by John 1.12 24/25 Planning Weekend Weekend to people an opportunity to give their Thompson & Partners – Singleton views and help develop ideas for a new urban Environment extension and major public park at Chilmington 70+ local residents attended Centre Green. The aim of the Weekend is to bring together everyone with an interest in Chilmington Green to produce a shared, practical Vision for its future development.
Date Event Details Attendees Appendix
Oct 20 Community This meeting was held to provide feedback on the An event hosted by John 1.13 Feedback Meeting Community Planning Weekend that took place Thompson & Partners – Singleton 24/25 Sept 2010. Environment 60+ Attendees Centre
2011
Feb 14 Workshop – Presentation by John Thompson and Partners 25 Attendees which included 9 1.14 Councillors and which included a workshop to discuss the Councillors 9, and 2 Parish Parish Council masterplan for Chilmington Green. Council Chairs Chairs Sept 27 Developer A public exhibition of the proposals for 1.15 Exhibition – Chilmington Green. The exhibition was organised Singleton by John Thompson & Partners on behalf of the Environment Chilmington Green Consortium ahead of an Centre Outline Planning Application to be submitted later this year. The exhibition illustrated how the consortium plan, to create a new community over the next 20 years. The Masterplan reflects the principles of Ashford Borough Council’s Adopted Core Strategy as well as the outcome of extensive technical studies, consultation with local people, Ashford Borough Council and other stakeholders. The purpose of the exhibition was to provide local people with more information about the new development and to collect further feedback.
Date Event Details Attendees Appendix
Nov 1 Stakeholder This event was organised by Ashford Borough The workshop, organised by 1.16 Workshop – Council where the emerging masterplan for Ashford Borough Council (ABC), Holiday Inn, Chilmington Green was presented and reviewed. saw around 60 delegates Bybrook, Ashford The workshop formed part of the councils participate, including elected consultation on the Area Action Plan for Members, representatives from Chilmington Green and Discovery Park. Ashford Borough Council, Great Consultants appointed by the Chilmington Green Chart with Singleton, Kingsnorth Consortium made presentations on key issues, and Sadoxhurst Parish Councils, including transport and movement, placemaking, Kent County Council and local greenspace, community development and residents. The consultant team, phasing and timing. appointed by the Chilmington Green Consortium, also participated and assisted in facilitating the workshops. Nov 23 Design Review This was a 1 day event which initially commenced 1.17 Panel with a Chilmington Green site visit, by Panel Members. This was followed by a workshop where the suggested following topics were discussed: • Community - identity and culture • Context and connections - response to wider context • Topography & Water - inc. SUDS • Vegetation & Wildlife • Urban Structure - Layout of neighbourhoods and local centres • Range of economic occupiers - mix of commercial and community uses • Scale and Character • Orientation and Legibility • Public realm and open space • Transport and movement - including parking • Sustainability • Delivery and phasing • Future engagement of the Panel
Date Event Details Attendees Appendix
2012
April Leaflet Drop To advertise the AAP Publication version 2012 consultation event and the public exhibitions, approximately 10,000 leaflets were sent out to local residents in Chilmington Location between 19th April and 31st April. This included Chilmington Green Hamlet, Singleton, Washford Farm, Bridewell, Kingsnorth, Stubbs Cross, Shadoxhurst, Great Chart, Brisley Farm, Park Farm and Chartfields.
These leaflets were also left in a variety of deposit points in the local areas (50 at each). These were: • Stubbs Cross Post Office • Footprints nursery and daycare (Imagine Play Centre), Kingsnorth • Kingsnorth Doctors Surgery • Kingsnorth Recreation Centre • Kingsnorth Medical Centre • Singleton Doctors Surgery - Hoxton Close • Stanhope Doctors Surgery – Kilndown Close • Singleton Medical Centre – The Singleton Centre • Singleton Dentist Surgery • Shadoxhurst Church • Queens Head Public House – Kingsnorth • Kings Head Public House – Shadoxhurst • Singleton Barn Public House • Hoodeners Horse Public House – Great Chart
Date Event Details Attendees Appendix
The leaflets were also sent out to the affected Parish Councils of Great Chart & Singleton PC, Kingsnorth PC and Shadoxhurst PC (100 each) to distribute.
16th April Public Consultation The Regulation 19 ‘Publication Version’ of The to 11th on AAP Chilmington Green Area Action Plan went out June for an 8 week public consultation. The consultation was advertised in the local press and on the Councils website. Letters were sent to all specific consultation bodies and general consultation bodies in accordance with the Statement of Community Involvement – First Review 2009. A letter was also sent to Parish Councils and any individuals that had registered an interest in the document on the Councils database. During the consultation period the AAP, representation forms and all supporting documents were left in 6 deposit points around the borough. These were: • Singleton Environment Centre • ABC Civic Centre • Ashford Gateway Plus • Wye Library • Tenterden Library • Charing Library
Date Event Details Attendees Appendix
May Public Exhibitions During the consultation period the planning Due to the drop in nature of 2012 of AAP policy team ran 3 public exhibitions for these events, we are unable residents to come and look at details of the to determine the exact number plan and ask questions to planning officers. of visitors to each of these There were information leaflets and events. representation forms for people to take away. They operated on a drop-in basis and were open to all members of the public. They were also advertised in the local press and on the Councils website. The event details are below: • Wednesday 2nd May - Singleton Environment Centre, Wesley School Road, 10am - 8pm • Wednesday 23rd May - Kingsnorth CEP School, Church Hill, Kingsnorth, 5pm-8pm • Wednesday 30th May - Shadoxhurst Village Hall, Hornash Lane, 5pm - 8pm