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REPRESENTATIONS TO MEDWAY COUNCIL LOCAL PLAN 2012 – 2035 Development Options Consultation Document Submitted on Behalf of The Landowners April 2017 REPRESENTATIONS TO MEDWAY COUNCIL LOCAL PLAN 2012 – 2035 Development Options Consultation Document Submitted on Behalf of The Landowners Project Ref: 25973/A5/JM/kf Status: Final Issue/Rev: 01 Date: 03 April 2017 Prepared by: Joshua Mellor Checked by: Andrew Wilford Authorised by: Andrew Wilford Barton Willmore LLP The Observatory Southfleet Road Ebbsfleet Dartford Kent DA10 0DF Tel: Ref: 25973/A5/JM/kf E-mail: Date: 03 April 2017 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of the Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. CONTENTS PAGE NO. 1.0 INTRODUCTION 01 2.0 NATIONAL PLANNING POLICY 03 i) National Policy & Plan Making 03 ii) National Policy & Housing Need 05 iii) Duty to Co-operate 05 iv) The Housing White Paper – Fixing Our Broken Housing Market (February 2017) 06 3.0 VISION AND STRATEGIC OBJECTIVES 07 4.0 DELIVERING SUSTAINABLE DEVELOPMENT - OPTIONS 08 i) Objectively Assessed Need 08 ii) Identified Supply of Development Land 08 iii) Options for Growth 09 5.0 LAND SOUTH OF SUNDRIDGE HILL, CUXTON 12 i) Site Suitability - Overall 19 6.0 CONCLUSIONS 21 APPENDICES Appendix 1: Sundridge Hill, Cuxton Location Plan. Appendix 2: Land South of Sundridge Hill – Site Proforma (Medway Council, November 2015). Appendix 3: Accessibility Appraisal (dha transport, March 2017). Appendix 4: Preliminary Ecological Appraisal (KB Ecology, March 2017). Appendix 5: Landscape and Visual Appraisal (Barton Willmore, March 2017). Introduction 1.0 INTRODUCTION 1.1 These representations are submitted on behalf of the Landowner (Mr Santok Gill) in response to Medway Council’s Local Plan 2012 – 2035 Development Options Consultation Document (MCDOCD) published in January 2017. 1.2 These representations focus on the promotion of a site known as ‘Land south of Sundridge Hill, Cuxton’ (The Site). A Site Location Plan is included at Appendix 1. 1.3 The Site comprises a single fallow field, redundant structures and single detached residential property, including associated hardstanding. Intermittent boundary vegetation, in the form of trees and hedgerows, runs along the northern boundary of the Site with the A228. The field is bound to the south by marshland and the Medway Valley railway line and to the west by a further field and an area of allotments. Residential dwellings bound the site to the north and east. 1.4 The Site forms part of a wider SLAA (Strategic Land Availability Assessment) site reference 1068 (South of Sundridge Hill, Cuxton) as identified in the Medway SLAA 2015 and 2017. The SLAA 2017 concludes that the site is unsuitable for allocation. 1.5 Notwithstanding our Clients’ specific land interests, these representations have been prepared in objective terms and in recognition of prevailing planning policy – in particular Government guidance as set out in the National Planning Policy Framework [NPPF] (March 2012) and National Planning Practice Guidance [NPPG] (March 2014). 1.6 The MCDOCD forms the first formal stage in the Local Plan’s preparation (under Regulation 18 of the Local Plan Regulations). 1.7 These representations focus on relevant matters relating to the release of the Site for residential dwellings and address the following: x Section 2 – National Planning Policy x Section 3 – Vision and Strategic Objectives x Section 4 – Delivering Sustainable Development - Options x Section 5 – Land south of Sundridge Hill, Cuxton 25973/A5/JM/kf 1 April 2017 Introduction 1.8 These representations are supported by an accompanying Accessibility Appraisal, Preliminary Ecological Appraisal and Landscape and Visual Appraisal which have been produced to demonstrates there are no overriding accessibility, ecological or landscape constraints which preclude the allocation of the Site for residential purposes, as detailed in Section 5. 25973/A5/JM/kf 2 April 2017 National Planning Policy 2.0 NATIONAL PLANNING POLICY i) National Policy & Plan Making 2.1 The NPPF (March 2012) places a strong ‘presumption in favour of sustainable development’ in all planning related matters and places a responsibility on Local Planning Authorities (LPAs) to encourage and support sustainable growth and to plan positively for new development. There are three dimensions to sustainable development in relation to the planning system as outlined in the NPPF. These include:- x an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure; x a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and x an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy. (Para. 8) 2.2 The presumption in favour of sustainable development, as set out in the NPPF should be seen as a golden thread, running through both plan-making and decision-taking. For plan-making this means that: Local Planning Authorities (LPAs) should positively seek opportunities to meet the development needs of their area; Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: – any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF taken as a whole; or – specific policies in the NPPF indicate development should be restricted. (Para. 14) 25973/A5/JM/kf 3 April 2017 National Planning Policy 2.3 LPAs should ‘submit a plan for examination which it considers is “sound” – namely that is: x Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; x Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; x Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and: x Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the NPPF. (Para. 182). 2.4 The NPPF considers that Local Plans should: x plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework; x be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date; x be based on co-operation with neighbouring authorities, public, voluntary and private sector organisations; x indicate broad locations for strategic development on a key diagram and land-use designations on a proposals map; x allocate sites to promote development and flexible use of land, bringing forward new land where necessary, and provide detail on form, scale, access and quantum of development where appropriate; x identify areas where it may be necessary to limit freedom to change the uses of buildings, and support such restrictions with a clear explanation; x identify land where development would be inappropriate, for instance because of its environmental or historic significance; and x contain a clear strategy for enhancing the natural, built and historic environment, and supporting Nature Improvement Areas where they have been identified. (Para. 157). 2.5 The NPPF directs that LPAs should use a proportionate evidence base in plan-making. LPAs should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. LPAs should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals. (Para. 158). 25973/A5/JM/kf 4 April 2017 National Planning Policy ii) National Policy & Housing Need 2.6 The NPPF (para 47) requires LPAs to use their evidence base to ensure that their Local Plan meets the full, ‘Objectively Assessed Needs’ (OAN) for market and affordable housing in the housing market area, as far as is consistent with the policies set out in the Framework, including identifying key sites which are critical to the delivery of the housing strategy over the Plan period. 2.7 LPAs should plan for a housing mix which takes into account “housing demand and the scale of housing supply necessary to meet this demand.” Household and population projections should also be a key consideration, taking into account of migration