Draft Local Plan (August 2013) – Consultee Responses Chapter 4: Setting out Our Local Plan Strategy for Swale

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Bearing Fruits 2031: draft Local Plan (August 2013) – Consultee Responses Chapter 4: Setting out our local plan strategy for Swale

Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We recognise that a key issue for the Borough in the plan period to 2031 is that of the economy and employment. Specifically, a relatively high proportion of the Borough's population commutes to places of work beyond the Borough and that furthermore, there is an under representation of higher value / skilled jobs in the Borough. We remain of the view that the Council should continue to seek to address these issues. In broad terms, out- commuting can have adverse effects upon the environment and the Swale economy. A lower-skilled workforce also means lower levels of prosperity and well-being. There are therefore clear reasons to address issues relating to the types of jobs that are available in the Borough and of out-commuting from the Borough. The Local Plan should therefore remain flexible in terms of the amount and location of land that is identified for both housing and employment development. For example, the Local Plan anticipates that Sheerness could become a major hub for the manufacture of off-shore wind turbines. The Local Plan therefore needs to be flexible to accommodate opportunities such as this, as and when they arise. Having said the above, an employment led strategy should be a means to an end. The Council's vision for Swale is ‘a sustainable, flourishing place in which to enjoy life and do business with'. If the Borough's economic circumstances remain unchanged, then there is a danger that an over-reliance on an employment- led strategy could threaten realisation of the Council's vision. We therefore consider that the Council's strategy should involve a positive approach to planning for all land uses, whilst recognising the environmental and infrastructural constraints in the Borough. We support paragraph 4.1.7 which sets out where growth will be directed, and agree that growth should be in Planner Savills (L&P) Ltd (for St Qualified Mr William Lusty LP1438 4.1 Where are we going? the most sustainable locations. We consider that this should also take place within environmental John's College, Cambridge) support constraints, and if possible, on land of the lowest agricultural environmental value. We believe, however, that this should be considered within the context of meeting housing and employment targets, and that agricultural land should not be protected where development is needed to achieve economic objectives and to maintain a good quality of life for the Borough's population. Therefore, in instances where there is an opportunity to achieve sustainable development, this should override agricultural land considerations. Whilst we support the need to create a sufficient supply of employment land in seeking to improve the Borough's economic circumstances, the Local Plan must also allow for developer choice and offer scope to accommodate opportunities as they arise and provide for the renewal of previously developed land and the delivery of existing undeveloped sites. As part of this, the Local Plan should be flexible to accommodate such opportunities when they arise. The Local Plan seeks to support a prosperous rural economy through support for existing businesses and also new businesses. However, the Local Plan states that this will not be micro-managed through the allocation of sites. We consider that this approach is not consistent with National Planning Policy Framework (NPPF), which sets out a presumption in favour of sustainable development. The NPPF confirms that for plan-making, this means local planning authorities should positively seek opportunities to meet the development needs of their area and with sufficient flexibility to adapt to rapid change. There should therefore be sufficient flexibility in the Local Plan's policies to allow for development within the rural areas to come forward, to ensure that sustainable development is not constrained by the Local Plan. I previously forwarded comments on the 'Bearing Fruits' document. Whilst attention has been paid to some points, concerns still remain for the overall strategy.

There is a definite need for more housing (of appropriate type for the existing population). However, the figure actually proposed allows a continued and significant level of inward migration. A better approach would be a targeted affordable housing policy aimed specifically at current Swale Mr Phil Johnson Objection LP209 4.1 Where are we going? residents. This would have the effect of reducing the pressure on transport and other services, i.e.

build houses for local people (working locally) rather than for extra people migrating into the borough, who may only wish to commute outside the area. By concentrating on housing for increased population by natural change (rather than inward migration) the required number of properties could be reduced.

The aim should be to enhance (in a sustainable fashion) the environment for existing companies to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

develop and grow thus improving the job prospects and quality of life for current residents.

The borough has failed to coordinate an adequate infrastructure over the last decade. How can we be certain that infrastructure will be made available for the significant increase in housing proposed. Development of the land formerly occupied by the old paper mill shows how development within the borough is poorly controlled. We have a new supermarket (Morrisons) which was certainly not urgently needed but are still waiting for the housing (urgently needed) planned for the site?

Housing development should go hand in hand with infrastructure development. Roads in the area (particularly near Key St and Stockbury roundabouts) are much overloaded. Levels of air pollution are already exceeding safe limits in some parts of the borough (Newington, Ospringe). I also have significant concerns about the availability of educational (e.g. primary school places) and health facilities (Medway Maritime has an adverse report against it) for the increased population. How will water services cope with the expected increased demand in the South East? Planned community improvements seem to revolve around an increasing number of supermarkets. Whilst these provide jobs, the vast majority are relatively low paid. Encouragement should be provided for companies to develop their skills base and provide added value to the workforce and services.

We should avoid using existing greenfield sites and in particular those being farmed. With the significant future increase in food production required (particularly on a local, low carbon footprint scale), it is important that we retain as many of these sites for agriculture. A greater awareness of the increasing value of agricultural land is required by the community so that town and country can develop in harmony. It is confirmed in the draft that in the context of economic uncertainty the Council remains ‘ambitious and must assume a longer-term 20-year view within which things will change for the better' (para 4.1.2). The need for a strategy that is able to ‘proactively drive and support sustainable economic development' is a core principle of the National Planning Policy Framework (NPPF para 17). We consider that an ambitious development strategy needs to be reflected in the Local Plan if it is to be consistent with national policy. Such a strategy must be capable of being delivered in a viable form if the plan is to be sound. In this context it is submitted that the Council should be looking to produce ambitious targets for employment and housing in order to ensure that the strategy is consistent with national guidance. The Council confirms that in order to achieve the jobs target (of 7,053) there is a need to ‘boost our supply of housing' (para 4.1.3). This is considered to be a correct response to this employment target. However, the Council does not propose to boost the supply of housing, rather it is proposed to rely on past delivery rates and it is proposed that ‘in the short to medium term (the) housing target should be close to the long term average levels of delivery'. It is proposed to set the target at some 10,800 new homes by 2031 (i.e.540 per annum net) (para 4.1.3). This is objected to as being inconsistent with a growth agenda. In addition, past delivery rates may not be relevant to the current and emerging economic position and the provision Vinson Trust - Lady Dane Farm Objection LP1337 4.1 Where are we going? of an unduly cautious strategy will not serve to meet local requirements for either housing or jobs. It is noted that this stated job target ‘will ultimately require even higher levels of housing to support it' and that ‘without them our economy will not grow in the face of other competing locations' (para 4.1.4). Under these circumstances it is likely that the proposed strategy will fail to realise the necessary scale of employment as planned for as this will be constrained by a lack of an adequate workforce. The housing target of 10,800 is therefore objected to as not being adequate to address the need for local employment within the Borough. The Council proposes to review these targets in the light of ‘clear and consistent signals of improved delivery in the housing market and the wider economy as a whole' (para 4.1.4). This is an acceptance that the initial targets are likely to be inadequate in any event. Under these circumstances we consider that the strategy is not appropriate to cater for an increase in development activity which is anticipated within the plan period. In fact the Council recognises the relationship between jobs and housing and confirms that ‘a failure to deliver in one or more areas may present unsustainable outcomes' (para 4.2.4). In the absence of an adequate supply of housing to match job creation, we consider that the strategy will be unsustainable, contrary to national guidance. It is confirmed that ‘growth will be directed to the most sustainable locations' and that these will ‘either have the facilities and services that can Object / Document Name Organisation Support Rep ID Title Consultee Response Part

support new growth or can themselves by supported by growth' (para 4.1.7). The introduction of development at locations such as Faversham is welcomed and supported as recognition of sustainability. The need to avoid environmental assets and constraints such as flood plains and areas of high agricultural land is recognised as being in line with national policy (para 4.1.8) as a matter of principle. It is accepted however that the provision of sustainable development is a balance and that the use of high quality agricultural land may be unavoidable in the most sustainable locations. In these areas there may also be a need to mitigate the impact of development on local policy considerations. This stance is supported as a pragmatic response to the need to allocate additional land in sustainable locations. In this context however, regard must be had to the impact on natural resources and the comments of bodies such as the RSPB and the Kent Wildlife Trust (KWT) should be given due weight in this assessment. We welcome the strong commitments to the protection and enhancement of Swale's environmental Conservation Officer, Policy and Miss Debbie Salmon Support LP1069 4.1 Where are we going? assets and the desire of the council to expand the range of biodiversity. We are pleased to see that Planning Kent Wildlife Trust ancient woodland and coastal habitats are now included within this protection. The Government is clear in pargraph 19 that it is committed to ensuring that the planning system does everything it can to support sustainable economic growth. An important component of this objective is delivering the housing needs of the Borough. Planning should operate to encourage and not act as an impediment to sustainable growth." Therefore significent weight should be placed on the need to support economic growth through the planning system" Mr Howard Courtley Director Courtley Consultants Ltd Objection LP366 4.1.3 Paragraph The Council are currently proposing a housing figure of 10,800 (540pa) over the period 2013 to 2031. This is some 6940 dwellings less than the Councils own housing needs assessment. Its employment target of 7053 is less than its need or potential over the plan period.

Currently the Councils draft Local Plan is failing to meet it objectively assessed development needs and is therefore unsound. We object to the housing target, which will not go far enough to meet the requirements of the borough. There is no evidence to back the approach taken. It is clear that the Council recognises c/o Tetlow King Planning Kent Objection LP1307 4.1.3 Paragraph that a higher housing target is required with specific reference made to undertaking an early review Developments UK Ltd of the Local Plan development targets. This is not considered a sustainable approach and we discuss this further below. The Council state in paragraph 4.1.4 that its housing target is well above demand arising from its "indigenous local population" but acknowledges its ambition to achieve its jobs target which "will ultimately require even higher levels of housing to support it". However the Council intend to meet this need in the longer term via a review of the Local Plan even before this one has been adopted ! Mr Howard Courtley Director Courtley Consultants Ltd Objection LP379 4.1.4 Paragraph What we have is a Council that acknowledge it has identified its housing needs over the plan period to between 12,080 (604pa) to 17,740(887pa) dwellings but will only meet a target of 10,800 dwellings. This is neither justified, effective and certainly not positively prepared. Development of Sheerness Port is mentioned and I will refer to it as we go through the paper. I believe this is overly optimistic; any port development has limited job opportunities as many of the Mr Paul Hutchinson Objection LP138 4.1.5 Paragraph operations are either automated or specialist; therefore there will be very limited opportunity for

local employment. Moreover, the port will be competing with more modern and larger deep water facilities in the Thames Estuary. CPRE Protect Kent objects most strongly to the identification of ‘Areas of Future Change’. We consider that giving commitment now to undefined development in these locations for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. We can find no support in the National Planning Policy Mr Brian Lloyd Senior Planner Protect KENT Objection LP851 4.1.5 Paragraph Framework for this approach. If these locations offer development potential that the Council will be pursuing during the Plan period, even if development is not envisaged during the Plan period itself (though at paragraph 6.8.18 there is a clear suggestion that development will progress at the Kent Science Park early in the Plan period), then the Plan should put forward policies setting out the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

development potential to provide the context for subsequent work. This will also provide the opportunity for people to comment on the suitability of these sites for future development as envisaged by the Council and for the sites to be explored in detail at the Examination in Public. The approach taken in the Draft Plan deprives people of this opportunity and promotes ‘back door’ planning. It predetermines that these locations will be developed without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the locations are identified as ‘Areas of Future Change’ in this Plan will be used as justification for their development in principle in future plans even though for this Plan no evidence would have been tested to endorse their development potential. Consequently, the Council should remove all references in the Plan to the Areas of Future Change in the Plan and present site specific policies that clearly set out the Council’s intentions for the areas together with the necessary supporting evidence if progress with development is envisaged during the Plan period. NOTE: These representations are submitted on behalf of the Peel Group, which includes Peel Land & Property (Ports) Limited and Peel Ports.

This paragraph states that Swale Borough Council are ‘ setting down some direction for the future Peel Group Support LP406 4.1.5 Paragraph of key areas like the Port of Sheerness...together with longer term infrastructure needs, where the

detail for the way forward is not yet sufficiently clear for them to be central to our strategy .'

Peel Group welcomes this approach and confirms it is keen to work with Swale Borough Council to develop a strategy in the relation to the future of the Port of Sheerness. To the list of important (national) environmental assets add “high quality agricultural land,” after “dry Mr Brian Lloyd Senior Planner Protect KENT Objection LP855 4.1.6 Paragraph valleys,” as the Plan recognises that high quality agricultural land is an important national resource which needs to be safeguarded ( e.g. in para 4.2.63) so recognition here will endorse that view. Paragraph 4.1.6 refers to protecting and enhancing important environmental assets as well as David Hammond Natural England Support LP1558 4.1.6 Paragraph expanding biodiversity within the area, this is to be welcomed and encouraged.

CPRE Protect Kent generally agree with the approach to development advocated here. However, Qualified we would wish to see a commitment to the use of previously developed land as a priority. We would Mr Brian Lloyd Senior Planner Protect KENT LP856 4.1.7 Paragraph support wish to see the following added to the end of the first sentence: “with priority given to the use of previously developed land.” Development stages p.30: MPC strongly opposes the inclusion of 4.1.7 (5) to allow SBC to focus on Parish Clerk Minster-on-Sea Parish Mrs Trish Codrington Objection LP260 4.1.7 Paragraph the development of the open countryside. Removing point (5) will ensure that the Borough Council Council continues to safeguard this important amenity. These are the holding comments from Newington Parish Council until the full council meeting on the 1 st October.

Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Mention is made of growth in the Sheerness, Queenborough, Minster triangle. The current infrastructure cannot support this growth; while there is space and potential at the Queenborough/Rushenden sites, the Sheerness, Mister & Halfway areas are constrained by aged Mr Paul Hutchinson Objection LP139 4.1.7 Paragraph infrastructure with limitations on development: narrow, unmade and congested roads, old (but

habitable) buildings. The current development at Thistle Hill, with little or no regard to adjoining infrastructure, clearly illustrates the constraints there are in this area. The local infrastructure is not a consideration; it is a constraint and should therefore be afforded the degree of planning required. Growth will be directed to the most sustainable locations that we can find and, in so far as it is compatible with this objective, on land of lowest environmental value. We are concentrating on regeneration sites and at locations that either have the facilities and services that can support new growth or can themselves be supported by growth. Development, will therefore be steered in reducing scales of focus at:

• Sittingbourne; followed by • Faversham and Sheerness, the latter part of a triangle of settlements with and supported by Queenborough/Rushenden and Minster/Halfway; followed by • rural local service centres – Iwade, Newington, Eastchurch, Leysdown, Teynham and Boughton; followed by Owner of land at Funton Bloomfields Ltd Objection LP1462 4.1.7 Paragraph • Brickworks the villages with built-up area boundaries; and followed by • the open countryside.

This paragraph applies a sequential approach to the location of development. However, it fails to recognise that some sites, such as rural brownfield land, do not fit neatly into the above hierarchy. Such sites should be recognised in order to reflect the more positive approach embodied in the National Planning Policy Framework (the Framework) – paragraphs 17 and 111 et al refer. Paragraph 51 of the Framework also encourages Local Planning Authorities to accept changes of use of commercial buildings to residential. This approach is not reflected in the above paragraph – which could otherwise preclude such forms of rural development and which would be contrary to fundamental principles embodied in the Framework.

Locations for Development It is confirmed that ‘growth will be directed to the most sustainable locations' and that these will ‘either have the facilities and services that can support new growth or can themselves by supported by growth' (para 4.1.7). The introduction of development at locations such as Minster is welcomed and supported as recognition of sustainability. The need to avoid environmental assets and constraints such as flood plains and areas of high agricultural land is Mr Philip Aelen S W Attwood & Partners Support LP824 4.1.7 Paragraph recognised as being in line with national policy (para 4.1.8) as a matter of principle. It is accepted however that the provision of sustainable development is a balance and that the use of high quality agricultural land may be unavoidable in the most sustainable locations. In these areas there may also be a need to mitigate the impact of development on local policy considerations. This stance is supported as a pragmatic response to the need to allocate additional land in sustainable locations.

We agree with the text - that growth will be directed to the most sustainable location with a focus on regeneration sites and at locations that either have the facilities and services that can support new Mr Neil Flanagan Support LP540 4.1.7 Paragraph growth or can themselves be supported by growth. We agree that Faversham sits below Sittingbourne in the Hierarchy proposed. We agree with the text - that growth will be directed to the most sustainable location with a focus on regeneration sites and at locations that either have the facilities and services that can support new Ordnance Wharf Support LP586 4.1.7 Paragraph growth or can themselves be supported by growth. We agree that Faversham sits below Sittingbourne in the Hierarchy proposed. We agree with the text - that growth will be directed to the most sustainable location with a focus on Gibb Femco Support LP671 4.1.7 Paragraph regeneration sites and at locations that either have the facilities and services that can support new

growth or can themselves be supported by growth. We agree that Faversham sits below Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Sittingbourne in the Hierarchy proposed. We agree with the text - that growth will be directed to the most sustainable location with a focus on regeneration sites and at locations that either have the facilities and services that can support new Mr Michael White Support LP631 4.1.7 Paragraph growth or can themselves be supported by growth. We agree that Faversham sits below Sittingbourne in the Hierarchy proposed. These are the holding comments from Newington Parish Council until the full council meeting on the 1 st October.

Newington historically has been a large village with good services and in the past would have been classed as Rural Local Service Centre. This is when it had a doctor's surgery, a choice of shops, three pubs and a social club, plus a half-hourly train service when over 50% of services stopped, M Harris Newington Parish Council Objection LP458 4.1.8 Paragraph and a road asset in the A2. It no longer has any health facilities; it is left with one pub and one shop. Now only 25% of trains stop at the village, and the main road has gone from being an asset to a problem. Very few people come to Newington from surrounding villages for any services except for a few using the station - and that is primarily because the station car park is free and there are no parking restrictions in the surrounding streets. Even these numbers are decreasing, as services from Newington are continually being cut. It is now no more than a large village that is located on a major road and has a railway line running through it. It should be moved from a rural local service centre to a village with built-up area boundaries. Swale BC accepts that compromises might be needed when meeting infrastructure needs, green building standards, and that higher housing targets may trigger the need for new infrastructure Principal Planning Officer Kent which may not be achievable. KCC Property feel this could indicate a reduced level of income from Miss Elizabeth Shier County Council (Planning and Objection LP1165 4.1.9 Paragraph S106 / CIL agreements and a resulting need for other funding to achieve community facilities. This Environment) may affect KCC’s ability to provide suitable community infrastructure in the right place at the right time. KCC are pleased to see that the draft strategy recognises the Borough’s “coastal habitats, Principal Planning Officer Kent downland, dry valleys, ancient woodlands and its historic assets above and below ground.” The Miss Elizabeth Shier County Council (Planning and Support LP1166 4.1.9 Paragraph variety of heritage assets in the Borough is among its most distinctive qualities. They will be crucial Environment) in its future prosperity and will be important elements in future regeneration projects. CPRE Protect Kent generally support this section, though we have a number of points which we make in response to specific paragraphs. However, one aspect of sustainable development that seems to be absent is the need to ensure that the character and identity of individual settlements is Qualified Achieving sustainable retained. This is particularly the case with the rural communities, and a key aspect in securing this is Mr Brian Lloyd Senior Planner Protect KENT LP857 4.2 support development in Swale to ensure that the gaps between settlements are retained. This is an important component of the spatial strategy in the currently adopted Local Plan. Therefore we strongly urge the Council to keep this in the new Plan and to continue to identify vulnerable gaps on the Policies Map as in currently done by saved Local Plan Policy E7. I question the use of the phrase sustainable development. Sustainability must mean that the local plan strives to ensure:

1) that rural areas remain rural Qualified Achieving sustainable Mr Simon Taylor LP68 4.2 2) that rural boundaries are maintained specifically between the west of Swale and the Medway support development in Swale Towns

3) that unauthorised developments are not permitted nor granted retrospectively.

I would like a greater commitment to the preserving the rural features of our area It should be noted by the council that para 119 of the Framework sets out that, ‘the presumption in c/o Tetlow King Planning Kent Objection LP1308 4.2.2 Paragraph favour of sustainable development (paragraph 14) does not apply where development requiring Developments UK Ltd appropriate assessment under the Birds or Habitats Directives is being considered, planned or Object / Document Name Organisation Support Rep ID Title Consultee Response Part

determined’. This will apply to a number of the proposed allocations and significantly, therefore, the presumption in favour referred to this in paragraph would not be applicable. The Council's adoption of the presumption in favour of sustainable development is supported, as is Klaire Lander (DHA) Owner of land at Support LP75 4.2.2 Paragraph the statement that the Council will approve applications without delay which accord with the policies Parsonage Farm, Newington of the Local Plan. The Council's adoption of the presumption in favour of sustainable development is supported, as is Owner of land at Cellar Hill, Teynham Support LP85 4.2.2 Paragraph the statement that the Council will approve applications without delay which accord with the policies

of the Local Plan. Para 4.2.4 is not consistent with the NPPF. Sustainable development does not mean, in addition to positive growth, that some proposals will need to be restricted or the scale and pace of growth reviewed and adjusted. The Framework is clear in para 9 that sustainable development involves seeking positive improvements in the quality of the building natural and historic environment, as well as in people’s quality of life. All these aspects are considered together. Para 10 of the Framework confirms that plans and decisions need to take local circumstances into account, so that they respond to the different opportunities for achieving sustainable development. This obviously will be c/o Tetlow King Planning Kent Objection LP1309 4.2.4 Paragraph reflected in an appropriate scale and growth. The only reference in the Framework to restricting Developments UK Ltd development is where it relates to sites under the Birds and Habitats Directives and/or designated SSI, Green Belt, AONB etc. This paragraph 4.2.4 should be rephrased so that it accurately takes account of achieving sustainable development.

As above we do not agree with the approach of a review of the Local Plan. The Plan should be at this stage in a position where it can meet objectively assessed needs in both housing and the economy. Although Swale are not the education authority the themes should also include education: Swale does not have any higher education colleges or Universities in the administrative boundary but perhaps a centre of excellence should be a consideration, may be around the industries of wind Mr Michael Lorkins Objection LP232 4.2.7 Paragraph power and located in Sheerness of in Science and based in the Science park promoting education and apprenticeships. There is also scope to include a business start-up units or a University Technical College at these sites. KCC welcome the commitment in the document to the development of a Heritage Strategy for Swale. This would help ensure that the local plan conforms with the NPPF. KCC has worked with Principal Planning Officer Kent Dover District Council to write a Heritage Strategy for Dover, is about to work with Thanet District Miss Elizabeth Shier County Council (Planning and Support LP1171 4.2.7 Paragraph Council to prepare a similar strategy, and is in discussion regarding a Heritage Strategy for Environment) Shepway. A Heritage Strategy for Swale should be a high priority and would be happy to discuss how KCC might contribute to its preparation. We understand the need to build a strong economy within Swale. We would however have reservations regarding large scale expansion of the Kent Science Park if it were to lead to the loss of or have indirect impacts on the sensitive ancient woodland habitats surrounding the site. In the Conservation Officer, Policy and Miss Debbie Salmon Objection LP1071 4.2.9 Paragraph case of the Port of Sheerness, Kent Wildlife Trust is unlikely to support expansion that involved land Planning Kent Wildlife Trust reclamation from the sea, as proposed in public consultations, as this would be likely to impact on coastal processes throughout the North Kent coast and could lead to significant impacts on the Natura 2000 and Ramsar network. A core planning priniciple set out in the NPPF is "Building a strong economy " This requires local planning authorities to have a clear understanding of business needs within the economic markets operating in and across their area"(para 160 and 161). This requires working together with county and neighbouring authoties and Local Enterprise Partnerships to prepare and maintain a robust Mr Howard Courtley Director Courtley Consultants Ltd Objection LP370 4.2.11 Paragraph base to understand both existing business needs and likely changes in the market. This should include working closely with the business community to understand their changing needs and identify and address barriers to investment, including a lack of housing, infrastructure or viability. We don't believe a proportionate evidence base is available to ensure delivery of the above. This makes the draft Local Plan therefore unsound. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Mr Neil Flanagan Support LP541 4.2.13 Paragraph We agree that Faversham has strong potential to diversify its economy around tourism.

Ordnance Wharf Support LP587 4.2.13 Paragraph We agree that Faversham has strong potential to diversify its economy around tourism.

Gibb Femco Support LP672 4.2.13 Paragraph We agree that Faversham has strong potential to diversify its economy around tourism.

In paragraph 4.2.13, we support the concept of tourism based on integration of the environmental and heritage offer in and around the town to bring in spending for short breaks and day trips and that a further important aspect of tourism potential is local food and drink. These aspects are already being promoted through walking trails and leaflets and the marketing of the town through Faversham Enterprise Partnership, the Town Council and the Faversham Society itself. These Anne Salmon Faversham Society Support LP1373 4.2.13 Paragraph initiatives are already helping local businesses and encouraging people to think about moving to the town and are what the Society suggested in the initial consultations on Issues and Options for the Plan. We support the concept that heritage-led decision making is central to the future of Faversham as a 21 st century small and compact market town and port and that an important element of this is the conservation and enhancement of the historic environment. We support the set of approaches to decision making set out in section 4.2.76 items 1-8. Mr Michael White Support LP632 4.2.13 Paragraph We agree that Faversham has strong potential to diversify its economy around tourism.

NOTE: These representations are submitted on behalf of the Peel Group, which includes Peel Land & Property (Ports) Limited and Peel Ports.

This paragraph states that ‘ There may also be the long term potential to expand the Port so as to Qualified free up its historic heart for regeneration, but there are considerable technical and environmental Peel Group LP408 4.2.18 Paragraph support challenges that need to be tackled '

Peel Group would welcome dialogue with Swale BC, to discuss the potential long term potential to expand the Port. Peel Group is in the early stages of producing a Masterplan for the Port of Sheerness and will be opening dialogue with Swale BC regarding this. It is acknowledged that there is only planning permission for such a facility but no actual manufacturer or indications of one, so why mention this; it provides false optimism. Moreover, I believe you will find there is already a wind turbine manufacturing facility in Belfast docks; therefore, Mr Paul Hutchinson Objection LP140 4.2.18 Paragraph the statement ‘currently the only one in the UK' is false. Such misleading statements call into question the credibility of the plan. Optimism is to be applauded but it needs to be supported by evidence not speculation. CPRE Protect Kent objects most strongly to the identification of ‘Areas of Future Change'. We consider that giving commitment now to undefined development in these locations for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. We can find no support in the National Planning Policy Framework for this approach. If these locations offer development potential that the Council will be pursuing during the Plan period, even if development is not envisaged during the Plan period itself (though at paragraph 6.8.18 there is a clear suggestion that development will progress at the Kent Science Park early in the Plan period), then the Plan should put forward policies setting out the development potential to provide the context for subsequent work. This will also provide the opportunity for people to comment on the suitability of these sites for future development as Mr Brian Lloyd Senior Planner Protect KENT Objection LP852 4.2.18 Paragraph envisaged by the Council and for the sites to be explored in detail at the Examination in Public. The approach taken in the Draft Plan deprives people of this opportunity and promotes ‘back door' planning. It predetermines that these locations will be developed without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the locations are identified as ‘Areas of Future Change' in this Plan will be used as justification for their development in principle in future plans even though for this Plan no evidence would have been tested to endorse their development potential. Consequently, the Council should remove all references in the Plan to the Areas of Future Change in the Plan and present site specific policies that clearly set out the Council's intentions for the areas together with the necessary supporting Object / Document Name Organisation Support Rep ID Title Consultee Response Part

evidence if progress with development is envisaged during the Plan period. CPRE Protect Kent objects most strongly to the identification of ‘Areas of Future Change'. We consider that giving commitment now to undefined development in these locations for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. We can find no support in the National Planning Policy Framework for this approach. If these locations offer development potential that the Council will be pursuing during the Plan period, even if development is not envisaged during the Plan period itself (though at paragraph 6.8.18 there is a clear suggestion that development will progress at the Kent Science Park early in the Plan period), then the Plan should put forward policies setting out the development potential to provide the context for subsequent work. This will also provide the opportunity for people to comment on the suitability of these sites for future development as Mr Brian Lloyd Senior Planner Protect KENT Objection LP853 4.2.19 Paragraph envisaged by the Council and for the sites to be explored in detail at the Examination in Public. The approach taken in the Draft Plan deprives people of this opportunity and promotes ‘back door' planning. It predetermines that these locations will be developed without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the locations are identified as ‘Areas of Future Change' in this Plan will be used as justification for their development in principle in future plans even though for this Plan no evidence would have been tested to endorse their development potential. Consequently, the Council should remove all references in the Plan to the Areas of Future Change in the Plan and present site specific policies that clearly set out the Council's intentions for the areas together with the necessary supporting evidence if progress with development is envisaged during the Plan period. NOTE: These representations are submitted on behalf of the Peel Group, which includes Peel Land & Property (Ports) Limited and Peel Ports.

This paragraph states that in the longer term, the town centre of Sheerness and its future seaside, maritime and historic prosperity may be inexorably tied to the success of its Port where its rejuvenation will be expected to benefit the town centre and adjoining areas as well.'

The rejuvenation of the Port is an aspiration which Peel Group is looking to achieve over the next Qualified Peel Group LP409 4.2.24 Paragraph 20-25 years. The Port of Sheerness Masterplan will outline the strategy for this. The comments support within Paragraph 4.2.24 place an expectation on the Port, to assist in the rejuvenation of the town of Sheerness. Peel Group is committed to working with stakeholders to assist with increasing investment in Sheerness. However, this investment and rejuvenation will, in our view, require the expansion of the Port. Peel Group would hope to work closely with Swale BC to achieve the objectives detailed above. As such, Peel Group recommends the following text to be included at the end of Paragraph 4.2.24:

‘ The Council will work closely with the Port of Sheerness and other key stakeholders to support its rejuvenation .' We note that tourism is to be encouraged within the AONB, the North Kent Marshes and the Blean. As all these areas contain designations of international importance we would advise that predicted increases in tourism are assessed within the strategic HRA, to ensure no impact on the integrity of Conservation Officer, Policy and the sites either individually or in-combination with other development proposed. We welcome the Miss Debbie Salmon Objection LP1072 4.2.25 Paragraph Planning Kent Wildlife Trust work being untaken to formulate a Sustainable Access, Management and Monitoring Strategy for the North Kent Marshes which should alleviate increases in impact. In relation to the Blean impacts will need to be assessed along with impacts from development and tourism proposed within Canterbury District. We welcome the commitment to a Local Transport Strategy and the promotion of alternative modes of transport. As stated within previous consultations Kent Wildlife Trust would have reservations Conservation Officer, Policy and Miss Debbie Salmon Objection LP1073 4.2.28 Paragraph regarding construction of a Southern Relief Road due to the sensitivity of the surrounding Planning Kent Wildlife Trust countryside and would object to these proposals unless it could be shown that the proposed route had no impact on the ecological habitats within the area either directly through loss of habitat or Object / Document Name Organisation Support Rep ID Title Consultee Response Part

indirectly via pollution, nitrogen deposition or increase recreational pressure.

This statement provides suspicion of penalizing car users. SBC accepts there are public transport constraints and also acknowledges that the area is a ‘dormitory area' where the majority of Mr Paul Hutchinson Objection LP141 4.2.29 Paragraph residents work outside of the region; therefore, to hint at penalizing car users is alarming. More clarity is required rather than a ‘throw-away line'. CPRE Protect Kent objects most strongly to the identification of ‘Areas of Future Change'. We consider that giving commitment now to undefined development in these locations for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. We can find no support in the National Planning Policy Framework for this approach. If these locations offer development potential that the Council will be pursuing during the Plan period, even if development is not envisaged during the Plan period itself (though at paragraph 6.8.18 there is a clear suggestion that development will progress at the Kent Science Park early in the Plan period), then the Plan should put forward policies setting out the development potential to provide the context for subsequent work. This will also provide the opportunity for people to comment on the suitability of these sites for future development as Mr Brian Lloyd Senior Planner Protect KENT Objection LP854 4.2.32 Paragraph envisaged by the Council and for the sites to be explored in detail at the Examination in Public. The approach taken in the Draft Plan deprives people of this opportunity and promotes ‘back door' planning. It predetermines that these locations will be developed without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the locations are identified as ‘Areas of Future Change' in this Plan will be used as justification for their development in principle in future plans even though for this Plan no evidence would have been tested to endorse their development potential. Consequently, the Council should remove all references in the Plan to the Areas of Future Change in the Plan and present site specific policies that clearly set out the Council's intentions for the areas together with the necessary supporting evidence if progress with development is envisaged during the Plan period. Again a throw-away statement that any impact to the transport system as a result of growth will be mitigated and the general methods of mitigation are shallow and are not necessarily reflected in some of the development plans highlighted later in the document. From a local perspective, on the Mr Paul Hutchinson Objection LP142 4.2.33 Paragraph negative the Thistle Hill has placed an unacceptable burden on local infrastructure and this will only get worse with future development plans in the Halfway/Minster area. Whereas the Rushenden By- pass will provide significant mitigation if and when this area is fully developed. We agree that the Plan’s strategy is intended to support the objectives of the Council’s Housing Mr Neil Flanagan Support LP542 4.2.36 Paragraph Strategy by, amongst other things, increasing housing supply. We agree that the Plan’s strategy is intended to support the objectives of the Council’s Housing Ordnance Wharf Support LP588 4.2.36 Paragraph Strategy by, amongst other things, increasing housing supply. We agree that the Plan’s strategy is intended to support the objectives of the Council’s Housing Gibb Femco Support LP673 4.2.36 Paragraph Strategy by, amongst other things, increasing housing supply. We agree that the Plan’s strategy is intended to support the objectives of the Council’s Housing Mr Michael White Support LP633 4.2.36 Paragraph Strategy by, amongst other things, increasing housing supply. The Council recognises that if it is possible to secure housing development of a scale that is in excess of the average achieved over the last 10 years this can trigger a Local Plan Review, (para 4.2.37) with presumably the objective of increasing the numbers to suit. This position means that Mr Philip Aelen S W Attwood & Partners Objection LP825 4.2.37 Paragraph the proposed strategy is not however responsive to changing circumstances and is unable to adapt to rapid changes as required (NPPF para 14). We consider that this reliance on an early review of the plan is an indication that it is deficient and fails to incorporate sufficient flexibility. Para 4.2.37 is not in keeping with the NPPF. Para 47 of the Framework is specific in that the LPAs c/o Tetlow King Planning Kent should ‘use their evidence base to ensure their Local Plan meets the full, objectively assessed Objection LP1310 4.2.37 Paragraph Developments UK Ltd needs for market and affordable housing in the housing market area, as far as is consistent with the policies sets out in this Framework’ Object / Document Name Organisation Support Rep ID Title Consultee Response Part

The Council recognises that if it is possible to secure housing development of a scale that is in excess of the average achieved over the last 10 years this can trigger a Local Plan Review, (para 4.2.37) with presumably the objective of increasing the numbers to suit. This position means that Vinson Trust - Lady Dane Farm Objection LP1338 4.2.37 Paragraph the proposed strategy is not currently responsive to changing circumstances and would be unable to adapt to rapid changes as required (NPPF para 14). We consider that this reliance on an early review of the plan is an indication that it is deficient and fails to incorporate sufficient flexibility. We support the acknowledgement that new housing is needed for economic, demographic and Mr Neil Flanagan Support LP543 4.2.37 Paragraph housing need based reasons. We support the acknowledgement that new housing is needed for economic, demographic and Ordnance Wharf Support LP589 4.2.37 Paragraph housing need based reasons. We support the acknowledgement that new housing is needed for economic, demographic and Gibb Femco Support LP674 4.2.37 Paragraph housing need based reasons. We support the acknowledgement that new housing is needed for economic, demographic and Mr Michael White Support LP634 4.2.37 Paragraph housing need based reasons. The is an important part of a development being given planning permission or not. Bad quality Mr Michael Lorkins Support LP234 4.2.45 Paragraph design will reflect on the town for years to come. Conservation Officer, Policy and We welcome the commitment to a Green Infrastructure Strategy within this section and the Miss Debbie Salmon Support LP1074 4.2.47 Paragraph Planning Kent Wildlife Trust enhancement of the green infrastructure. Indicates SBC will seek co-location of services and activities through dual use of schools, sports and playing pitches. Will protect viable services if faced with demand for alternative uses. KCC would draw the Council's attention to the issue that safeguarding issues on school sites means that Principal Planning Officer Kent Qualified playing fields at schools cannot be made public space. It may, however, be possible to create Miss Elizabeth Shier County Council (Planning and LP1169 4.2.53 Paragraph support community agreements for some sports facilities to enable greater use to be made out of hours Environment) where there is demand. In other types of building KCC would seek actively to work with Swale BC to ensure opportunities for joint working and location are fully explored.

The text rightly identifies Swale’s coast as an essential resource that will need careful management. In considering the use and protection of the coast it should be remembered that Swale possesses many hundreds of structures and archaeological sites along its coastline. Recent Rapid Coastal Zone Assessment surveys carried out by Wessex Archaeology along most of the Swale coastline Principal Planning Officer Kent recorded hundreds of sites, many previously unknown. The heritage assets along the coast of Miss Elizabeth Shier County Council (Planning and Support LP1167 4.2.59 Paragraph Swale range from Roman salt and pottery kilns to post-medieval forts and defences and Second Environment) World War structures and have the potential to contribute significantly to the Borough through tourism trails and as elements of local character. Many of these sites are highly vulnerable, however, and could easily be damaged or destroyed by coastal works. Kent County Council’s Heritage Conservation team should be consulted on any proposals that could impact on the coastal zone. CPRE Protect Kent supports these initiatives, but we consider that a major contribution to future energy security and reducing carbon emissions can be secured by seeking the inclusion of micro- renewable energy initiatives as part of development, for example by the inclusion of solar panels on Qualified Mr Brian Lloyd Senior Planner Protect KENT LP860 4.2.60 Paragraph buildings as a prerequisite for any new development. This, we believe, would be far more effective support and sustainable in meeting the challenges of future energy security than large-scale freestanding solar farms and wind farms in the open countryside which currently seem to be the preferred approach. The Energy opportunities Map should not guide the strategy without clear indication of constraints. The Kent Downs AONB has produced a ‘Renewable Energy Position Statement' and supporting ‘Companion Report'. The purpose of this statement is to provide a clearly articulated position for the Mrs Jennifer Bate Planning Officer Kent Downs AONB Objection LP507 4.2.62 Paragraph Kent Downs AONB partnership with regards to renewable energy technologies. http://www.kentdowns.org.uk/guidance-management-and-advice/renewable-energy1 . The Kent Downs AONB is a major constraint on wind turbines and ‘Solar Farms' and the statement in para Object / Document Name Organisation Support Rep ID Title Consultee Response Part

4.2.62 could be misinterpreted to indicate that the Kent Downs AONB is an area of unrestrained opportunity. The map 7.7.1 needs clarification to indicate that the mapped SSSIs and AONB represent potential constraints to some types of renewable energy developments.

Suggest change wording to include mention of the KDAONB Position Statement and indicate that the opportunities map only indicates where there is potential for generating energy subject to the LP policies. Add the following to the end of the first sentence: “as well as ensuring that the tranquillity of our Mr Brian Lloyd Senior Planner Protect KENT Objection LP861 4.2.64 Paragraph countryside and open spaces is preserved.” Principal Planning Officer Kent Need to include enhancements for development sites, developments should not only retain and Miss Elizabeth Shier County Council (Planning and Objection LP1170 4.2.64 Paragraph mitigate for biodiversity they should also ensure enhancements are included within proposed Environment) development sites. Paragraphs 4.2.64 to 4.2.82 make reference to conserving, enhancing and creating more robust ecological and landscape structures, this is to be welcomed and encouraged. Also welcomed is the David Hammond Natural England Support LP1559 4.2.64 Paragraph reference to the Kent Downs Area of Outstanding Natural Beauty (AONB).

The KDAONB supports the sequential approach of developing previously developed land first. Qualified Mrs Jennifer Bate Planning Officer Kent Downs AONB LP508 4.2.68 Paragraph However 'viability' needs qualification. Viability should not be determined by comparison to the support development of more easily developed sites, such as greenfield sites. Paragraph 4.2.71 in relation to “achieving a net gain on biodiversity” is especially welcomed. Also welcomed is the reference to achieving sustainable development, paragraph 4.2.80, which is in line David Hammond Natural England Support LP1560 4.2.71 Paragraph with our previous comments.

Kent Wildlife Trust welcomes the commitment to maintaining and enhancing biodiversity, the production of a Green Infrastructure Plan and the incorporation of biodiversity within new development contained.

We also welcome and applaud the commitment to adequately compensate for habitats lost within development using biodiversity offsetting to provide landscape scale projects within the Biodiversity Opportunity Areas. Kent Wildlife Trust supports Biodiversity Offsetting in principal but feels it should only be used for residual impacts that cannot be compensated on site and should not lead to the loss of important habitats, designated sites or the requirement to provide Green Infrastructure. We have long felt that development does not adequately compensate for impact presently and Biodiversity Offsetting provides a mechanism under which there can be no net loss and possibly a Conservation Officer, Policy and Qualified Miss Debbie Salmon LP1075 4.2.72 Paragraph net gain to ecology. Planning Kent Wildlife Trust support Due to the quantum of development proposed within Swale, the significant areas of the borough, covered by designations and the alternative natural open space and habitat enhancement and creation likely to be required to mitigate Swale's impact on internationally, nationally and locally designated sites and compensate for direct loss, caution is required when proposing land be offered to other Local Authorities to mitigate wildlife impacts. Kent Wildlife Trust has reservations regarding offsets being located too far from impact and feels that ideally offsets should be provided in the district that has experienced the loss. There is a danger that if offsets are provided miles away from impacts, areas will become ecologically less diverse, with species distributions being limited. Biodiversity Offsetting within the estuarine habitats outside the district of impact may be appropriate as the SPAs are contiguous. As this paragraph is described as portraying "the breadth of Swale's historic environment' it should Principal Planning Officer Kent be more comprehensive and should be amended as follows: The breadth of Swale's historic Miss Elizabeth Shier County Council (Planning and Objection LP1172 4.2.75 Paragraph environment reflects prehistoric, Roman, early medieval and medieval legacies, our naval and Environment) maritime history and our industrial and agricultural past. For the following reasons, it is central to delivering our Local Plan Vision and the sense of place and uniqueness of different parts of the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Borough The current text overplays the role of the pilgrim and coaching routes in the origins of Sittingbourne. It might be more accurate to say: Sittingbourne exists because of its strategic location on Roman Watling Street, the road between London and Canterbury and by Milton Creek. It also played an important role as a staging post on the pilgrim and coaching routes. Conservation and regeneration will be needed to maintain the vitality and character of the town. Objective 1 - Support As Swale's heritage has a role to play in all the themes identified and identifying this role clearly (presumably in the Heritage Strategy) will help ensure that it can play its role fully. Objective 2 -This policy could be re-written to be made clearer. The ‘broad sweep' implies trying to get a feel for the Borough's assets whereas the ‘strategic level heritage assets' sounds like only the most important ones? Objective 3 - Support, KCC has produced a series of historic town surveys - ‘Archaeology and Historic Towns' that can help to identify historic structures and archaeologically sensitive areas of towns as well as the historic patterns of development. Within Swale surveys exist for Faversham, Milton Regis, Queenborough, Sittingbourne and Sheerness and these can be supplied to SBC. At the smaller scale English Heritage, Kent Downs AONB and Kent County Council have recently produced guidance on historic farmsteads that will help planning Principal Planning Officer Kent authorities judge the appropriateness of new development in rural locations. For historic landscapes Qualified Miss Elizabeth Shier County Council (Planning and LP1173 4.2.76 Paragraph the Historic Landscape Characterisation Survey (2001) provides an important tool for understanding support Environment) the time-depth and historic character of Kent's countryside. It is important to note, however, that the characterisation is only appropriate for broad-brush consideration. For the ‘detailed planning levels' referred to in the text more focused and detailed assessment on a site by site basis will be needed KCC would be happy to discuss this further. Objective 4 - Support although the words "will be written" should be added after the word "policies". Objective 5 - Support Objective 6 - Support Objective 7 - Support - A Local List of Heritage Assets would be an invaluable tool for helping to conserve those assets of particular importance to the character of the Borough even when the assets are not nationally designated. Tunbridge Wells Borough Council have recently produced an SPD on Local Heritage Assets that could serve as a useful template. KCC are happy to discuss it further. Objective 8 - SupportFor clarity it is suggested that replacing the word "will" with "to". We support the concept that heritage-led decision making is central to the future of Faversham as a 21 st century small and compact market town and port and that an important element of this is the Anne Salmon Faversham Society Support LP1374 4.2.76 Paragraph conservation and enhancement of the historic environment. We support the set of approaches to decision making set out in section 4.2.76 items 1-8. Suggest adding' the setting' to 10a. The Local policy guidance provided later in this consultation Qualified Delivering sustainable Mrs Jennifer Bate Planning Officer Kent Downs AONB LP509 Policy ST 1 document covers the setting of the Kent Downs AONB 10a '...... for the Kent Downs AONB and its support development in Swale setting... CPRE Protect Kent generally support this Policy, but we would wish to see the following changes: In the opening sentence remove the words "all parties and development proposals shall" and replace with "the Borough Council will ensure that development proposals" . As is done in point 4, it would be useful to add a cross reference to the appropriate ‘ST' and/or ‘CP' policy that will achieve the objective listed. In point 1 delete all after "local firms" . Add an additional point after Qualified Delivering sustainable point 4 as follows: "Protect the individual character, identity and setting of settlements and the Mr Brian Lloyd Senior Planner Protect KENT LP862 Policy ST 1 support development in Swale retention of separation between them by the identification of important countryside gaps that will be protected from inappropriate development;" Amend point 5 to read as follows: " Locations outside the built-up area boundaries shown on the Policies Map the intrinsic value, beauty and tranquillity of the countryside will be protected and where possible enhanced. Isolated homes ..." In point 11, amend the start of the sentence to read: "Conserve and enhance the historic environment, in particular features characteristic of and/or unique in Swale, by applying national policy..." . The Local Plan is required to contain a discrete policy expressly reflecting the provisions of the C/O Clifford Thurlow Terance Butler Qualified Delivering sustainable MR John Rees LP442 Policy ST 1 National Planning Policy Framework that there will be a presumption in favour of sustainable Limited support development in Swale development. The local Plan does not contain such a discrete policy. Conservation Officer, Policy and Qualified Delivering sustainable This is an excellent policy which is likely to protect and enhance the ecological value of the Miss Debbie Salmon LP1077 Policy ST 1 Planning Kent Wildlife Trust support development in Swale borough. We welcome the commitment to green infrastructure, the protection afforded to the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

internationally, nationally and locally designated sites, the commitment to landscape scale enhancement within the BOAs and the remediation of pollution. It is likely the larger sites to require areas of natural open space, rather than landscaping as implied within the policy. To strengthen the policy further commitment could be made to the preservation of natural resources and improvement of water and air quality. Policy ST1 is a critical policy which sets out the approach of Swale to sustainable development and Qualified Delivering sustainable is important in the context of the National Planning Policy Framework. The policy is a portmanteau Anne Salmon Faversham Society LP1375 Policy ST 1 support development in Swale with many aspects and it may prove difficult to show how any scheme is either fully supportable or contrary to the policy. The key diagram is noted. Scale of Development It is confirmed in the draft that in the context of economic uncertainty the Council remains ‘ambitious and must assume a longer-term 20-year view within which things will change for the better' (para 4.1.2). The need for a strategy that is able to ‘proactively drive and support sustainable economic development' is a core principle of the National Planning Policy Framework (NPPF para 17). We consider that an ambitious development strategy needs to be reflected in the Local Plan if it is to be consistent with national policy. In this context it is submitted that the Council should be looking to produce ambitious targets for employment and housing in order to ensure that the strategy is consistent with national guidance. The Council confirms that in order to achieve the jobs target (of 7,053) there is a need to ‘boost our supply of housing' (para 4.1.3). This is considered to be a correct response to this employment target. However, the Council does not propose to boost the supply of housing, rather it is proposed to rely on past delivery rates and it is proposed that ‘in the short to medium term (the) housing target should be close to the long term average levels of delivery' . It is proposed to set the target at some 10,800 new homes by 2031 (i.e. 540 per annum net) (para 4.1.3). This is objected to as being inconsistent with a growth Delivering sustainable Mr Philip Aelen S W Attwood & Partners Objection LP823 Policy ST 1 agenda. In addition, past delivery rates may not be relevant to the current and emerging economic development in Swale position and the provision of an unduly cautious strategy will not serve to meet local requirements. It is noted that this stated job target ‘will ultimately require even higher levels of housing to support it' and that ‘without them our economy will not grow in the face of other competing locations' (para 4.1.4). Under these circumstances it is likely that the proposed strategy will fail to realise the necessary scale of employment as planned for as this will be constrained by a lack of an adequate workforce. The housing target of 10,800 is therefore objected to as not being adequate to address the need for local employment. The Council proposes to review these targets in the light of ‘ clear and consistent signals of improved delivery in the housing market and the wider economy as a whole ' (para 4.1.4). This is an acceptance that the initial targets are likely to be inadequate in any event. Under these circumstances we consider that the strategy is not appropriate to cater for an increase in development activity. In fact the Council recognises the relationship between jobs and housing and confirms that ‘a failure to deliver in one or more areas may present unsustainable outcomes' (para 4.2.4). In the absence of an adequate supply of housing to match job creation, the strategy will be unsustainable, contrary to national guidance. It is recognised that ‘Swale contains significant environmental constraints which affect the potential of certain areas to accommodate growth' (para 4.4.11). Whilst we accept that this is the case, it is notable that the Council confirms that, ‘ our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets' (para 4.4.12). It is evident therefore that there is no overriding objection to the provision of growth at a higher level than is proposed by reason of environmental impact. The provision of housing in the region of 740 Delivering sustainable dwells per annum would not thus be in conflict with the national requirement to protect and enhance Mr Philip Aelen S W Attwood & Partners Objection LP828 Policy ST 1 development in Swale the environment (NPPF para 7). The need to ensure that infrastructure is provided to support development is a component of sustainable development (NPPF para 7). Although there may be some constraint on development due to the impact on the road network (and especially at J5 M2) (para 4.4.14) there is no indication of any embargo in principle on development at the higher levels of growth. The Council notes that in terms of deliverability, ‘A key consideration is the deliverability of development, both in terms of viability of development in Swale and the capacity of the housing and development markets to deliver sufficient growth at a sustained rate year on year over the whole plan period' (para 4.4.15). The Council indicates that, ‘as of 2011/12, the average level of Object / Document Name Organisation Support Rep ID Title Consultee Response Part

completions in Swale were: over 5 years (dwellings per annum) = 560; 10 years = 600' (para 4.4.16). It is therefore suggested that accordingly, the ability of the local housing market to cater for an increased rate of development is ‘untested' (para 4.4.15). This appears to be the sole reason for the Council's proposed use of a reduced housing target. In our view this position is untenable. Firstly the published KCC ‘Housing Information Audit 2011' confirms that the net dwelling completions in Swale over recent years are as follows:

Year Completions Totals

2001-2002 659

2002-2003 568

2003-2004 570

2004-2005 375

2005-2006 854

3026

2006-2007 835

2007-2008 767

2008-2009 494

2009-2010 709

2010-2011 433

3238

This means that over the last 10 years, the average rate of completions has been 626 per annum and over 5-years it has increased to 648 per annum. The last 5 years is of course the period that is contained in the South East Plan with approved provision at 540 dwells per annum. These figures appear to be at odds with those used by the Council but in any event they demonstrate that in the recent past the local housing market has performed to a level that is consistently in excess of the 540 rate that is now proposed. In fact over the last 10 years completions have been +16% over the planned requirement, over the last 6 years at +26% and over 5 years at +20%. We note that in 7 years out of the last 10, the performance of the market in Swale has exceeded the 540 target. It is evident from this that there is no inherent reason why the local market would not perform at a higher level in Swale given the right national economic conditions. Using the suggested 740 dwells per annum figure needed to support economic development the recent market performance would only require an increase of +12.5%. This is not an excessive figure and should be capable of being achieved as noted in the SHMA (para 4.4.17). The ability of the area to accommodate additional development in the short to medium term is demonstrated through the proposed housing trajectory (see para 8.1.29). This confirms that in the period 2015 to 2019 it is anticipated that there will be completions substantially in excess of the proposed target rate, generated essentially through the implementation of extant planning permissions. This increased rate is not anticipated to be constrained by the market and so contradicts the Council's overall view that potential difficulties in the local market justify the use of a cautious target throughout the plan period. In addition, the plan Object / Document Name Organisation Support Rep ID Title Consultee Response Part

confirms that development rates are ‘expected to pick up markedly' (para 8.1.31) thus confirming that there is no reason to artificially constrain the target when set against anticipated market activity. As we have noted, this level of pick up would only need to be in the region of 12% to ensure that a target consistent with that needed to provide for economic activity is achieved. The projected house requirements are far beyond what is needed for natural growth of the Borough as a whole. The type of housing likely – based on that of the past 15 years – will be overwhelmingly above the affordability of most Swale residents. This means that Swale are effectively building for people migrating into the area, whilst failing to provide adequate affordable housing for people already living here. This is nonsensical. It also means that most of the people moving into the borough will be commuting to work – largely in London. This replicates the pattern of the past 10 years. Getting to Sittingbourne railway station is already difficult due to the weight of traffic on the Delivering sustainable A2 and associated roads, and although slightly alleviated by the recent northern relief road, this Mr Mike Baldock Swale - UKIP Objection LP740 Policy ST 1 development in Swale benefit will soon be lost with the new house building. A proposal for metro rail stops at Bobbing and Bapchild which could have helped alleviate this gridlock in Sittingbourne centre does not seem to be supported by Swale Borough Council.

There is already huge pressure on school places in Swale, and a new school is needed for the existing population. The amount of new schooling that will be required by this Plan is quite horrendous, given that the existing schools have been expanded way beyond comfortable limits and there are few areas where so many new schools could be put. Minster-on-Sea Parish Council (MPC) objects .to the inclusion of this policy because point (1) presents various risks. SBC's choice of the wording: "by meeting predicted and unforeseen needs on a choice of sites" should be omitted with further questions being asked by MPC as to why bio- sciences and technology were the only considerations. MPC has also concerns about the risk Parish Clerk Minster-on-Sea Parish Delivering sustainable Mrs Trish Codrington Objection LP223 Policy ST 1 presented by SBC's inclusion of the clause "with a review of the Local Plan" which again presents a Council development in Swale serious risk and should be omitted. Bearing on this in mind, MPC concluded that there is no reasonable alternative to SBC's decision to setting out how the principles of sustainable development should be applied locally (as per NPPF advice) as national policy covers the relevant issues. As one of the Kent Police Crime Prevention Design Advisers Reduction, with the responsibility to advise on "Designing Out Crime" for the Borough of Swale, we think it is important that The Swale Borough Local Plan "Bearing Fruits" includes design principles that the Council as the Local Planning Authority, should be demonstrating in developments for the prevention of crime to contribute jointly with us to continue to build Safer and Stronger Communities and to continue and support the work of the Safer Communities Partnerships. The Local Plan should include an approach to planning for crime prevention in order to prevent or deter criminal activity and anti- social behaviour by reducing the availability of opportunities to commit crime, achieved through the careful design of buildings, streets and spaces to create safer and more pleasant environments in the Borough of Swale. With this in mind, Kent Police have been working with local planners, KCC Delivering sustainable and architects to develop the Kent Design Initiative (KDI) - Design For Crime Prevention document, Mr Adrian Fromm CPDA Team Kent Police Swale Objection LP2 Policy ST 1 development in Swale which is a Kent Design Guide for Planners, Developers, Architects and Designers. The purpose of this document is to provide summary guidance for developers, the police and planners to ensure that all development proposals incorporate the principles for designing out crime and Crime Prevention Through Environmental Design (CPTED). The KDI document has been endorsed by the Chair of Kent Planning Officer Group (KPOG) and the Chief Constable of Kent and we respectfully request that crime prevention is considered within The Swale Borough Local Plan in line with Section 17 of The Crime and Disorder Act 1998 and the principles contained within the Kent Design Initiative (KDI) - Design For Crime Prevention document. We hope the attached (uploaded) Design For Crime Prevention document will assist in the consultation process and should you have any questions please do not hesitate to contact the Crime Prevention Design Advisor (CPDA) Team at Force Headquarters on 01622 653234/653209 or via email at [email protected] . Delivering sustainable No mention is made in this policy statement that infrastructure will be developed to meet needs; this Mr Paul Hutchinson Objection LP143 Policy ST 1 development in Swale is contrary to the other general statements highlighted above. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Whilst we agree with the council's position on promoting sustainable development in line with national guidance, there are a number of fundamental flaws with the policy and ultimately, the plan, in its current form, will not deliver sustainable development leading it to be unsound. Paragraph 1 of the policy promotes a strong competitive economy. However, it makes no reference to the important links between housing growth and economic growth made in paragraph 4.2.5 of the supporting text. Paragraph 4.3.5 identifies the important link between the economy and housing and identifies that failing to deliver in one of these areas may present ‘unsustainable outcomes'. Paragraph 1 of policy ST1 should be revised to take account of the intrinsic link between housing and economic growth and reflect the comments of paragraph 4.2.5. Paragraph 2 of policy ST 1 should include reference to growth east of Thistle Hill, Minster which has capacity for substantial c/o Tetlow King Planning Kent Delivering sustainable Objection LP1311 Policy ST 1 urban growth in a relatively constraint free area of the borough. We strongly disagree with Developments UK Ltd development in Swale paragraph 6 of policy ST 1. Point (a) seeks to balance levels of deliverability with need; however national guidance states that housing targets need to be based on objectively assessed need. The woefully inadequate housing target is discussed in more detail in our comments on policy ST 2. In addition, the borough has the capacity to realistically deliver at higher levels than planned for. Point (b) is supported in principle but as discussed in our comments on policy ST 2 this will not be achieved with the plan and housing targets in their current form. Whilst we agree with paragraph 7 of policy ST 1 in principle, the design requirements must not become overly restrictive to the point that they threaten viability. In summary the plan in its current form will not achieve sustainable development due to insufficient housing provision being planned. This will negatively impact on levels of economic growth, culminating in a failed strategy. Delivering sustainable Adrian Oliver Swale Cycle Forum Objection LP1117 Policy ST 1 This should refer to cycling and have inter-connected holistic approach. development in Swale 10d -should be amended and include the following: Ensure that biodiversity is maintained and enhanced by appropriately designed, on site, landscaping schemes (where applicable they should include the relevant mitigation) 10 e -should be amended and include the following: protecting and enhancing, in accordance with their status, the international, national and Kent level biodiversity Principal Planning Officer Kent designations (including the Greater Thames Natural Improvement Area) and priority habitats 10 f - Delivering sustainable Miss Elizabeth Shier County Council (Planning and Objection LP1176 Policy ST 1 should not state that a net gain on biodiversity is achieved when natural/semi natural green space is development in Swale Environment) created to offset the impact of development. Net gains can only be achieved when any habitat creation or enhancements is in addition to what is required for mitigation. Additional bullet points to be included: Maintain and enhance protected and notable species populations Planning application must be achieving net gains in biodiversity by incorporating ecological enhancements within planning developments. We support parts of the Policy as follows:

Item 1 - Building a strong and competitive economy by meeting needs on a choice of sites. Delivering sustainable Mr Neil Flanagan Support LP544 Policy ST 1 development in Swale Item 2 - Support enforcing and enhancing the role of Faversham as a centre for home and wider populations in a way which is proportionate to its scale and character.

Item 6 - Support delivering a wide choice of high quality homes. Policy ST1 item 8 will promote healthy communities by delivering cultural facilities by safeguarding Delivering sustainable Rose Freeman The Theatres Trust Support LP396 Policy ST 1 such facilities. development in Swale

Delivering sustainable Trenport generally supports the proposed policy for delivering sustainable development in Swale. Chris Hall Trenport Investments Ltd Support LP784 Policy ST 1 development in Swale Eleven options are listed which can be broadly supported by Natural England, helping to deliver Delivering sustainable David Hammond Natural England Support LP1561 Policy ST 1 green infrastructure, through sustainable development. development in Swale Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We support parts of the Policy as follows:

Item 1 - Building a strong and competitive economy by meeting needs on a choice of sites.

Delivering sustainable Item 2 - Support enforcing and enhancing the role of Faversham as a centre for home and wider Ordnance Wharf Support LP590 Policy ST 1 development in Swale populations in a way which is proportionate to its scale and character.

Item 6 - Support delivering a wide choice of high quality homes.

We support parts of the Policy as follows:

Item 1 - Building a strong and competitive economy by meeting needs on a choice of sites. Delivering sustainable Gibb Femco Support LP675 Policy ST 1 development in Swale Item 2 - Support enforcing and enhancing the role of Faversham as a centre for home and wider populations in a way which is proportionate to its scale and character.

Item 6 - Support delivering a wide choice of high quality homes. Response: The Crown Estate supports policy ST1 and feels that land at Belgrave Road, Minster is well placed to assist in the delivery of sustainable development in the Borough. The Crown Estate supports the approach for delivering sustainable development set out in Policy ST1. It is considered that sites around Minster, specifically The Crown Estate's site at Belgrave Road (SW/165) can make a significant contribution to delivering sustainable development in the borough. The key attributes of sustainable development in Minster and specifically land at Belgrave Road include:

• This well connected and permeable site can promote sustainable transport use as the site offers a highly sustainable location to accommodate growth needs. The site is accessible by alternatives to private motor vehicles; footpath connections are available via Belgrave Road and Rosemary Avenue. The site lies within easy access to local community facilities and services and to public transport links on Queenborough Road. Therefore, a good opportunity exists to promote a reduction in car use and encourage walking and cycling.

• It can deliver a wide choice of quality homes through a development of at least140 dwellings at a density of approximately 30dph to meet the requirements of Local Plan Policy Delivering sustainable The Crown Estate Support LP1432 Policy ST 1 A9 including a mix of affordable homes for local people. There is no land ownership or development in Swale technical constraints to prevent the land coming forward.

• It can deliver good design that reflects the character of the area. The site has been assessed as being of low landscape quality and of a high capacity to accommodate development. The Crown Estate's site at Belgrave Road is relatively flat and is contained by the higher land of Furze Hill. This coupled with the strong hedgerows that bound the site mean it will not have significant landscape impacts once developed. It presents an excellent opportunity for creating a high quality development that maximises potential integration with the town.

• Development will promote healthy communities. The site would retain the public open space in the existing location and provides opportunities to enhance local cycling and footpath links.

• The site can assist in meeting the challenges of Climate Change as it is located within Flood Zone I (lowest risk of flooding) and should be sequentially preferred over other Object / Document Name Organisation Support Rep ID Title Consultee Response Part

locations at greater risk of flooding.

• Development of the site would conserve the natural environment. The site is currently an arable field of limited ecological value and limited landscape quality and with high potential to accommodate development.

• Development would also conserve the historic environment: There are no protected sites or historic buildings on, or in the immediate vicinity of the site.

The Crown Estate has undertaken a number of technical assessments relating to transport, ecology and heritage (see our response to policy A9) which demonstrate that the site could contribute to the Council's aspiration of delivering sustainable development in the borough as set out in Policy ST1. KCC supported the provision of 13,500 dwellings in the previous ‘Bearing the Fruits’ consultation document. It was considered that this would more than provide for the needs of the existing population. That figure reflected a different plan period and KCC support the Borough Council’s target of 10,800 as a minimum with a view that this will be reviewed if economic conditions improve. Growth on this scale should also avoid breaching the national and international environment and landscape designations that apply to parts of Swale. Policy ST4 summarises the dwelling provision, Principal Planning Officer Kent Delivering sustainable and the majority of the new allocations and ‘Areas of search’ located at the urban areas. KCC Miss Elizabeth Shier County Council (Planning and Support LP1132 Policy ST 1 development in Swale continue to support the location of new dwellings mainly at the urban areas, notably Sittingbourne Environment) and Sheerness/Queenborough. The draft Plan brings forward more housing on brownfield land in Sittingbourne town centre and Queenborough–Rushenden although the numbers that these areas are likely to achieve has been re-evaluated. A retail led regeneration in Sittingbourne town centre to the north of the railway is being pursued and housing numbers have also increased at North West Sittingbourne as further masterplanning work has progressed. KCC support the proposed distribution of new dwellings. Principal Planning Officer Kent Delivering sustainable Particularly welcome key points 2,5,6 and 8: promote healthy communities to deliver social, Miss Elizabeth Shier County Council (Planning and Support LP1175 Policy ST 1 development in Swale recreational, cultural facilities and services through co-location, etc. Environment) We support parts of the Policy as follows:

Item 1 - Building a strong and competitive economy by meeting needs on a choice of sites. Delivering sustainable Mr Michael White Support LP635 Policy ST 1 development in Swale Item 2 - Support enforcing and enhancing the role of Faversham as a centre for home and wider populations in a way which is proportionate to its scale and character.

Item 6 - Support delivering a wide choice of high quality homes. Whilst including 'healthy communities' at 8 the clarification given in the sub sections ignores the NPPF requirement of 'safe and accessible environments where crime and disorder, and the fear of Alternatives considered - crime, do not undermine the quality of life or community cohesion'. This is a serious omission from Developer Contributions Mr Trevor Hall Objection LP288 Table 4.2.1 Delivering sustainable the draft policy making it flawed as it fails to recognise the negative impact crime and disorder and Manager Kent Police development in Swale the fear of crime can have on the health and well being of people and the sustainability/health of communities. This omission will seriously undermine Swale Borough Council's ability to deliver 'Healthy Communities' as required. Trenport generally supports the Key Diagram, in particular the general identification of North East Sittingbourne and Teynham as housing locations and main proposed employment locations, and Chris Hall Trenport Investments Ltd Support LP785 Map 4.3.1 The Key Diagram the identification of Teynham as a Rural Local Service Centre (ST3 Main focus in rural areas).

CPRE Protect Kent note and welcome the pragmatic approach outlined in this section towards the Qualified Assessing our needs for new Mr Brian Lloyd Senior Planner Protect KENT LP864 4.4 delivery of future development. However, we are concerned at the level of analysis of the support development deliverability of the housing and employment targets. There is a superficiality to the comments, Object / Document Name Organisation Support Rep ID Title Consultee Response Part

for example those in paragraph 4.4.16, and the result is a serious underestimate of the chances of delivering the targets. This is especially important in the light of the conditions in the NPPF concerning underperformance. We feel that our analysis in Part 1 of our response gives a more detailed view on the level of development that should be included in the Plan. It is confirmed in the draft that in the context of economic uncertainty the Council remains ‘ambitious and must assume a longer-term 20-year view within which things will change for the better' (para 4.1.2). The need for a strategy that is able to ‘proactively drive and support sustainable economic development' is a core principle of the National Planning Policy Framework (NPPF para 17). We consider that an ambitious development strategy needs to be reflected in the Local Plan if it is to be consistent with national policy. In this context it is submitted that the Council should be looking to produce ambitious targets for employment and housing in order to ensure that the strategy is consistent with national guidance. The Council confirms that in order to achieve the jobs target (of 7,053) there is a need to ‘boost our supply of housing' (para 4.1.3). This is considered to be a correct response to this employment target. However, the Council does not propose to boost the supply of housing, rather it is proposed to rely on past delivery rates and it is proposed that ‘in the short to medium term (the) housing target should be close to the long term average levels of delivery' . It is proposed to set the target at some 10,800 new homes by 2031 (i.e. 540 per annum net) (para 4.1.3). This is objected to as being inconsistent with a growth agenda. In addition, past delivery rates may not be relevant to the current and emerging economic position and the provision of an unduly cautious strategy will not serve to meet local requirements. It is noted that this stated job target ‘will ultimately require even higher levels of housing to support it' and that ‘without them our economy will not grow in the face of other competing locations' (para 4.1.4). Under these circumstances it is likely that the proposed strategy will fail to realise the necessary scale of employment as planned for as this will be constrained by a lack of an adequate workforce. The housing target of 10,800 is therefore objected to as not being adequate to address the need for local employment. The Council proposes to review these targets in the light of ‘ clear and consistent signals of improved delivery in the housing market and the wider economy as a whole ' (para 4.1.4). This is an acceptance that the initial targets are likely to be inadequate in any event. Under these circumstances we consider that the strategy is not appropriate to cater for an increase Assessing our needs for new Floplast Ltd Objection LP1076 4.4 in development activity. In fact the Council recognises the relationship between jobs and housing development and confirms that ‘a failure to deliver in one or more areas may present unsustainable outcomes' (para 4.2.4). In the absence of an adequate supply of housing to match job creation, we consider that the strategy will be unsustainable, contrary to national guidance. The draft Plan identifies a strategy with twin objectives of developing in sustainable locations and developing land of lower value. As these representations (and those previously submitted) set out, the Floplast site is sustainable (and will become even more so given the draft allocation for land to the west of Sittingbourne which is accessible from the site on foot via Bramblefield Lane), and also of lower value given the existing industrial use. The need to avoid environmental assets and constraints such as flood plains and areas of high agricultural land is recognised as being in line with national policy (para 4.1.8) as a matter of principle and it is noted that the FloPlast site is not constrained in either sense. The Council recognises that if it is possible to secure housing development of a scale that is in excess of the average achieved over the last 10 years this can trigger a Local Plan Review, (para 4.2.37) with presumably the objective of increasing the numbers to suit. This position means that the proposed strategy is not however responsive to changing circumstances and is unable to adapt to rapid changes as required (NPPF para 14). We consider that this reliance on an early review of the plan is an indication that it is deficient and fails to incorporate sufficient flexibility. It is noted that the evidence base has been updated through a 2013 study by NLP (para 4.4.1). The use of updated figures is welcomed and supported as being consistent with national guidance (NPPF para 14). It is noted that these considerations to inform the strategy are set out in the plan (Fig 4.4.1). In terms of housing need it is confirmed that the objectively assessed needs based on demographic assumptions would require between 670 and 890 dwells per annum (para 4.4.6). It is noted that the ONS projections are at the higher end of this range (a minimum of 840 dwells p.a.). It is a requirement of the NPPF that there is a need to identify these elements and to cater (as set out in the SHMA) for this level of demand with this reflected in the subsequent SHLAA (NPPF para 159). A jobs-based scenario suggests that a level of 740 dwells per annum is the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

minimum needed (para 4.4.7). It is firm guidance (NPPF para 14) that a local plan ‘should meet objectively assessed needs... unless any adverse effects of doing so would significantly and demonstrably outweigh the benefits... ' It is notable that the Council's proposed target (of 540 dwells per annum) is lower than the economic or demographic requirements and is recognised as such in the NLP study. On this basis, we consider that this scale of provision fails to meet any reasonable assessment of housing need in the Borough and it is thus incompatible with national guidance. On the basis that additional housing sites are available and can be delivered in sustainable locations such as the FloPlast site, we consider that there is no justification to rely on a lower target. It is recognised that ‘Swale contains significant environmental constraints which affect the potential of certain areas to accommodate growth' (para 4.4.11). Whilst we accept that this is the case, it is notable that the Council confirms that, ‘ our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets' (para 4.4.12). It is evident therefore that there is no overriding objection to the provision of growth at a higher level than is proposed by reason of environmental impact. The provision of housing in the region of 740 dwellings per annum would not thus be in conflict with the national requirement to protect and enhance the environment (NPPF para 7). The need to ensure that infrastructure is provided to support development is a component of sustainable development (NPPF para 7). Although there may be some constraint on development due to the impact on the road network (and especially at J5 M2) (para 4.4.14) there is no indication of any embargo in principle on development at the higher levels of growth. The Council notes that in terms of deliverability, ‘A key consideration is the deliverability of development, both in terms of viability of development in Swale and the capacity of the housing and development markets to deliver sufficient growth at a sustained rate year on year over the whole plan period' (para 4.4.15). The Council indicates that, ‘as of 2011/12, the average level of completions in Swale were: over 5 years (dwellings per annum) = 560; 10 years = 600' (para 4.4.16). It is therefore suggested that accordingly, the ability of the local housing market to cater for an increased rate of development is ‘untested' (para 4.4.15). This appears to be the sole reason for the Council's proposed use of a reduced housing target. In our view this position is untenable. Firstly the published KCC ‘Housing Information Audit 2011' confirms that the net dwelling completions in Swale over recent years are as follows:

Year Completions Totals 2001-2002 659 2002-2003 568 2003-2004 570 2004-2005 375 2005-2006 854 3026 2006-2007 835 2007-2008 767 2008-2009 494 2009-2010 709 2010-2011 433 3238

level in Swale given the right national economic conditions. Using the suggested 740 dwellings per annum figure needed to support economic development the recent market performance would only require an increase of +12.5%. This is not an excessive figure and should be capable of being achieved as noted in the SHMA (para 4.4.17). The ability of the area to accommodate additional development in the short to medium term is demonstrated through the proposed housing trajectory (see para 8.1.29). This confirms that in the period 2015 to 2019 it is anticipated that there will be completions substantially in excess of the proposed target rate, generated essentially through the implementation of extant planning permissions. This increased rate is not anticipated to be constrained by the market and so contradicts the Council's overall view that potential difficulties in the local market justify the use of a cautious target throughout the plan period. In addition, the plan confirms that development rates are ‘expected to pick up markedly' (para 8.1.31) thus confirming that there is no reason to artificially constrain the target when set against anticipated market activity. As we have noted, this level of pick up would only need to be in the region of 12% to ensure that a target consistent with that needed to provide for economic activity is achieved. Para 4.4.5 - 4.4.6 and Figure 4.4.1 we note the range of scenarios which point to an objective assessment of housing need considerably higher than the 540pa selected in the Plan. Para 4.4.12 - We fully agree with the LPA's statement that evidence concludes that growth levels within the lower and middle bands of the 600-900 housing range would not significantly adversely affect the Borough's principal environmental assets. Paragraph 8.53 of the SHMA update report 2013 confirms this. Further comments on how the council has assessed sites are included under the proposed site allocations, however in summary it is concluded there has been an inconsistent approach taken to the assessment of suitable, available and deliverable sites. The site at Woottons Farm is on land without any national or local special designation and in the context of the Borough is not a principal environmental asset. Para 4.4.15 - 4.4.17 - it is clear that to meet the range of objective needs would see an increase, on average, in the delivery of housing greater than that c/o Tetlow King Planning Kent Assessing our needs for new achieved over the past 10 years. However, this is due to the previous Local Plans being subject to Objection LP1312 4.4 Developments UK Ltd development different policies, and housing requirements and so on. It is notable that completions for the 11 years 2001/2 to 2011/12 averaged 606 dwellings (net) per annum (Swale District Housing Information Audit 2011/12 - KCC). This is exactly the same as the annual average housing requirement set by the Kent Structure Plan for this period. In other words there was not under- delivery against targets and it is likely that a low target suppressed delivery. The fact that objectively assessed needs are clearly much higher would support this. The new Local Plan provides the opportunity to make sure that provisions are put in place to ensure the allocations are made to meet the new housing requirement. Reference is made to the performance of the first 2 years of the plan which are below the bottom of the objectively assessed needs, but these years are subject to existing ‘Saved' policies and not that of the emerging policies, which should be seeking to positively plan to meet for the needs as required by the Framework. As such, comparison in this way is not sufficient evidence to justify the approach. Further details are set out below. It is noted that the evidence base has been updated through a 2013 study by NLP (para 4.4.1). The use of updated figures is welcomed and supported as being consistent with national guidance (NPPF para 14). It is noted that these considerations to inform the strategy are set out in the plan (Fig 4.4.1). In terms of housing need it is confirmed that the objectively assessed needs based on demographic assumptions would require between 670 and 890 dwellings per annum (para 4.4.6). It is noted that the ONS projections are at the higher end of this range (a minimum of 840 dwells p.a.). It is a requirement of the NPPF that there is a need to identify these elements and to cater (as set out in the SHMA) for this level of demand with this reflected in the subsequent SHLAA (NPPF para Assessing our needs for new Vinson Trust - Lady Dane Farm Objection LP1339 4.4 159). A jobs-based scenario suggests that a level of 740 dwells per annum is the minimum needed development (para 4.4.7). It is firm guidance (NPPF para 14) that a local plan ‘should meet objectively assessed needs... unless any adverse effects of doing so would significantly and demonstrably outweigh the benefits...' It is notable that the Council's proposed target (of 540 dwells per annum) is lower than the economic or demographic requirements and is recognised as such in the NLP study. On this basis, we consider that this scale of provision fails to meet any reasonable assessment of housing need in the Borough and it is thus incompatible with national guidance. It is also potentially in conflict with the economic strategy of the emerging plan in that the resulting workforce will not be sufficient to cater for local jobs. It is recognised that ‘Swale contains significant environmental Object / Document Name Organisation Support Rep ID Title Consultee Response Part

constraints which affect the potential of certain areas to accommodate growth' (para 4.4.11). Whilst we accept that this is the case, it is notable that the Council confirms that, ‘our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets' (para 4.4.12). It is evident therefore that there is no overriding objection to the provision of growth at a higher level than is proposed by reason of environmental impact. The provision of housing in the region of 740 dwells per annum would not thus be in conflict with the national requirement to protect and enhance the environment (NPPF para 7). In our view this position is evident at Faversham where there are no overriding environmental constraints relating to development at Lady Dane Farm, apart from it being a greenfield site. This position may however, not be replicated at Oare, which is recognised as having a degree of impact on the nearby Swale Special Protection Area. This is a national level of constraint and development here may result in conflict with national policy. The need to ensure that infrastructure is provided to support development is a component of sustainable development (NPPF para 7). Although there may be some constraint on development in the Borough due to the impact on the road network (and especially at J5 M2) (para 4.4.14) there is no indication of any embargo in principle on development at the higher levels of growth. This applies in particular to J6 and J7 on the M2, which have been assessed as having capacity to accommodate further development. The Council notes that in terms of deliverability, ‘A key consideration is the deliverability of development, both in terms of viability of development in Swale and the capacity of the housing and development markets to deliver sufficient growth at a sustained rate year on year over the whole plan period' (para 4.4.15). This is a major policy consideration and requires that the identified strategic sites (such as for mixed uses at Faversham) must demonstrate deliverability if they are to be sustainable and provide for the delivery of the strategy. The Council indicates that, ‘as of 2011/12, the average level of completions in Swale were: over 5 years (dwellings per annum) = 560; 10 years = 600' (para 4.4.16). It is therefore suggested that accordingly, the ability of the local housing market to cater for an increased rate of development is ‘untested' (para 4.4.15). This appears to be the sole reason for the Council's proposed use of a reduced housing target. In our view this position is untenable. Firstly the published KCC ‘Housing Information Audit 2011' confirms that the net dwelling completions in Swale over recent years are as follows:

Year Completions Totals 2001-2002 659 2002-2003 568 2003-2004 570 2004-2005 375 2005-2006 854 3026 2006-2007 835 2007-2008 767 2008-2009 494 2009-2010 709 2020-2011 433 3238

match or exceed the growth potential required to meet local needs. The Council's desire to artificially restrain housing growth is therefore at odds with a growth-led strategy and its implications for job-creation and support are not helpful. Using the suggested 740 dwells per annum figure needed to support economic development the recent market performance would only require an increase of +12.5%. This is not an excessive figure and should be capable of being achieved as noted in the SHMA (para 4.4.17). The ability of the area to accommodate additional development in the short to medium term is demonstrated through the proposed housing trajectory (see para 8.1.29). This confirms that in the period 2015 to 2019 it is anticipated that there will be completions substantially in excess of the proposed target rate, generated essentially through the implementation of extant planning permissions. This increased rate is not anticipated to be constrained by the market and so contradicts the Council's overall view that potential difficulties in the local market justify the use of a cautious target throughout the plan period. In addition, the plan confirms that development rates are ‘expected to pick up markedly' (para 8.1.31) thus confirming that there is no reason to artificially constrain the target when set against anticipated market activity. As we have noted, this level of pick up would only need to be in the region of 12% to ensure that a target consistent with that needed to provide for economic activity is achieved. The Councils Nathaniel Lichfield & Partners (NLP) study on Swale BC SHMA and Development Needs Assessment(2013) suggested that an annual average job growth of 357 jobs pa should be a minimum target but they also acknowledged that this figure was still below the pre-recession growth level of 432 jobs pa which indicates scope for the Borough to achieve higher growth if potential of individual sectors are maximised.

The NLP report "indicates that constrained housing supply can act as a barrier to achieving economic growth potential where it limits labour market flexibility. It is therefore important that ,if pursuing a jobs-led approach to future planning, that sufficient new housing is provided to align the needs of the local economy" ( para 4.34 NLP report 2013).

The main demographic scenarios (A,B,D and E) set out in the NLP report provide an objective assessment of demographic led needs, demonstrating that to meet projected demographic change would require between 671 and 887 dwellings pa. Swale BC has advanced a jobs-led approach through previous consultations, and three potential economic growth targets were considered. Mr Howard Courtley Director Courtley Consultants Ltd Objection LP381 4.4.1 Paragraph These scenarios (F,G and H) show that to meet business needs, to maintain a balanced supply within the Borough to support economic growth, there is a requirement for between 600 and 820 dwellings pa.The report suggests that with "a positive and pro-active strategy around delivering higher economic growth for Swale 740 dwellings pa" could be achieved.

The scale of affordable housing need is acute and the assessment undertaken by NLP calculate that 1,186 affordable dwellings pa would be needed to meet affordable housing needs in the Borough.

Due to the various factors and assumptions feed into the assessment of future needs the NLP report did not define a single figure which would identify Swale's objectively assessed development needs, it however did consider "an objective assessment of housing need and demand for Swale Borough falls within the range 600 to 900 dwellings pa equivalent to 12,000 to 18,000 additional dwellings over the plan period 2013 to 2031". The Council does not attempt to meet its objectively assessed needs. It is noted that the evidence base has been updated through a 2013 study by NLP (para 4.4.1). The use of updated figures is welcomed and supported as being consistent with national guidance Mr Philip Aelen S W Attwood & Partners Support LP826 4.4.1 Paragraph (NPPF para 14). It is noted that these considerations to inform the strategy are set out in the plan (Fig 4.4.1). In terms of housing need it is confirmed that the objectively assessed needs based on demographic Mr Philip Aelen S W Attwood & Partners Objection LP827 4.4.6 Paragraph assumptions would require between 670 and 890 dwells per annum (para 4.4.6). It is noted that the ONS projections are at the higher end of this range (a minimum of 840 dwells p.a.). It is a Object / Document Name Organisation Support Rep ID Title Consultee Response Part

requirement of the NPPF that there is a need to identify these elements and to cater (as set out in the SHMA) for this level of demand with this reflected in the subsequent SHLAA (NPPF para 159). A jobs-based scenario suggests that a level of 740 dwells per annum is the minimum needed (para 4.4.7). It is firm guidance (NPPF para 14) that a local plan ‘should meet objectively assessed needs… unless any adverse effects of doing so would significantly and demonstrably outweigh the benefits… ’ It is notable that the Council’s proposed target (of 540 dwells per annum) is lower than the economic or demographic requirements and is recognised as such in the NLP study. On this basis, we consider that this scale of provision fails to meet any reasonable assessment of housing need in the Borough and it is thus incompatible with national guidance. CPRE Protect Kent agree with this conclusion. However, in view of this conclusion, deliverability Qualified Mr Brian Lloyd Senior Planner Protect KENT LP865 4.4.8 Paragraph becomes an even important consideration. Plucking employment targets from the air in the name of support “aspiration” is not in our view an objective approach. Kent Wildlife Trust is concerned that the level of housing seems to have been identified without a Habitats Regulations Assessment being undertaken. A HRA should not only identify impacts and mitigation required, although this is an important function of the assessment. The HRA should be undertaken early in the policy process and should assess the level and location of development that can be delivered without impacting on the integrity of the Natura 2000 and Ramsar network. When considering housing levels the HRA should assess ways to avoid and mitigate impacts to ensure an acceptable level of housing is delivered. The HRA needs to take into account individual and in- Conservation Officer, Policy and Miss Debbie Salmon Objection LP1079 4.4.10 Paragraph combination impacts of proposed development and growth levels within neighbouring authorities, if Planning Kent Wildlife Trust relevant. We are extremely concerned that this section suggests that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets, when no HRA has been undertaken and there is no commitment to preparation of the assessment until the submission stage. It is our view that it is imperative that a HRA be carried out before further planning is undertaken to assess the level and location of the housing and employment contained within the Preferred Options consultation. In addition to the environmental constraints referred to here, the presence of a significant amount of high quality agricultural land should also be acknowledged. Whilst this is not an absolute constraint to development, the National Planning Policy Framework (para 112) does require the economic and Mr Brian Lloyd Senior Planner Protect KENT Objection LP867 4.4.11 Paragraph other benefits of the best and most versatile agricultural land to be taken into account. The fact that Swale has such high proportion of the Nation’s high quality land, and that agriculture is an important and growing component of the local economy, makes it all the more important that this resource is protected. Principal Planning Officer Kent This para should clearly state its all locally, nationally and internationally designated sites – rather Miss Elizabeth Shier County Council (Planning and Objection LP1179 4.4.11 Paragraph than giving an example of one designated sites. It should also include legally protected species. Environment) This paragraph is only restricted to the impact on recreational pressure to the European Designated Principal Planning Officer Kent Sites. This Para needs to be titled more clearly or provide additional information detailing how Miss Elizabeth Shier County Council (Planning and Objection LP1180 4.4.11 Paragraph biodiversity will be managed within the whole district not just restricted to the recreational pressure Environment) within the SPA Environmental constraints are mentioned under paragraph 4.4.11 to 4.4.13 and reference is made high quality agricultural land which is acknowledged and welcomed as a consideration in David Hammond Natural England Support LP1562 4.4.11 Paragraph development proposals.

The Council has suggested that environmental constraints have restricted the level of housing it can deliver within Swale Borough. The Council give an example in the SPA which it suggests maybe sensitive to cumulative levels of development in Swale. However there is no available evidence to Mr Howard Courtley Director Courtley Consultants Ltd Objection LP371 4.4.12 Paragraph support identification of a definitive threshold beyond which develpment could not be accommodated.

The Council lacks the evidence that would suggest it cannot meet its objectively assessed housing Object / Document Name Organisation Support Rep ID Title Consultee Response Part

needs. This draft plan is therefore unsound. Bird abundance, disturbance and visitor surveys commissioned by the North Kent Environmental Planning Group (‘NKEPG') and undertaken by Footprint Ecology show there have been marked declines in the numbers of birds using the three SPAs in North Kent and that recreational disturbance is a potential cause of the declines. Birds are responding to the presence of people, and there is evidence that the busiest locations (which have seen the most marked bird declines) support particularly low numbers of birds. Access levels are linked to local housing, with much of Miss Sophie Flax RSPB Objection LP42 4.4.13 Paragraph the access involving frequent use by local residents with dog walking, and in particular dogs off leads, being by far the main cause of disturbance. The NKEPG has made significant progress towards developing a strategic approach to mitigating and managing disturbance to birds on the North Kent Marshes and Local Plans are important for embedding policies to support this partnership working. Swale's Local Plan requires a robust strategic approach to managing and mitigating the effects of recreational disturbance and other potential impacts on the Natura 2000 sites and SSSIs along its coastline. The Council suggest that infrastructure may limit the potential to accomodate growth, particularly in relation to traffic and the road network. However, this again is not currently defined as a specific threshold, and future transport modelling and assessment work will be required to test different Mr Howard Courtley Director Courtley Consultants Ltd Objection LP382 4.4.14 Paragraph levels of growth. This should consider the extent to which capacity factors limit development in specific locations but also whether new development could help resolve constraints by helping to fund infrastructure improvements, through Sec106, CIL or other mechanisms. The Highways Agency should be consulted before any of these proposed developments are put forward because having free flowing traffic is the key to the success of the expansion project contained in this document.

The Highways Agency were instrumental in stopping the development of the proposed development of Sittingbourne Town centre by Tesco following an immense amount of work by the company and much trumpeting of success by the local councillors. Therefore they should be part of the Mr David Hawkins Objection LP551 4.4.14 Paragraph consultation process before any plans are put forward as it would save a lot of time and effort on the

part of developers, planners and councillors.

The agency has already indicated that Junction 5 of the M2 needs to be severely modified to be able to cope with any major increase in development. They have also indicated that the Grovehurst roundabout needs to be improved to carry the increase in traffic to the industrial sites. These improvements should be put in place before any new housing development is given the go ahead. Failure to do so would be reckless and put people’s health and safety at risk. It is heartening to see that infrastructure constraints are acknowledged. Looking at the ‘large' constraint: J5 of the M2, while acknowledging it and looking at mitigation, but with no defined view or plan; there is still an intention to grow the population in the area which will only add a further burden to this bottle-neck and an inevitable increase in road incidents. At a more local level other Mr Paul Hutchinson Objection LP144 4.4.14 Paragraph bottle-necks are well known and recorded (ie KCC's acknowledgement that the crossroads at

Halfway is at over-capacity). Therefore, without acknowledged and considered mitigation of all such constraints in the event of a serious incident I am sure the ‘duty-of-care' will be properly assessed and considered when apportioning responsibility and possible blame. Once again, the audit trail of such Plans and comments comes to the fore. We would disagree with the opening sentence of this paragraph. There is clear evidence, and it is accepted elsewhere in the draft Plan, that transport infrastructure is a significant constraint to development and that new development will significantly increase congestion in the Borough. It is clear to us from the evidence that transport infrastructure will provide a significant constraint to Mr Brian Lloyd Senior Planner Protect KENT Objection LP868 4.4.14 Paragraph accommodating growth. Indeed, the very next sentence of this paragraph confirms that development that would impact further on Junction 5 of the M2 attracts ‘holding' directions from the Highways Agency. It is concerning that despite a ‘Memorandum of Understanding' being agreed between the Borough Council, Highway Authority and Highway Agency prior to the adoption of the current Local Plan in early 2008 to identify an appropriate solution and a delivery mechanism for Object / Document Name Organisation Support Rep ID Title Consultee Response Part

improvements at Junction 5, this has not been progressed in any meaningful way over the last seven-or-so years. This paragraph needs to be amended to recognise the serious constraint that current transport infrastructure presents to accommodating future development. CPRE Protect Kent agree that deliverability is a key consideration in setting the levels of future development, and this is a requirement of the National Planning Policy Framework (NPPF). We welcome the approach taken by the Council to resist pressures to set a level of development that is undeliverable, as to do so - as acknowledged in paragraphs 4.4.21 to 4.4.23 of the draft Plan - could result in speculative development in unsustainable locations contrary to the plan-led strategy if the Council fails to have an identified five year land supply of deliverable sites. However, our detailed analysis of deliverability, as set out in Part 1 of our response, suggests that the District Council remains too optimistic about the deliverability of its targets. By way of example, we would highlight the experience of Dover District where in its Core Strategy the District Mr Brian Lloyd Senior Planner Protect KENT Objection LP869 4.4.15 Paragraph Council set a high housing target in order to boost economic growth. However, despite persuading the Examination Inspector that the target was deliverable, this has proved not to be the case and the District Council cannot now demonstrate a deliverable five-year housing land supply in accordance with the NPPF. Consequently, the District Council has recently granted planning permission for 521 dwellings in the Kent Downs Area of Outstanding Natural Beauty for a site that forms no part of its planned strategy. Dover can, perhaps, be forgiven for not being aware of this consequence of an overly ambitious housing target, as the Core Strategy was adopted before the NPPF was formulated. But Swale is in a position to give full regard to this consequence in setting its housing target. As a result, as shown in our earlier detailed analysis in Part 1 of our response the housing target should be set at 10,000 dwellings by 2031. Once again, your stance to curtail housing development is to be applauded. I still caution that Qualified without a robust argument the new planning rules may scupper this strategy. We should not Mr Paul Hutchinson LP145 4.4.20 Paragraph support hesitate to call upon our local MP to support and champion the Plan (a copy of my comments will be forwarded to Mr Henderson). The Council acknowledge that its draft Local Plan currently falls well below it objectively assessed housing needs. On the basis of the NLP report (2013) the Council should consider a housing target somewhere in the middle of the 600 to 900 range per annum. Such a scale would meet demographic assessed needs and would not place any undue constraint on meeting the economic potential of Swale. This would also accord with the jobs-led approach the Council have previously promoted. Mr Howard Courtley Director Courtley Consultants Ltd Objection LP374 4.4.23 Paragraph The NLP report concludes: "A housing target of c750 dwellings pa, representing the mid-point of the range, alongside an economic and employment land startegy to deliver the higher economic growth scenario (equating to 357 additional jobs pa), would meet a full objective assessment of need for both employment and housing within Swale".

This has to be the starting point for Swale BC in preparing its Local Plan. It is noted that Swale acknowledges that its preferred housing target would be below the objectively Klaire Lander (DHA) Owner of Centre assessed development needs. This approach is opposed. The Council should avoid the Local Plan Objection LP73 4.4.23 Paragraph 2000, St Michaels Road being found unsound and should therefore allocate sufficient housing sites to meet the housing need of the Borough. It is noted that Swale acknowledges that its preferred housing target would be below the objectively Klaire Lander (DHA) Owner of land at Objection LP76 4.4.23 Paragraph assessed development needs. The Council should avoid the Local Plan being found unsound and Parsonage Farm, Newington should therefore allocate sufficient housing sites to meet the housing need of the Borough. It is noted that Swale acknowledges that its preferred housing target would be below the objectively Owner of land at Cellar Hill, Teynham Objection LP87 4.4.23 Paragraph assessed development needs. The Council should avoid the Local Plan being found unsound and

should therefore allocate sufficient housing sites to meet the housing need of the Borough. Swale BC has a "Duty to Cooperate" on planning issues that cross administrative boundaries, Mr Howard Courtley Director Courtley Consultants Ltd Objection LP383 4.4.25 Paragraph particularly those which relate to the "strategic priorities" set out in paragraph 156 of the NPPF. The Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Government expects joint working on areas of common interest to be diligently undertaken for mutual benefit of neighbouring authorities. Swale BC should take account of different geographic areas, including travel-to-work areas.

Joint working should enable planning authorities to work together to meet development requirements which cannot wholly be met within their own areas.

Swale BC have failed to demonstrate that it has effectively cooperated to plan for issues with cross- boundary impacts. The new National Planning Policy Guidence confirms that the timing of other neighbouring authority Local Plans is no justification for not jointly setting out the strategic priorities for the area in the Local Plan i.e homes and jobs needed in the area; retail, leisure and employment; provision of infrastructure; provision of community services health security etc and climate change mitigation and adoptation. I note that your objectively assessed needs for housing was for between 604 and 890 dwellings per annum. The Council has chosen a figure of at least 540 dwellings per annum (10, 800 dwellings for the plan period). This figure matches the figure set out in the South East Plan (which has since been abolished). This would result in a shortfall of between 1,280 - 7,000 dwellings over the plan period to 2031. The Plan states that should the 5 year past trend of net housing completions exceed 600 dwellings per annum a review of the Local Plan would be triggered. You refer to the fact that as of 2011/12, Swale had a net supply of 571,405 sq m of employment floorspace, whilst the Local Plan allocates an additional circa 97,840 sq m. You state that the Council would be prepared to enter into discussions with neighbouring authorities who may have issues meeting their own identified needs for employment floorspace. At the moment, Medway's evidence base is also identifying a surplus of employment land provision. Consequently, Medway Council does not consider there to be any need for it to enter into such a discussion with you on this particular matter at this point in time. However, we will continue to liaise with you on this and other policy issues, and should there be any significant change in circumstances we will of course notify you of this. Swale's jobs provision target is 353 per annum, 7,053 for the plan period (this has been reduced from the previous figure). The Local Plan says further housing will be necessary to meet jobs growth ambitions. It states that to advocate a jobs-led approach based upon the higher economic growth scenario; there would be a requirement for around 740 dwellings per annum. In terms of the Medway Submission Draft Core Strategy, the Council maintained the same dwelling requirement of 815 dwellings per annum that was set out in the South East Plan. The Council considered that this Senior Planning Officer Medway figure represented a balance between the needs of the current population and the aspirations of the Paul Cronk Objection LP1121 4.4.25 Paragraph Council Thames Gateway as a growth area. Our own Examination Inspector has pointed out to us in writing that we need to have an up to date assessment undertaken of our objectively assessed housing needs in order to justify the retained housing requirement figure. We have employed ORS Consultants to produce a Strategic Housing Market Assessment (SHMA) Update that sets out fresh demographic projections for the period to 2028. This Assessment will be available very shortly. It is likely to identify higher levels of housing requirement for Medway than those set out in the South East Plan. Based upon the current housing requirement of 815 dwellings per annum, Medway has a housing supply of approximately 7.75 years (assuming a 5% allowance). However, should the Council have no other option then to withdraw its Core Strategy and begin work on a new Local Plan, urgent work would be undertaken to identify and justify a new interim housing target. Medway Council would expect to prepare a full new SHMA once the full 2011 Census data is available, and the revised boundaries of individual Strategic Housing Market Areas are known. This is likely to be in around one year's time. We will of course be keen to liaise with neighbouring local authorities regarding this work. This would be the key piece of evidence to underpin any future housing requirement figure within a new Local Plan. Given current uncertainty, Medway Council does not consider that it is in a position to assist your Authority' in meeting your unmet housing requirements. It is very likely that Medway Council will find it very challenging to meet any higher housing requirement of it's own. Consequently, it is highly unlikely that it would be able to assist other local authorities meet their own unmet housing requirements. We can confirm that we remain fully committed to carrying on collaboration with you on planning policy matters of mutual importance, including work on a Joint SHMA if appropriate. Medway Council does not specifically wish to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

request an appearance at your Examination. However, it would be happy to do so should the Inspector consider it beneficial. On page 57, it is stated that there is a need for a budget hotel at Faversham but with no specific location mentioned. This issue was discussed recently at a meeting in connection with a proposed scheme at Perry Court near to the Ashford Road and M2. There are a number of other budget hotels in the areas around Faversham and that at present there is little additional hotel capacity in this sector. If, like the hotel suggested as part of the Perry Court scheme, the hotel were located close to the motorway, then visitors are only likely to stay one night and not come in to the town as Anne Salmon Faversham Society Objection LP1376 4.4.33 Paragraph such hotels tend to have their own restaurants in associated chains. A better site for such a hotel is proposed in the Dane Park scheme which was the subject of a recent public exhibition, since it was on Love Lane and opposite Windermere from which there is a fairly short walking route to the town so that visitors could access the town’s shops and restaurants. We would comment however that the supply chains of these organisations are national and therefore such a hotel may offer little benefit to local suppliers. Under paragraph 4.4.42 reference is made to recognising recreational pressure on sites which is to be encouraged, the link to the Community Infrastructure Levy, to alleviate issues of pressure and deficiency are welcomed and to be encouraged. The Council having identified areas of deprivation David Hammond Natural England Support LP1563 4.4.42 Paragraph and potential for improvement, should seek to link green spaces, alleviating fragmentation and enhance where possible green/open space provision. This will help reduce potential for impact on designated sites and help strengthen as well as be in line with the Council’s policies.

Water Resources Planning

We published our draft Water Resources Management Plan (dWRMP) in May 2013. After a three month consultation period, the final plan is due to be published in April 2014. This plan sets out how we intend to maintain the balance between increasing demand for water and available supplies over the next 25 years up to 2040. The plan takes into account planned housing growth as well as the potential impact of climate change.

To ensure secure supplies for the future, we must ensure our plan reflects the housing numbers in our supply area as accurately as possible.

The district of Swale that is within our Supply area lies within South East Water's resource zone 8. Our dWRMP indicates that, for average demands a shortfall in water is expected from 2025 and for peak demands a deficit is expected from 2020 onwards. After which time additional supply schemes will be required to satisfy demand including regional transfers from neighbouring companies, Broad Qualified Avory Gemma South East Water plc LP216 4.4.43 Paragraph Oak reservoir (2030-2035) and a desalination plant at Reculver (2030-40). support It is imperative that there is sufficient flexibility within the Core Strategy to support any currently unforeseen development that maybe required during the plan period to maintain and enhance the provision of water and the water supply network. We would suggest that this is mentioned in section 4.4.43 to ensure future planning permission to secure safe water supplies is supported.

Housing allocations

In line with statutory guidance, our planning takes full account of the planning forecasts of Local Authorities within our region. All Local Authorities been contacted and we have a comprehensive forecast, developed by Experian, together with neighbouring companies, of growth estimates in population and households.

For Swale in particular, our forecasts include a growth estimate of: Object / Document Name Organisation Support Rep ID Title Consultee Response Part

• 880 households over the period 2012 to 2020; • 2,199 households over the period 2012 to 2030; and • 3,533 households over the period 2012 to 2040.

Our dWRMP assumes there will be 2,199 new homes from 2012-2030 across the part of Swale within our supply area. These figures are in line with your Core Strategy requirement of 10,800 new homes up to 2031 across the entire district. It is heartening to hear that the water companies do not indicate there would be insurmountable difficulties in water supply and that waste water will require some infrastructure work. I note however from the Bearing Fruits Strategy paper dated March 2012 (page 21 - map 2.1.6) the main Mr Paul Hutchinson Objection LP146 4.4.43 Paragraph development areas of Sittingbourne and Rushenden/Queenborough lie squarely in the area that are assessed as being over abstracted for water. What is the correct statement? This needs to be qualified and clarified; you have provided conflicting information. Principal Planning Officer Kent A new secondary school together with new and expanded primary schools have been identified by Miss Elizabeth Shier County Council (Planning and Objection LP1201 4.4.44 Paragraph KCC. It is anticipated that the suggested new rural 1FE school on a 2FE site is located in the south Environment) Sittingbourne area. You mention the housing target has dropped to 7053; this is laudable and the argument is sound. Qualified Development targets for jobs Mr Paul Hutchinson LP135 Policy ST 2 However, will this be ‘interfered' with under the new planning rules being introduced by the Planning support and new homes 2011-2031 Minister Nick Boles? A clearer articulation of the argument may be required. Response: The Crown Estate supports 540 dwellings per annum (dpa) as a minimum rate of growth and the identification of Minster as a growth location. Policy ST2 sets out the proposed growth rate for delivering homes and jobs. The Council has chosen a lower target than included in the Draft Core Strategy (March 2012) and is planning for this target through the sources of development outlined in Table 3.1. Source Number of new homes

Completions 2011-2012 397 Extant Planning Permissions 2,192 New land identified for housing through Local lPlan 7,027 Windfalls 1,449 Total proposed by Local Plan 11,065

So far over the period 2011-2011, 397 dwellings have been completed with an identified supply of 7,027 dwellings giving an overall supply of 9,219 dwellings. A provision for 1,449 windfall sites and 82 Gypsy and Traveller sites make up the shortfall. Overall The Crown Estate supports the level of growth set out in Policy ST2 as a minimum rate of growth to 2031. Although The Crown Estate Qualified Development targets for jobs The Crown Estate LP1433 Policy ST 2 generally supports this policy, consideration should be given to the following recommendations in support and new homes 2011-2031 order for the Local Plan to be found sound. The emphasis of NPPF is to ensure local plans are positively prepared (paragraph 182) and significantly boost housing supply (paragraph 47). This also requires local planning authorities to identify a specific supply of developable sites or broad locations for year 6-10 and, where possible, for years 11-15 and update this annually. In addition, local plans should be sufficiently flexible to adapt to rapid changes (paragraph 14). In order to provide a sound growth strategy it is important to allocation sufficient land, including a mixed portfolio of Brownfield and Greenfield sites, such as The Crown Estate's site at Belgrave Road Minster, in order to provide a positive growth strategy which is sufficiently flexible in line with the emphasis of NPPF as outlined above. Our response to Policy A9 in chapter 6 of this statement gives justification for the allocation of this land and demonstrates that it is deliverable in line with guidance in NPPF. Whilst the Council's evidence base makes an assumption that windfalls will continue to deliver, in line with the calls in NPPF to provide a positive growth strategy and better respond to housing needs we support the approach of allocating sufficient Greenfield sites, including land at Belgrave Road Minster, rather than continuing with an over reliance on windfalls, to provide a sound growth strategy and ensure the successful delivery of the Local Plan. The allocation of The Crown Estate's site at Minster can assist in planning for the longer term requirements, including delivering affordable housing, rather than persisting with the piecemeal Object / Document Name Organisation Support Rep ID Title Consultee Response Part

approach provided by an over reliance on windfalls. This approach is supported by NPPF (paragraph 157) which states that: "Crucially, Local Plans should: ...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 ..." It is essential that the Local Plan provides for sufficient levels of housing development. Housing provision helps to support existing businesses and can also encourage new ones. In turn, this can lead to inward movement of population with additional households that are economically active in supporting existing services, facilities and businesses. There is also the issue of affordable housing need, which can be addressed by sufficient levels of housing provision. So, through the development of sufficient levels of housing, the economic prosperity and indeed social prosperity of the Borough can be supported. Policy ST2 sets a target of 10,800 homes between 2011-2031, which equates to 540 homes per annum. This is a significant reduction in housing numbers presented within previous consultation documents (13,500 within the Draft Core Strategy). This significant reduction in the number of homes in the Draft Local Plan relative to the Draft Core Strategy is therefore concerning. Whilst we acknowledge that the recession has presented significant problems for housing delivery, this has been because of a reduction in housing demand, Planner Savills (L&P) Ltd (for St Qualified Development targets for jobs Mr William Lusty LP1439 Policy ST 2 rather than housing need and it is important that this is not confused. If the Council is to be able to John's College, Cambridge) support and new homes 2011-2031 capitalise on opportunities for additional employment in the Borough, then it is essential that sufficient housing stock is therefore available to support this. Levels of development to be planned for should also be viewed within the context of the NPPF. The ‘presumption in favour of sustainable development', also means for plan-making that Local Plans ‘should meet objectively assessed needs'. The 2013 Update to the Strategic Housing Market Assessment and Development Needs Study that was commissioned by the Council forms part of the evidence base to the Local Plan and concludes that the objectively assessed housing need for the Borough is 600 - 900 dwellings per annum, equating to 12,000 to 18,000 dwellings in the plan period. Even taking a mid-range point, this equates to 15,000 dwellings over the plan period, which is in excess of 4,000 more dwellings than is now being proposed by the Council. It is acknowledged that this level of development must then be achieved within the context of the constraints that affect the Borough, but these are unlikely to have changed so significantly to justify the significant reduction that is proposed by the Council. The 10,800 houses appear to conform to the Levels proposed within the South East Plan. Providing the HRA assesses that these levels can be delivered without impacting on the integrity of the SPA and Ramsar sites, we accept this level of housing delivery is required to ensure housing needs are met. Conservation Officer, Policy and Qualified Development targets for jobs Miss Debbie Salmon LP1080 Policy ST 2 Planning Kent Wildlife Trust support and new homes 2011-2031 We welcome the clause within Policy ST1 that Planning permission will only be granted For sites requiring assessment under the Habitats Regulations, taking such actions as necessary to protect the integrity and special interest of the European designated site , however we feel that the housing numbers should be assessed as part of the strategic HRA before a final decision is made. It is confirmed in the draft that in the context of economic uncertainty the Council remains ‘ambitious and must assume a longer-term 20-year view within which things will change for the better' (para 4.1.2). The need for a strategy that is able to ‘proactively drive and support sustainable economic development' is a core principle of the National Planning Policy Framework (NPPF para 17). We consider that an ambitious development strategy needs to be reflected in the Local Plan if it is to be consistent with national policy. In this context it is submitted that the Council should be looking to Development targets for jobs produce ambitious targets for employment and housing in order to ensure that the strategy is Mr P Aelen Abacus Developments Objection LP819 Policy ST 2 and new homes 2011-2031 consistent with national guidance. The Council confirms that in order to achieve the jobs target (of 7,053) there is a need to ‘boost our supply of housing' (para 4.1.3). This is considered to be a correct response to this employment target. However, the Council does not propose to boost the supply of housing, rather it is proposed to rely on past delivery rates and it is proposed that ‘in the short to medium term (the) housing target should be close to the long term average levels of delivery'. It is proposed to set the target at some 10,800 new homes by 2031 (i.e. 540 per annum net) (para 4.1.3). This is objected to as being inconsistent with a growth agenda. In addition, past Object / Document Name Organisation Support Rep ID Title Consultee Response Part

delivery rates may not be relevant to the current and emerging economic position and the provision of an unduly cautious strategy will not serve to meet local requirements. It is noted that this stated job target ‘will ultimately require even higher levels of housing to support it' and that ‘without them our economy will not grow in the face of other competing locations' (para 4.1.4). Under these circumstances it is likely that the proposed strategy will fail to realise the necessary scale of employment as planned for as this will be constrained by a lack of an adequate workforce. The housing target of 10,800 is therefore objected to as not being adequate to address the need for local employment. The Council proposes to review these targets in the light of ‘clear and consistent signals of improved delivery in the housing market and the wider economy as a whole' (para 4.1.4). This is an acceptance that the initial targets are likely to be inadequate in any event. Under these circumstances we consider that the strategy is not appropriate to cater for an increase in development activity. In fact the Council recognises the relationship between jobs and housing and confirms that ‘a failure to deliver in one or more areas may present unsustainable outcomes' (para 4.2.4). In the absence of an adequate supply of housing to match job creation, we consider that the strategy will be unsustainable, contrary to national guidance. Delivering High Quality Homes The Council recognises that if it is possible to secure housing development of a scale that is in excess of the average achieved over the last 10 years this can trigger a Local Plan Review, (para 4.2.37) with presumably the objective of increasing the numbers to suit. This position means that the proposed strategy is not however responsive to changing circumstances and is unable to adapt to rapid changes as required (NPPF para 14). We consider that this reliance on an early review of the plan is an indication that it is deficient and fails to incorporate sufficient flexibility. Assessment of Needs It is noted that the evidence base has been updated through a 2013 study by NLP (para 4.4.1). The use of updated figures is welcomed and supported as being consistent with national guidance (NPPF para 14). It is noted that these considerations to inform the strategy are set out in the plan (Fig 4.4.1). In terms of housing need it is confirmed that the objectively assessed needs based on demographic assumptions would require between 670 and 890 dwells per annum (para 4.4.6). It is noted that the ONS projections are at the higher end of this range (a minimum of 840 dwells p.a.). It is a requirement of the NPPF that there is a need to identify these elements and to cater (as set out in the SHMA) for this level of demand with this reflected in the subsequent SHLAA (NPPF para 159). A jobs-based scenario suggests that a level of 740 dwells per annum is the minimum needed (para 4.4.7). It is firm guidance (NPPF para 14) that a local plan ‘should meet objectively assessed needs... unless any adverse effects of doing so would significantly and demonstrably outweigh the benefits... ' It is notable that the Council's proposed target (of 540 dwells per annum) is lower than the economic or demographic Development targets for jobs requirements and is recognised as such in the NLP study. On this basis, we consider that this scale Mr P Aelen Abacus Developments Objection LP821 Policy ST 2 and new homes 2011-2031 of provision fails to meet any reasonable assessment of housing need in the Borough and it is thus incompatible with national guidance. On the basis that additional housing sites are available and can be delivered in sustainable locations such as Minster, we consider that there is no justification to rely on a lower target. Setting a Target It is recognised that ‘Swale contains significant environmental constraints which affect the potential of certain areas to accommodate growth' (para 4.4.11). Whilst we accept that this may be the case, it is notable that the Council confirms that, ‘ our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets' (para 4.4.12). It is evident therefore that there is no overriding objection to the provision of growth at a higher level than is proposed by reason of environmental impact. The provision of housing in the region of 740 dwells per annum would not thus be in conflict with the national requirement to protect and enhance the environment (NPPF para 7). The need to ensure that infrastructure is provided to support development is a component of sustainable development (NPPF para 7). Although there may be some constraint on development due to the impact on the road network (and especially at J5 M2) (para 4.4.14) there is no indication of any embargo in principle on development at the higher levels of growth. The Council notes that in terms of deliverability, ‘A key consideration is the deliverability of development, both in terms of viability of development in Swale and the capacity of the housing and development markets to deliver sufficient growth at a sustained rate year on year over the whole plan period' (para 4.4.15). The Council indicates that, ‘as of 2011/12, the average level of completions in Swale were: over 5 years Object / Document Name Organisation Support Rep ID Title Consultee Response Part

(dwellings per annum) = 560; 10 years = 600' (para 4.4.16). It is therefore suggested that accordingly, the ability of the local housing market to cater for an increased rate of development is ‘untested' (para 4.4.15). This appears to be the sole reason for the Council's proposed use of a reduced housing target. In our view this position is untenable. Firstly the published KCC ‘Housing Information Audit 2011' confirms that the net dwelling completions in Swale over recent years were as follows:

Year Completions Totals 2001-2002 659 2002-2003 568 2003-2004 570 2004-2005 375 2005-2006 854 3026 2006-2007 835 2007-2008 767 2008-2009 494 2009-2010 709 2020-2011 433 3238

This means that over the last 10 years, the average rate of completions has been 626 per annum and over 5-years it has increased to 648 per annum. This has been an overall +6.4% increase. The last 5 years is of course the period that is contained in the South East Plan with approved provision at 540 dwells per annum. These figures appear to be at odds with those used by the Council but in any event they demonstrate that in the recent past the local housing market has performed to a level that is consistently in excess of the 540 rate that is now proposed. In fact over the last 10 years completions have been +16% over the planned requirement, over the last 6 years at +26% and over 5 years at +20%. We note that in 7 years out of the last 10, the performance of the market in Swale has exceeded the 540 target. It is evident from this that there is no inherent reason why the local market would not perform at a higher level in Swale given the right national economic conditions. Indeed, the average figures for the last 5 and 10 years confirm that there has been an increase in market performance in the past. Using the suggested 740 dwells per annum figure needed to support economic development, the recent market performance would only require an increase of +12.5%. This is not an excessive figure and should be capable of being achieved as noted in the SHMA (para 4.4.17). The ability of the area to accommodate additional development in the short to medium term is demonstrated through the proposed housing trajectory (see para 8.1.29). This confirms that in the period 2015 to 2019 it is anticipated that there will be completions substantially in excess of the proposed target rate, generated essentially through the implementation of extant planning permissions. This increased rate is not anticipated to be constrained by the market and so contradicts the Council's overall view that potential difficulties in the local market justify the use of a cautious target throughout the plan period. In addition, the plan confirms that development rates are ‘expected to pick up markedly' (para 8.1.31) thus confirming that there is no reason to artificially constrain the target when set against anticipated market activity. As we have noted, this level of pick up would only need to be in the region of 12% to ensure that a target consistent with that needed to provide for economic activity is achieved. Draft policy ST2 is objected to given that the specified housing target of 10,800 dwellings for the period 2011 to 2031 is considered to be too low. The use of an overall strategy that is based on an overtly pessimistic assessment of delivery is inappropriate and fails to respond to the need to significantly boost the supply of housing so as to meet objectively assessed housing needs. In this respect it is not consistent with national planning policy and the strategy is correspondingly unsound. We consider that the policy should be amended to match the scale of local housing needed to provide for the anticipated level of economic development in Swale. This suggests a minimum housing target of 14,800 dwellings (740 per annum). This figure would also move towards meeting the objectively Object / Document Name Organisation Support Rep ID Title Consultee Response Part

assessed housing needs of the area, although emerging data from the 2011 Census indicates that the regional figure should be increased which we anticipate will have a knock-on effect on the local target. The policy should also include an amended threshold for any subsequent review of the plan, triggered through monitoring when the 5-year trend falls below 665 dwells per annum (i.e. 90% of the target). This would enable the Council to consider ways in which the housing supply could be encouraged, such as the allocation of additional more viable land and/or the relaxation of costs associated with community or infrastructure provision or the scale of affordable housing. Draft policy ST2 is objected to given that the specified housing target of 10,800 dwellings for the period 2011 to 2031 is considered to be too low. The use of an overall strategy that is based on an overtly pessimistic assessment of delivery is inappropriate and fails to respond to the need to significantly boost the supply of housing so as to meet objectively assessed housing needs. In this respect it is not consistent with national planning policy and the strategy is correspondingly unsound. We consider that the policy should be amended to include a minimum housing target of Development targets for jobs 14,800 dwellings (740 per annum) which would match the scale of local housing needed to provide Mr Philip Aelen S W Attwood & Partners Objection LP829 Policy ST 2 and new homes 2011-2031 for the anticipated level of economic development in Swale and move towards meeting the objectively assessed housing needs of the area. The policy should also include an amended threshold for any subsequent review of the plan, triggered through monitoring when the 5-year trend falls below 665 dwells per annum (i.e. 90% of the target). This would enable the Council to consider ways in which the housing supply could be encouraged, such as the allocation of additional more viable land and/or the relaxation of costs associated with community or infrastructure provision or the scale of affordable housing. Draft Policy ST2 looks to provide for 10,800 dwellings during the plan period (2011- 2031) i.e. 540 dpa. The Local Development Framework Panel report of the 27 June 2013 makes it clear at paragraph 1.1 that: ' This report introduces the draft Swale Local Plan which has been prepared in accordance with Members' instruction (Cabinet Minute 638).' And that 'The plan has been redrafted for compliance with the National Planning Policy Framework (NPPF) as far as possible, but retains the housing development target of 540 dwellings per annum promoted in the draft Core Strategy 'Bearing Fruits' (March 2012).' My emphasis As set out in paragraph 1.2 of the Local Development Framework Panel report of the 27 June 2013, the report that was considered by SBC's Local Development Framework Panel on the 21 February 2013 made it clear that the additional research undertaken to ensure compliance with the NPPF had indicated that 'linked development targets of 740 dwellings per annum and 353 jobs per annum would be more compliant with the NPPF requirement that 'objectively assessed needs' be addressed within the Borough" and that 'No overriding environmental constraints were identified in respect of achieving that target' It is also clear from the Local Development Framework Panel report of the 27 June 2013 (Para 2.2) that 'members had doubts as to the deliverability of such a target, year on year for the entirety of the plan period, given the recorded performance of the local housing market in both favourable and Development targets for jobs depressed economic conditions over the last 30 years'; and that 'given the poor viability issues Judith Ashton Barratt Strategic Objection LP430 Policy ST 2 and new homes 2011-2031 currently experienced in the Borough, even on unconstrained sites and the need for key pieces of infrastructure to support significant new development and affordable housing objectives, it was considered that consistent deliverability of such a target was extremely unlikely'. Before commenting upon the level of growth proposed in draft Policy ST2 the Bearing Fruits draft Local Plan (August 2013), we feel it important to highlight the fact that restricting the scale of housing development predicated on the view that the economic downturn justifies a lower housing target is in our opinion totally inappropriate and contrary to the aspirations of the NPPF to 'boost significantly the supply of new housing'. Although the economic recovery may be taking longer than originally hoped, it is still a reasonable assumption that the economy will return to more normal levels of growth over the plan period. Whilst this is a factor which may affect the housing trajectory it is not a credible reason for reducing the overall housing target. As we have suggested before the plan could/ should provide for reserve sites in the CS as a means of assisting in the maintenance of the 5 year housing land supply - a matter that officers raised when the draft CS 'Bearing Fruits' was reported to the LDF panel meeting of the 23rd February 2012. Having regard to the above we have to advise that we do not believe the level of housing provision proposed in draft policy ST2 of the Bearing Fruits draft Local Plan August 2013 reflects the objectively assessed needs of the area as required by Para 47 and 159 of the NPPF and that as a result the Bearing Fruits draft Local Plan Object / Document Name Organisation Support Rep ID Title Consultee Response Part

August 2013 does not comply with the aims and objectives of national government guidance and is thus unsound. We say this for the following reasons:-

1. The Office for National Statistics (ONS) baseline 2010 projections suggest a need to provide for 16,840 dwellings (842dpa) over the plan period i.e. 6,040 dwellings (302dpa) more than proposed in draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013. 2. The Office for National Statistics (ONS) baseline 2011 interim projections suggest a need to provide for 17,740 dwellings (887dpa) over the plan period i.e. 6,940 dwellings (347dpa) more than proposed in draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013. 3. The What Homes Where tool kit (extract attached), which utilises the 2008-based household projections, shows a need for 14,074 dwellings over the plan period or 704dpa i.e. 3,274 dwellings (164dpa) more than proposed in draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013. 4. Population projections based upon long term migration trends suggest the need to provide for 13,420 dwellings (671dpa) over the plan period i.e. 2,620 dwellings (131dpa) more than proposed in draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013. 5. The Experian economic baseline suggests a need to provide for 12,080 dwellings (604dpa) over the plan period i.e. 1,280 dwellings (64dpa) more than proposed in draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013. 6. The East Kent SHMA update 2013 indicates that the scale of affordable housing need is acute- Table 6.1 indicates the Current Housing Need (Backlog) is 4,295, and that 1,186 affordable dwellings per annum would need to be delivered in order to meet affordable housing needs of the borough. As however this level of growth would far outstrip the underlying structural need for housing from demographic change, the SHMA goes on to suggest that an objective assessment of housing need and demand for Swale Borough falls within the range 600 to 900 dwellings per annum equivalent to 12,000 to 18,000 additional dwellings over the plan period.

Given the above, put simply, the level of growth proposed by draft Policy ST2 of the Bearing Fruits draft Local Plan August 2013 is considerably less than that which Swale BC has been identified as necessary to meet their objectively assessed needs.

• Draft Policy ST2 10,800 540dpa • ONS baseline 2010 projections16,840 842dpa • ONS- 2011 interim projections 17,740 887dpa • What Homes Where 14,074 704dpa • Population projections based upon long term migration trends13,420 671dpa • Experian - economic baseline 12,080 604dpa • East Kent SHMA update- 2013 12,000 to 18,000 600 to 900dpa

Whilst the South East Plan (SEP) may well have promoted 10,800 dwellings within Swale for the plan period 2006 - 2026 (540dpa) the fact is the evidence base for the SEP is now relatively old and recent appeal cases and high court decisions have made it clear that LPA's must base their housing requirement in their Core Strategies/ Local Plans on up to date objectively assessed needs. Given the substance of the report that was considered at the Local Development Framework Panel meeting of the 27 June 2013 it appears to us that the Bearing Fruits draft Local Plan August 2013 was formulated to support the members instructions, rather than being an objective assessment of the needs of the area and how these are to be addressed. This is clearly contrary to the aims and objectives of the NPPF and only goes to demonstrate that the plan has not been positively prepared, is not justified and will not be effective. Such that it is clearly inconsistent with the aims and objectives of national policy as set out in the NPPF. Page 10 of the Non Technical Summary of the Sustainability Appraisal (SA) makes clear that-The Council's preferred approach is Option 4 which delivers 540 dwellings and 353 jobs per annum which is 10,800 dwellings and 7,053 jobs over the plan period. This approach is broadly in accordance with the interim appraisal findings with respect to achieving the environmental related SA objectives (e.g. air, biodiversity, climate, soil, Object / Document Name Organisation Support Rep ID Title Consultee Response Part

landscape}, however it does not perform as well as other options in terms of meeting economic (i.e. local economy, employment and skills) and housing related (i.e. housing, population) SA objectives. This is because it is not based on the objectively assessed needs of the future population or the number of houses potentially needed to support the labour supply for the economic growth proposed.' My emphasis Clearly the preferred approach does not meet 2 of the 3 sustainability criteria (social and economic) set out in the NPPF and does not meet the objectively assessed needs of the area. There is no explanation as to why this approach was adopted in either the draft LP or the SA. Furthermore Para 16.6.15 and 16.8.14 of the SA indicates that 'it is recognised that the quantum of growth planned for housing in the plan set out in Policies ST2 and ST4 is not based on the employment growth forecast or demographic projections and may constrain the delivery of employment growth' and that as a result the recommendation on p108/p114 of the main report/ p13 of the Non Technical Summary SA is that the draft LPA should ' Consider revising the proposed housing growth target so that it can support the plan's economic growth identified in Policies ST2 and ST4 and the delivery of housing based on objectively assessed need.' Whilst the SA, in considering the spatial distribution strategy indicates Strategic Spatial Options considered at Stage 1 in Box 10.1 (p76), we note that all 4 options proposed some level of development at lwade. Nowhere in either the SA or the draft LP is there an explanation as to why no development is now proposed in lwade. Likewise we note that in assessing the alternative growth scenarios appendix II of the SA indicates that the Economic Baseline of 604 dwellings per annum (12,080 over the plan period) 'aims to deliver the future economic baseline based on objectively assessed need, and provides a housing supply to support the labour supply needed to deliver this.' And that 'Overall, this option is expected to perform better than Option 4 with regards to achieving economic and social objectives.' Option 4 being the Bearing Fruits draft Core Strategy 2012 figure of 540 dwellings per annum, 10,800 dwellings over the plan period P161 of appendix II refers. As it stands, the approach adopted to the scale of housing development proposed in the draft LP (policy ST2) and associated distribution of development, especially in lwade has not in our opinion been justified. In addition to the above we are unsure as to how the level of employment provision is linked to the level of housing growth. The Local Development Framework Panel report of the 27 June 2013 indicates at Para 2.13 that the plan will provide for 7,053 jobs. Thus the plan in providing 10,800 dwellings will be providing more than 1 house per job. Whilst this would appear to make sense given the fact the SHMA 2013 update indicates at Para 7.8 that 'The number of elderly households (defined as households where all members are aged 65 or more) currently totals 11,873 accounting for 21.4% of all households' and that 'The KCC demographic projections suggest this is set to increase by c.5,690 households under the modelled 2011-based SNPP scenario, accounting for up to 50% of all net household growth' it could well be that in order to accommodate the growing needs of the elderly there needs to be a greater level of housing growth than proposed if the boroughs economic targets are to be achieved and the governments aims and aspirations as set out in the NPPF- i.e. to build a strong competitive economy and deliver a wide choice of high quality housing, are also to be achieved. Indeed Table 5.1 of the SHMA 2013 update which summarises demographic, economic and housing scenarios over the period 2011-2031 indicates that in order to accommodate circa 7000 jobs over the plan period the plan needs to provide for 14,811 - 16, 848 dwelling dependent upon whether one adopts an economic or demographic approach to the population projections. To this end we note that Para 5.26 of the SHMA (2013 update) indicates that adopting a SEP Housing Target of 540 dwellings per annum in Swale will ‘ substantially constrains the size of the labour force and creation of jobs compared to the Baseline and 2011 SNPP scenarios. This results in the labour force increasing by 3,299 economically active people and only 154 new jobs by 14 per annum' Finally, in terms of the Duty to Cooperate, it is unclear to us whether the adjacent boroughs of Maidstone. Ashford, Canterbury and Medway have agreed to accommodate the shortfall in housing provision bought about by SBC's failure to meet their objectively assessed needs - if there is no agreement in place how is this matter to be addressed? The Draft Local Plan and associated SA both need to explain how the duty to cooperate has been taken into account, and how containing growth in the way proposed looks to address both swale and its neighbouring authorities needs/ will help the local economy. How can Barratt Strategic's concerns be addressed Para 159 of the NPPF is clear on plan making for housing. The starting point is to prepare the SHMA which should identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which: -meets household and Object / Document Name Organisation Support Rep ID Title Consultee Response Part

population projections, taking account of migration and demographic change; -addresses the need for all types of housing, including affordable housing and the needs of different groups in the community ....and -caters for housing demand and the scale of housing supply necessary to meet this demand; Thereafter the LPA should prepare a SHLAA to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period. In formulating their housing requirement Swale BC must have regard to their up to date objectively assessed housing needs, they then need to establish from the SHLAA whether they have the land available to meet that need. Having regard to the conclusions on the population projections outlined above its clear there is a wide range, all of which exceeds that proposed in the Draft Local Plan. On that basis, and assuming a conservative requirement, we believe the Swale LP should be looking to provide for circa 14,000- 15,000 dwellings over the plan period 2011-2031 (i.e. 700- 750dpa). Appendix 4 of the SHLAA clearly indicates that sufficient sites have been identified that are suitable, achievable and available to provide for 8616 dwellings, in addition to those that have already been completed (397), have permission (2192), are existing local plan commitments (not clear), and windfalls (1449). This includes 80 dwellings on land at Cryalls Lane Sittingbourne (SHLAA ref SW126) and 311 dwellings on land east of lwade (SHLAA ref SW123). Conclusions:- We do not believe the level of housing proposed in the borough has been justified. It does not reflect the objectively assessed needs of the area and as such has not been positively prepared and will not 'boost significantly the supply of housing'. There is in addition nothing to demonstrate that the plan will be effective. The plan thus conflicts with the aims and objectives of national policy as set out in the NPPF and is unsound. The only recourse open to SBC is to review the housing requirement, increase the housing target and identify additional land through a review of the settlement boundaries of the more sustainable settlements such as lwade, to meet the objectively assessed needs of the district. Whilst we trust the above is of assistance we would be happy to meet with officers to discuss the concerns we have raised further if they felt this would assist them in moving the Borough Plan forward. Objection to this policy with respect to land east of Love Lane, Faversham. Development targets for jobs Mr Attwood Attwood Trust Objection LP1016 Policy ST 2 and new homes 2011-2031 Details as per attached file. MPC asks for a 'jobs first' approach to homes in Swale. This is not reflected in current policy. In Parish Clerk Minster-on-Sea Parish Development targets for jobs Mrs Trish Codrington Objection LP224 Policy ST 2 addition the job target is considered too low and does not meet the housing target. This will create Council and new homes 2011-2031 future social and economic problems. In answer to the detailed questions raised in your letter:- i) the Borough Council’s annualised housing target as set out in the 2008 Core Strategy amounts to about 1,175 dwellings per annum across the whole Plan period from 2006-21, the vast majority of which is planned for the Ashford urban area and its immediate surroundings. This reflects the South East Plan figures for the Borough. ii) The Council has commissioned an updated Strategic Housing Market Assessment (alongside Maidstone and Tonbridge & Malling Borough Councils) and we have only recently received a draft report which is currently being digested. It is our intention to publish the report early in the New Year following discussions with Members. iii) In our opinion, the borough does have a 5 year land supply of deliverable housing land albeit with very little buffer – see the recently published KCC Housing Information Audit for 2012/13. iv) See (ii) above. v) The initial outcomes from the Policy Manager Ashford Borough Development targets for jobs SHMA indicate an objectively assessed housing for the borough lower than the ‘policy-driven’ Core Mr Simon Cole Objection LP1614 Policy ST 2 Council and new homes 2011-2031 Strategy / South East Plan target. vi) Whilst the SHMA outputs will be crucial in the Council’s reassessment of housing targets in the new Local Plan 2030 (which will supersede the 2008 Core Strategy), it is understood that this is not necessarily the only issue that would determine a development target for the borough. At present, it is too early to say what the eventual housing target for the borough in the new Local Plan will be. vii) As I have alluded to above, the borough council is in the process of identifying the scale of its objectively assessed needs when considered against the existing and emerging government guidance on the issue. We fully understand the need to proactively participate in the Duty to Co-operate and learn lessons from other areas of the country who are dealing with similar issues. To that end, although it is too soon to be able to indicate whether it would be possible for Ashford to accommodate the unmet housing needs of any other local authority, we do recognise the need for an on-going dialogue to hopefully resolve Object / Document Name Organisation Support Rep ID Title Consultee Response Part

problems as far as possible and avoid the prospect of needing to object to neighbours’ Local Plans. We act for G H Dean & Co Limited, the owner of various and substantial tracts of land in the Sittingbourne area. G H Dean & Co Ltd object to the development target for housing set in Policy ST2 because, put simply, it fails to satisfy objectively assessed housing need as required by the NPPF. The objectively assessed need for housing and the balance between housing and employment land provision has been set out on behalf of the Council in the reports prepared by Nathaniel Lichfield & Partners (NLP) - the content of these reports is not repeated here. Safe to say that if the Council is truly committed to an employment led strategy in its Plan then the housing target must be calibrated accordingly. The Council's position is summed up in para 4.4.7 of the Plan with a target of 740 dpa. This was described by officers at para 2.22 of the LDF Framework Panel Report of 21 st February 2013, "this scenario would generate a need for 741 dwellings per annum. Housing delivery totals of more than 700 dwelling have been delivered in 5 years out of the past 20. Option G therefore represents a jobs-led scenario which demonstrates good levels of ambition for economic regeneration which has a realistic chance of being achieved and implies a challenging but achievable (given a favourable economic context) housing target to support it." In paras 4.4.11 - 4.4.25 of the Plan the Officers have made a valiant effort to "muddy the water" and seek to justify a housing target below that objectively assessed on the Council's behalf by NLP, ie by praying in aid environmental constraints; infrastructure constraints (particularly J5 of M2) and deliverability constraints whereas, pointedly, the Council's own Sustainability Appraisal highlights the need to increase housing provision to support the Plan's Development targets for jobs economic growth. Clearly, if the Sustainability Appraisal indicates the need for additional housing G H Dean G H Dean & Co Objection LP355 Policy ST 2 and new homes 2011-2031 provision to support the economic objectives and that additional housing is not to be provided, then, in failing the Sustainability Assessment, the Plan cannot be sustainable. If the Plan is not sustainable then, again, it is in diametric conflict with the advice on sustainable development in the NPPF. Inevitably, the Plan will be found fundamentally unsound. Although the Borough has been located within the Thames Gateway Growth Area for several decades, the Council has never fully embraced the growth area concept. Even now, although Maidstone is identified merely as a growth "point" (where growth is intended to be only a fraction of that which might occur in a growth "area",) the scale of planned growth at Maidstone far exceeds that of Swale. Tellingly, in the context of the South East Plan, whilst highly constrained districts further to the west were planning to increase housing provision by a factor of 2 or 3, Swale on the other hand planned to reduce housing targets. As a result, the EIP Panel increased housing provision in Swale by a token 1000 units but noted that Swale is the least constrained district with the Thames Gateway Growth Area. NPPF requirements to boost significantly the supply of housing and meet the full objectively assessed needs for housing, demonstrably, are not met by this Plan. Even with a "moderated" jobs target the housing target is woefully inadequate and the suggestion of a Local Plan Review if jobs and housing targets move out of alignment in the longer term is, in fact, a certainty from the outset. It is clear to us that in the context of NPPF advice any Submission Draft Plan submitted to the Secretary of State with the current jobs and housing targets will be summarily rejected and will not be allowed to proceed to EIP. The Council is therefore requested to revisit its jobs and housing targets and adopt a housing target of 740 dpa in line with the objectively assessed need. The Inadequacy of the Housing Provision The basis of this objection is that the Council has not made sufficient provision for housing in the Draft Local Plan. Provision has been made for 10800 dwellings between 2011 and 2032, which equates to 540 dwellings per annum. Of all the Scenarios for housing requirements illustrated by figure 4.4.5 of the Local Plan, only the unrealistic "zero net migration" option is lower. The other Scenarios vary from a requirement for 604 to 1186 dwellings per annum. Demographic changes alone would require 670 to 890 dwellings. In 2013 the Council Development targets for jobs commissioned a report by Nathanial Litchfield on housing requirements in relation to economic Mr Mick Drury Partner BDB Design LLP Objection LP286 Policy ST 2 and new homes 2011-2031 performance. This recommended that the Council should consider a range of 600 to 900 dwellings per annum. The Council's own officers recommended that the Council adopt a target of 740 dwellings per annum, which is the number of houses required to support the higher scenario for employment growth of 7053 jobs over the plan period. This does not in itself represent a particularly ambitious jobs target and is a lower rate of employment growth than Swale experienced in the years prior to the recession. The Council has nevertheless adopted the 7053 target for employment growth in the Local Plan but at 540 dwellings per annum has allocated insufficient houses to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

support it. The Plan recognises the consequences of this. Paragraph 4.1.4 states that the 7053 jobs target "will ultimately require even higher levels of housing to support it." Paragraph 4.4.23 acknowledges that: "the preferred housing target is below objectively assessed development needs." The Council's answer is to promise an early review of the Local Plan if circumstances require it. We do not consider that this is an adequate or responsible response. Paragraph 4.4.50 stresses the need to ensure that there are as few barriers as possible to kick starting the Swale economy. A Local Plan review will take time, possibly several years, not to mention the cost to the Council and Developers and would be a serious barrier to the economic growth of the Borough if, as seems likely as the national economy improves, housing provision fails to keep pace with employment growth. This will create uncertainty and could lead to "planning by appeal" scenario in Swale. It would also make it difficult for the Borough to maintain a 5-year housing land supply as required by the NPPF (Swale only has a 3 year supply at present). We would therefore argue that the Council should meet the housing needs of the Borough over the Plan period to 2032 at the present time, by allocating sufficient housing land at the very least to meet the pragmatic recommendation of officers of a target of 740 dwellings per annum. In this way housing provision would at least meet the Plan's employment targets, and would not represent a somewhat arbitrary lower figure, unrelated to any other strategic targets in the Plan. To achieve this would require additional allocations for 4000 dwellings. We object to the scale of housing development proposed in the Local Plan, on the grounds that it is inadequate to meet the future needs of the Borough.

The basis of this objection is that the Council has not made sufficient provision for housing in the Draft Local Plan. Provision has been made for 10800 dwellings between 2011 and 2032, which equates to 540 dwellings per annum. Of all the Scenarios for housing requirements illustrated by figure 4.4.5 of the Local Plan, only the unrealistic "zero net migration" option is lower. The other Scenarios vary from a requirement for 604 to 1186 dwellings per annum. Demographic changes alone would require 670 to 890 dwellings. In 2013 the Council commissioned a report by Nathanial Litchfield on housing requirements in relation to economic performance. This recommended that the Council should consider a range of 600 to 900 dwellings per annum. The Council's own officers recommended that the Council adopt a target of 740 dwellings per annum, which is the number of houses required to support the higher scenario for employment growth of 7053 jobs over the plan period. This does not in itself represent a particularly ambitious jobs target and is a lower rate of employment growth than Swale experienced in the years prior to the recession. The Council has nevertheless adopted the 7053 target for employment growth in the Local Plan but at 540 dwellings per annum has allocated insufficient houses to support it. Development targets for jobs c/o Mick Drury Crabtree & Crabtree Objection LP293 Policy ST 2 The Plan recognises the consequences of this. Paragraph 4.1.4 states that the 7053 jobs target "will and new homes 2011-2031 ultimately require even higher levels of housing to support it." Paragraph 4.4.23 acknowledges that: "the preferred housing target is below objectively assessed development needs." The Council's answer is to promise an early review of the Local Plan if circumstances require it. We do not consider that this is an adequate or responsible response. Paragraph 4.4.50 stresses the need to ensure that there are as few barriers as possible to kick starting the Swale economy. A Local Plan review will take time, possibly several years, not to mention the cost to the Council and Developers and would be a serious barrier to the economic growth of the Borough if, as seems likely as the national economy improves, housing provision fails to keep pace with employment growth. This will create uncertainty and could lead to "planning by appeal" scenario in Swale. It would also make it difficult for the Borough to maintain a 5-year housing land supply as required by the NPPF (Swale only has a 3 year supply at present).

We would therefore argue that the Council should meet the housing needs of the Borough over the Plan period to 2032 at the present time, by allocating sufficient housing land at the very least to meet the pragmatic recommendation of officers of a target of 740 dwellings per annum. In this way housing provision would at least meet the Plan's employment targets, and would not represent a somewhat arbitrary lower figure, unrelated to any other strategic targets in the Plan. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We ask for an additional 4000 dwellings to be identified on land and sites The Brett Group considers that the Council has not made sufficient provision for housing in the Draft Local Plan.

Provision has been made for 10800 dwellings between 2011 and 2032, which equates to 540 dwellings per annum. Of all the Scenarios for housing requirements illustrated by figure 4.4.5 of the Local Plan, only the unrealistic "zero net migration" option is lower. The other Scenarios vary from a requirement for 604 to 1186 dwellings per annum. Demographic changes alone would require 670 to 890 dwellings.

In 2013 the Council commissioned a report by Nathanial Litchfield on housing requirements in relation to economic performance. This recommended that the Council should consider a range of 600 to 900 dwellings per annum. The Council's own officers recommended that the Council adopt a target of 740 dwellings per annum, which is the number of houses required to support the higher scenario for employment growth of 7053 jobs over the plan period. This does not in itself represent a particularly ambitious jobs target and is a lower rate of employment growth than Swale experienced in the years prior to the recession. The Council has nevertheless adopted the 7053 target for employment growth in the Local Plan but at 540 dwellings per annum has allocated insufficient houses to support it.The Plan recognises the consequences of this. Paragraph 4.1.4 states that the 7053 jobs target "will ultimately require even higher levels of housing to support it." Paragraph 4.4.23 acknowledges that: "the preferred housing target is below objectively assessed development needs." The Council's answer is to promise an early review of the Local Plan if circumstances require it.

The Brett Group does not consider that this is an adequate or responsible response. Paragraph 4.4.50 stresses the need to ensure that there are as few barriers as possible to kick starting the Development targets for jobs Swale economy. A Local Plan review will take time, possibly several years, not to mention the cost Mr Mick Drury Brett Group Objection LP324 Policy ST 2 and new homes 2011-2031 to the Council and Developers and would be a serious barrier to the economic growth of the Borough if, as seems likely as the national economy improves, housing provision fails to keep pace with employment growth. This will create uncertainty and could lead to "planning by appeal" scenario in Swale. It would also make it difficult for the Borough to maintain a 5-year housing land supply as required by the NPPF (Swale only has a 3 year supply at present).

The Brett Group would therefore argue that the Council should meet the housing needs of the Borough over the Plan period to 2032 at the present time, by allocating sufficient housing land at the very least to meet the pragmatic recommendation of officers of a target of 740 dwellings per annum. In this way housing provision would at least meet the Plan's employment targets, and would not represent a somewhat arbitrary lower figure, unrelated to any other strategic targets in the Plan. To achieve this would require additional allocations for 4000 dwellings. It is accepted that the bulk of any additional provision should be steered to the Thames Gateway part of the Borough. Faversham should nevertheless take its share and the local economy would benefit from the additional spending power. On the basis of the distribution of the existing allocations in the draft Local Plan, a figure of an additional 200 to 300 dwellings is suggested.

Paragraph 6.3.10 of the draft Plan recognises that the developer believes that an additional 100 houses at Oare Lakes could be supported and states that this will be further assessed during the consultation period on the draft Local Plan. Work undertaken at Oare Lakes, set out in the summaries which accompany this Representation, has established that the site is capable of accommodating 280 dwellings at a density of 30 dph, within the general area allocated for development in the draft Local Plan. There would not be any increase in flood risk, the increase is acceptable in transport terms, and the additional housing would not detract in any way from the site's ecological and heritage potential. An increase of 130 over the 150 dwellings at present allocated would make a useful contribution towards meeting the shortfall in housing provision generally. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

This letter is in response to the above consultation and provides Gladman Developments' representations. We understand that the current consultation seeks views on the Council's draft Local Plan Part 1. This follows the authority's previous consultation on its draft Core Strategy in spring 2012. The National Planning Policy Framework (The Framework) has been with us now for over a year and the industry is beginning to get to grips with its application and the need for some fundamental changes in the way in which planning operates. One such change relates to the need to significantly boost the supply of housing and how this fundamental requirement of the Framework should be reflected in the plan making process. Gladman, who operate on a national basis, have had the opportunity to become involved in a number of local plan preparation processes since the Framework was brought into force including participation in the Examination stage and have gained significant experience as a result. What continues to be clear from this experience is that many local authorities have not fully addressed the requirements of the Framework when preparing their Local Plans and this has led to significant concerns being expressed by Inspectors on the soundness of their plans in their current format. The main concerns centre upon the requirement in the Framework to "use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area" (§47). The process of undertaking an objective assessment is clearly set out in the Framework principally in §14, §47, §152 and §159 and should be undertaken in a systematic and transparent way to ensure that the plan is based on a robust evidence base. The starting point for this assessment is set out in §159 which requires local planning authorities to have a clear understanding of housing needs in their area. This involves the preparation of a Strategic Housing Market Assessment (SHMA) working with neighbouring authorities where housing market areas cross administrative areas. The Framework goes on to set out the factors that should be included in a SHMA including identifying "the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:

• Meets household and population projections taking account of migration and demographic Development targets for jobs Mr Peter Dutton Gladman Developments Objection LP1493 Policy ST 2 change; and new homes 2011-2031 • Addresses the need for all types of housing including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and • Caters for housing demand and the scale of housing supply necessary to meet this demand."

Key points that are worth noting from the above is that the objective assessment should identify the full need for housing before the Council consider undertaking any process of assessing the ability to deliver this figure. In addition, §159 specifically relates to catering for both housing need and housing demand within the authority area. It is worth pointing out that any assessment of housing need and demand within a SHMA must also consider the following factors; falling household formation rates, net inward migration, the need to address the under provision of housing from the previous local plan period, the preliminary results of the Census 2011, housing vacancy rates including the need to factor in a 3% housing vacancy rate for churn in the housing market, economic factors to ensure that the economic forecasts for an area are supported by sufficient housing to deliver economic growth, offsetting a falling working age population by providing enough housing to ensure retiring workers can be replaced by incoming residents, addressing affordability and delivering the full need for affordable housing in an area. It is our understanding that a majority of the SHMAs that were prepared under the current guidance on SHMA preparation are not Framework compliant and do not consider the full range of factors that are outlined in §159. This is causing significant problems for authorities currently at Examination and therefore, to avoid this issue, SHMAs should be updated to take account of the Framework and ensure plans are based on robust and up-to-date evidence. Indeed, the Government have noted the deficiency in SHMAs and are updating the guidance on SHMA preparation to fully reflect the guidance given in the Framework. Following the exercise to identify the full, objectively assessed need for housing in an area, the local planning authority should then seek to undertake the assessment outlined in §152 Object / Document Name Organisation Support Rep ID Title Consultee Response Part

of the Framework. This states that "Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where adverse impacts are unavoidable, measures to mitigate the impact should be considered. Where adequate mitigation measures are not possible, compensatory measures may be appropriate." This statement clearly sets out that local planning authorities should seek to deliver the full, objectively assessed need and that this should be tested through the evidence base. Only where the evidence shows that this is not achievable should they then test other options to see if any significant adverse impacts could be reduced or eliminated by pursuing these options. If this is not possible then they should test if the significant adverse impacts could be mitigated and where this is not possible, where compensatory measures may be appropriate. The final stage of the process is outlined in §14 and involves a planning judgement as to whether, following all of the stages of the process outlined above, "any adverse impacts of meeting the objectively assessed needs would significantly and demonstrably outweigh the benefits, when assessed against the policies in this framework taken as a whole or specific policies in this Framework indicate development should be restricted." It is also worth noting that the final part of this sentence refers to footnote 9 which sets out the types of policies that the Government consider to be restrictive. These include "sites protected under the Birds and Habitat Directive (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion". Although this list is not exhaustive it is clear that local landscape designations, intrinsic value of the countryside, the character of areas, green gaps etc are not specifically mentioned as constraints. As the Council may already be aware, the Government has recently issued a guidance note to support local authorities in objectively assessing and evidencing development needs for housing (both market and affordable) and economic development. This document supports and provides further guidance on the process of undertaking such assessments as set out in the Framework. Gladman highlight the following key points from this document:

• Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, infrastructure or environmental constraints. • Household projections published by the Department for Communities and Local Government should provide the starting point estimate of overall housing need. • Household projection based estimates of housing need may need adjusting to reflect factors affecting local demography and household formation rates which are not captured by past trends, for example historic suppression by under supply and worsening affordability of housing. The assessment will need to reflect the consequences of past under delivery and the extent to which household formation rates have been constrained by supply. • Plan makers need to consider increasing their housing numbers where the supply of working age population is less than projected job growth, to prevent unsustainable commuting patterns and reduced local business resilience. • If the historic rate of development shows that actual supply falls below planned supply, future supply should be increased to reflect the likelihood of under-delivery of a plan. • Plan makers should take account of concealed households. • Housing needs indicated by household projections should be adjusted to reflect appropriate market signals, as well as other market indicators of the balance between the demand for and supply of dwellings. Appropriate comparisons of indicators (land prices, house prices etc) should be made - with longer term trends in the HMA, similar demographic and economic areas, and nationally. Divergence under any of these circumstances will require upward adjustment to planned housing numbers. • The more significant the affordability constraints (as reflected in rising prices and rents, and worsening affordability ratio) and the stronger other indicators of high demand (e.g. the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

differential between land prices), the larger the improvement in affordability needed, and the larger the additional supply response should be.

Market signals are affected by a number of economic factors. Plan makers should increase planned supply by an amount that, on reasonable assumptions and consistent with principles of sustainable development, could be expected to improve affordability. This guidance is a material consideration, and whist limited weight can only be attached to it at this stage it is a clear indication of the Government's direction of travel to which the Council should pay due regard through the preparation of its Plan. Policy ST2 of the Council's draft Local Plan sets out an overall housing requirement of 10,800 new homes over the Local Plan period 2011-2031, equating to 540 dpa. Reviewing the Council's evidence Gladman submit that this requirement is unjustifiably low and does not take into account the authority's full, objectively assessed housing needs. The Council's 2013 SHMA recommended that the Council progress a dwelling requirement of between 600 and 900 new dwellings. The Council would need to provide 887 dpa to meet its demographic needs alone, whilst 741 dpa would be required to align with the authority's draft job target. The Council has not planned to meet its objectively assessed needs. It should not base its housing requirements on the now abolished South East Regional Strategy or political decisions. Gladman believe that further consideration needs to be given in relation to the proposed housing requirement to ensure that this is in line with the process for determining objectively assessed need as outlined in paragraphs 158, 159, 152 and 14 of the Framework. The Council has not shown that the impacts of meeting a substantially higher requirement would significantly and demonstrably outweigh the housing and economic benefits. The Council must not constrain its housing requirement based on what it considers to be deliverable. It should not progress its Local Plan to adoption with an arbitrarily low housing requirement and on the basis of undertaking a plan review. With regards to your SHMA, as you may be aware the Office for National Statistics recently issued interim-2011 based household projections. These should now be factored into your future housing scenarios to provide an up-to- date understanding of future housing requirements in your area. We consider that these projections should be used with some caution, as they are likely to have been influenced by short term issues affecting the housing market and economy, and that when these ease household formation rates are likely to return to a pre-recession trajectory over the longer term. Gladman note that even these conservative projections set a requirement for 905 dpa in Swale. The provision of affordable housing is a key priority that Council's seek to achieve through their Local Plan. However the only way to improve affordability is to provide housing. If the evidence base suggests that a certain level of affordable housing is required and the local planning authority are not seeking to address this through their Local Plan then the affordability gap will only get worse. Local Plan housing requirements should therefore reflect the full need for affordable housing provision as required by paragraph 47 of the Framework if addressing affordability is to be achieved. Gladman note that the Council's proposed housing requirement is likely to constrain the scope for addressing affordable housing needs in Swale, with a significant annual need for 1,830 affordable dwellings in the borough. This supports the need to increase the Council's overall housing requirement. The Council should note guidance set out in the Government's recent Assessment of Housing and Economic Development Needs guidance document in this regard, which states that "The total affordable housing need should then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the Local Plan should be considered where it could help deliver the required number of affordable homes". At the heart of the Framework is the Presumption in Favour of Sustainable Development. The Framework sets out that this should be seen as a golden thread running through both plan making and decision taking. The Framework outlines that all Plans should be based on and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption will be applied locally. The Council's Local Plan currently refers to the presumption in the supporting text for Policy ST1. Gladman submit that it would be more appropriate to make reference to the presumption in the policy itself, to make it clear that that development which is sustainable should go ahead. In relation to the presumption the Council refers to sluggish progress on creating jobs or new homes as potential justification for reviewing the scale and pace of growth. Gladman again submit that this would not be a sound Object / Document Name Organisation Support Rep ID Title Consultee Response Part

reason for the Council to ignore its full, objectively assessed housing needs, or refuse planning applications. It is important to stress that the process outlined above in relation to determining the objectively assessed need should be undertaken with full regard to the Duty to Cooperate as set out in §110 of the Localism Act. This ensures that if the needs of the authority cannot be fully met within their own area then the surrounding authorities agree to accommodate the shortfall or, if the surrounding authorities cannot meet their full need, then the shortfall is picked up within your authority. The Council needs to undertake the Duty to Cooperate with meaningful results. If it does not adequately address its unmet housing needs through the Duty it runs the risk its Plan being found unsound and its approach would not be legally compliant. In terms of Spatial Distribution, your authority has a number of different and distinct housing market areas. Each of these distinct areas will have their own requirement for housing and this should be reflected in the spatial distribution of housing supply within the Local Plan. This decision should be based on the findings of the evidence base and should not be a politically driven spatial strategy to put a disproportionate amount of housing in areas where people don't want to (and will not) live. If the spatial distribution does not reflect need/demand as shown by the evidence base, then the housing will not be delivered and the Plan will not be implemented. Following a dispersed spatial distribution pattern across a large number of settlements is also undesirable as this approach is not likely to be sustainable, will not be delivered and cannot generate the level of community benefits that larger sites can to help make settlements more sustainable and fill important gaps in community provision. Gladman are generally supportive of the Council's approach to direct development to main and local centre settlements. Growth should be distributed to sustainable locations in key settlements with established facilities, services and infrastructure. This is in accordance with the key theme running through the Framework of promoting sustainable development. However, this should not preclude development in lower order sustainable settlements, which could also help to sustain existing facilities and services. The level of growth directed to each settlement should be reviewed in light of meeting a higher housing requirement and their ability to accommodate sustainable, deliverable development. Gladman note that the Council are directing a significant portion of their housing growth to several large sites. The Council should distribute growth to a range of sustainable sites that will support the Council's strategy and deliver housing to meet the authority's needs. The Plan needs to provide sufficient flexibility to address situations where housing does not come forward as expected. In this regard it may be necessary to plan for the release of additional housing sites, and earlier in the Plan period, to maintain a five-year housing land supply. In some instances this objective may be best achieved through sustainable, deliverable sites that do not benefit from a formal Plan designation. Several of the Local Plan's policies refer to developer contributions. In this regard Gladman remind the Council of their obligations in respect of ensuring the viability and deliverability of development in accordance with §173 of the Framework. This paragraph states that "Plans should be deliverable. Therefore the sites and scale of development in the Plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened". Any policy obligations should be founded on robust evidence and should not act to restrict development coming forward. Conclusions What is clear from the Framework, and from the Government's agenda to boost significantly the supply of housing, is that the premise of the whole process is the assessment and delivery of the full, objectively assessed needs for housing in an area unless there are adverse impacts that would significantly and demonstrably outweigh the benefits. If the process set out in the Framework and highlighted above is not followed then the Council run the real risk of the plan being found unsound and this will create significant delay and uncertainty in the process. All of our best interests are served by your authority getting a Local Plan found sound at the earliest possible opportunity, rather than us utilising considerable resources on preparing for and attending EIPs, preparing Judicial Reviews etc. This approach will put the authority back in control of planning in their area and will give the Members comfort and certainty over the level and location of development that will take place over the lifetime of the Plan. If you decide to progress a strategy that is contrary to your evidence base you will be aware that early on in your process, you will need to provide a Consequences Report. These are necessary to justify any form of departure from the evidence base and to allow everyone to fully understand the consequences of following an alternative strategy. Gladman have raised significant concerns in relation to the ‘soundness' of the Local Plan (with reference to tests of soundness outlined in paragraph 182 of the Framework). The Local Plan does not provide a positive policy approach and Object / Document Name Organisation Support Rep ID Title Consultee Response Part

in a number of cases is not consistent with national policy. Key areas where Gladman raise concerns are summarised as follows:

• Housing requirement -The Council's proposed housing requirement is substantially lower than the authority's true, full objectively assessed needs. The Council has not shown that the impacts of meeting a higher requirement would significantly and demonstrably outweigh the housing and economic benefits. It is not sound to constrain the authority's housing requirement based on what the Council considers to be deliverable. • Affordable Housing - Gladman note that the Council's proposed housing requirement will significantly constrain the scope for addressing affordable housing needs in Swale. This supports the need to increase the Council's overall housing requirement. • Duty to Cooperate - The Council needs to undertake the Duty to Cooperate with meaningful results. If it does not adequately address its unmet housing needs through the Duty it runs the risk its Plan being found unsound and its approach would not be legally compliant. • Spatial Distribution - The Plan should provide sufficient flexibility to address situations where housing does not come forward as expected. It should direct development to a broad range of sites and plan for the release of additional housing sites, and earlier in the Plan period, to maintain a five-year housing land supply if required. • Viability - Several of the Local Plan's policies refer to developer contributions. Such polices should meet the requirements of §173 of the Framework. Any policy obligations should be founded on robust evidence and should not act to restrict development coming forward.

We act for E J Mackelden & Sons (Bobbing) Ltd the owner of various tracts of land on the west side of Sittingbourne. E J Mackelden & Sons (Bobbing) Ltd object to the development target for housing set in Policy ST2 because, put simply, it fails to satisfy objectively assessed housing need as required by the NPPF. The objectively assessed need for housing and the balance between housing and employment land provision has been set out on behalf of the Council in the reports prepared by Nathaniel Lichfield & Partners - the content of these reports is not repeated here. Save to say that if the Council is truly committed to an employment led strategy in its Plan then the housing target must be calibrated accordingly. The Council's position is summed up in para 4.4.7 of the Plan with a target of 740 dpa. This was described by officers at para 2.22 of the LDF Framework Panel Report of 21 st February 2013, "this scenario would generate a need for 741 dwellings per annum. Housing delivery totals of more than 700 dwelling have been delivered in 5 years out of the past 20. Option G therefore represents a jobs-led scenario which demonstrates good levels of ambition for economic regeneration which has a realistic chance of being achieved and implies a challenging but achievable (given a favourable economic context) housing target to support it." In paras 4.4.11 - 4.4.25 of the Plan the Officers have made a valiant effort to "muddy the water" and seek to justify a housing target below that objectively assessed on the Council's behalf by NLP, ie Development targets for jobs E J Mackelden & Sons Ltd Objection LP367 Policy ST 2 by praying in aid environmental constraints; infrastructure constraints (particularly J5 of M2) and and new homes 2011-2031 deliverability constraints whereas, pointedly, the Council's own Sustainability Appraisal highlights the need to increase housing provision to support the Plan's economic growth. Clearly, if the Sustainability Appraisal indicates the need for additional housing provision to support the economic objectives and that additional housing is not to be provided, then, in failing the Sustainability Assessment, the Plan cannot be sustainable. If the Plan is not sustainable then, again, it is in diametric conflict with the advice on sustainable development in the NPPF. Inevitably, the Plan will be found fundamentally unsound. Although the Borough has been located within the Thames Gateway Growth Area for several decades, it has never fully embraced the growth area concept. Even now, although Maidstone is identified merely as a "growth point" (where growth is intended to be only a fraction of that which might occur in a "growth area"), the scale of planned growth at Maidstone far exceeds that of Swale. Tellingly, in the context of the South East Plan, whilst highly constrained districts further to the west were planning to increase housing provision by a factor of 2 or 3, Swale on the other hand planned to reduce housing targets. As a result, the EIP Panel increased housing provision in Swale by a token 1000 units but noted that Swale is the least constrained district with the Thames Gateway Growth Area. NPPF requirements to boost significantly the supply of housing and meet the full objectively assessed needs for housing, Object / Document Name Organisation Support Rep ID Title Consultee Response Part

demonstrably, are not met by this Plan.

The projected house requirements are far beyond what is needed for natural growth of the Borough as a whole. The type of housing likely - based on that of the past 15 years - will be overwhelmingly above the affordability of most Swale residents. This means that Swale are effectively building for people migrating into the area, whilst failing to provide adequate affordable housing for people already living here. This is nonsensical. It also means that most of the people moving into the Development targets for jobs Mrs Lynda Fisher Borden Parish Council Objection LP403 Policy ST 2 borough will be commuting to work - largely in London. This replicates the pattern of the past 10 and new homes 2011-2031 years. Getting to Sittingbourne railway station is already difficult due to the weight of traffic on the A2 and associated roads, and although slightly alleviated by the recent northern relief road, this benefit will soon be lost with the new house building. A proposal for metro rail stops at Bobbing and Bapchild which could have helped alleviate this gridlock in Sittingbourne centre does not seem to be supported by Swale Borough Council. Draft policy ST2 is objected to given that the specified housing target of 10,800 dwellings for the period 2011 to 2031 is considered to be too low. The use of an overall strategy that is based on an overtly pessimistic assessment of delivery is inappropriate and fails to respond to the need to significantly boost the supply of housing so as to meet objectively assessed housing needs. In this respect it is not consistent with national planning policy and the strategy is correspondingly unsound. We consider that the policy should be amended to include a minimum housing target of Development targets for jobs 14,800 dwellings (740 per annum) which would match the scale of local housing needed to provide Floplast Ltd Objection LP1078 Policy ST 2 and new homes 2011-2031 for the anticipated level of economic development in Swale and move towards meeting the objectively assessed housing needs of the area in a sustainable manner. The policy should also include an amended threshold for any subsequent review of the plan, triggered through monitoring when the 5-year trend falls below 665 dwellings per annum (i.e. 90% of the target). This would enable the Council to consider ways in which the housing supply could be encouraged, such as the allocation of additional more viable land and/or the relaxation of costs associated with community or infrastructure provision or the scale of affordable housing. Trenport is concerned at the setting of the housing target at 540 dwellings per annum, or 10,800 dwellings for the plan period 2011-2031, which is at a level below the Council’s own objectively assessed housing need, especially bearing in mind that 4.4.12 states that – ‘Our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands Development targets for jobs of the 600-900 housing range would significantly adversely affect the Borough's principal Chris Hall Trenport Investments Ltd Objection LP786 Policy ST 2 and new homes 2011-2031 environmental assets’. Trenport is also concerned that the total jobs target for 2011 to 2031 has reduced to 7,053 (353 per annum) compared to the jobs target of 8,548 for the same period set out in the Draft Core Strategy: Bearing Fruits (March 2012). Trenport welcomes the commitment to review the Local Plan (in the circumstances set out in ST 2) in order to help overcome possible concerns from others that the Plan could be unsound in the light of the under-provision of housing. We ask you to review your targets for job creation in order that they reflect the trend of needing more than one job to be created per proposed dwelling. When taking into account that the majority of jobs created in the retail sector are 'part time' and that the major take up of housing in newly developed sites will be from younger families. The stated policy will only create further social and Chairman Halfway Houses Residents Development targets for jobs economic problems. Where is the development of additional infrastructure and community services Mr Paul Hayes Objection LP799 Policy ST 2 Association and new homes 2011-2031 to be found? Where problems already exist, any expansion of need must be planned prior to any additional development. The expansion of services needs to be put in place before the need arises not very start of development connection to overloaded drains and an antiquated road and transport system must be planned not 'found out about' after the first heavy rainfall or adverse weather conditions. Nowhere in any of these policies are we told the target for site provision. ST2 gives an overall housing target of 540 pa or 10800 which is supposed to include the needs for GTs but this need is Development targets for jobs not stated. Para 7.4.28 states that the findings of the 2013 GTAA are outlined in the supporting text Mrs Alison Heine Objection LP22 Policy ST 2 and new homes 2011-2031 to ST2. But this only states as follows at 4.4.9 Any chosen housing target will also include meeting the objectively assessed needs of the Gypsy and Traveller communities. To isolate the level of need for these specific groups, a Gypsy and Traveller Accommodation Assessment (GTAA) was Object / Document Name Organisation Support Rep ID Title Consultee Response Part

prepared for the Council by Salford University in July 2013. This concluded that 85 pitches would be needed to 2031, adjusted to 82 pitches to reflect permanent planning permissions granted between February and March 2013. This target falls within the range of pitch options identified by the Council in its review of evidence for the March 2012 consultation on Bearing Fruits. This is hardly a resume of the 2013 GTAA, It fails to even explain how the need of 85 pitches is made up, the need for front loading to reflect the immediate need for sites etc. According to the 2013 GTAA there is a 5 year need for over 35 pitches (2013/14- 2018/19) just for Gypsy-Travellers. Of this there is an immediate need for at least 27 pitches (families with temporary consents, concealed, unauthorised). The 2013 GTAA target of 85 pitches by 2031 but this is for the period 2013-2031 which is not the same period as ST2 which is 2011-2031. No need was identified for show people. This is not made clear in the local plan. ST2 refers to a per annum approach. This is not appropriate for Gypsy-Travellers where there is a backlog of need. Almost half the need identified is for the first 5 years. The remainder is for household formation at a rate of 3%. It is no appropriate for this to be allocated/provided on a per annum basis. Provision needs to be front loaded to address the immediate need within the first 5 years.

I understand that the plan proposes to construct 10,800 new dwellings in the Swale Borough, in the period from 2013 to 203I. This is described as 'minimum' surely this will leave the door open for even greater housing numbers. The essential improvements to Swale services are fast lagging behind the pace of housing development, this seems as if it will be too much housing too soon.

Development targets for jobs Swale Borough Council as I understand it, has no finance for housing provision, so is therefore Mr J P Honeysett Objection LP422 Policy ST 2 and new homes 2011-2031 totally reliant upon developers to meet the housing targets. This can only lead to untold problems for the residents of the area.

Developers will take the easy route and choose greenfield sites for development ignoring the more difficult to develop, brownfield sites. The developers will be dictating the quantity, and locations of the sites. This sounds to me like a case of the tail wagging the dog!! I have lived in this area since 1963 , and in the last three decades the area has expanded to virtual breaking point, any more expansion will result in complete loss of agricultural and also of the natural enviromnent . The new draft plan of 10,800 new dwelling in the Swale Borough equates to an additional 30,000 residents in the 25 year period up to 2031 which will result in complete saturation point . Development targets for jobs Mrs B A Honeysett Objection LP424 Policy ST 2 and new homes 2011-2031 I understand that Swale Borough Council has no finance provision for housing, therefore the council will have no control over future developments The developers are quite likely to cherry pick the new greenfield sites for housing development ,due to lower construction costs ,therefore ignoring the brownfield sites. I always understood that the Council was in charge of the borough, not the developers! It would appear that whilst the Council have reverted to the lower of the two housing targets originally proposed, primarily on the basis that the larger projection of circa 18,000 new homes was proven to be undeliverable. However it is clear that it remains an ambition of the Council to develop beyond the housing numbers now being proposed. Nowhere is this is more apparent than in the SHLAA which is heavily front loaded. Here the Council advocates building 75% of their target in the first half of the plan period. This creates a number of problems, firstly if achieved it would leave the Council wide open to pressure to continue this rate of development. Secondly it creates a false Development targets for jobs Mr A Hudson Chairman Bapchild Parish Council Objection LP1352 Policy ST 2 requirement to bring forward sites to meet a 5 year supply which is entirely self-imposed. Thirdly the and new homes 2011-2031 phasing is totally unrealistic; by the Councils own admission “Housing delivery of over 800 dwellings per annum has only been achieved in five years during the past 30 years” Yet the Council would have us believe that it will do exactly this in years 4,5,6,7 and 8 of the plan and achieve an average of 841 per annum in the first 10 years. The 5 Year supply currently phased will automatically commit the Council to a review of the Local Plan by 2017/18 because it will have delivered an average of 675 dwellings per annum which triggers the review under Policy ST2 having exceeded 600 dwellings per annum threshold. This seems either incredibly short-sighted, or Object / Document Name Organisation Support Rep ID Title Consultee Response Part

a deliberate attempt to mislead the public, so that the Council can if fact bring forward more housing in just 5 years’ time. As stated previously, the other problem facing the borough is the huge anomaly in terms of the location of this housing which would see a split of around 60% for Sittingbourne, 35% for Sheppey and a mere 5% for Faversham. Compare this with the current populations for the three towns where the ratio is approximately 46% for Sittingbourne, 30% for Sheppey and 24% for Faversham and it would seem that Sittingbourne will take a disproportionally high volume of the housing and Faversham very little indeed. Whilst of course there are constraints in some areas of the Borough as where housing could be located, the problems cited by the Council with regards to aging populations and increased commuting apply to the whole borough. The arguments put forward to support development in Sittingbourne and Sheppey apply equally to Faversham. The planned distribution will create some of the very problems the Council seeks to address. Residents in Faversham will be forced to seek housing provision elsewhere in the borough, and potentially result in increased commuting. Over development in Sittingbourne and Sheppey brings its own disadvantages as the current infrastructure and services is geared to the existing population. So whilst pressure will be exerted on services such as Education they will by the Councils own admission fall in Faversham. By contrast the reverse might be true with Health related services. All of this is likely to lead to a significant increase in journeys within the borough, which will exacerbate existing highway problems where the infrastructure itself will need substantial changes to accommodate the step change in policy. Faversham which would require some 2,375 houses to meet the needs of the existing population and another say 500 for migration will get less than 20% of this. We would like to see a more balanced and sustainable approach to the delivery of housing, which would reduce the need to relocate services or increase journeys. The Council argues that one out of every three houses built under this plan is purely to service the expected inward migration. This seems unnecessarily high, especially given the marginal increase in the resident labour supply that is derived from this. It has not escaped our attention that there is already more employment land provision with existing planning permission that has not commenced, than is necessary to deliver the jobs target set in the plan period, in fact nearly double. So why on earth would the Council then propose even more? To suggest that… “there are strong reasons for having a land portfolio in excess of this numerical need so that we get the right quality of sites.” Is in our opinion an open admission that the Council has not therefore adequately assessed the employment land sites that it has brought forward and therefore the Council is suggesting that some of these sites are not of suitable quality and should therefore be withdrawn. In 2011 when the Council were proposing a very high end jobs target 30,500 jobs (some 60% of Kent labour supply) the Council put forward an equally high end 595,000 Development targets for jobs Mr A Hudson Chairman Bapchild Parish Council Objection LP1353 Policy ST 2 m2 of employment floor space. Now having twice reduced the jobs target, because it was and new homes 2011-2031 undeliverable, we have a jobs growth projection of 7,053 and unbelievably 597,605m2. Therefore the Council is advocating an average floor space requirement per job of 84.73 m2 when your own evidence suggests just 24.89m2 (175,531m2 / 6,053 jobs). It would appear that the Council has failed to address all our previous concerns that its employment land provision is massively overstated and simply resorted to the very same figures it derived back in 2011 regardless of the fact the jobs growth has been scaled back some 75%. The employment land provision with existing planning permission 318,069 m2 is therefore capable of providing 12,779 jobs. There is no requirement what-so-ever to add to what is a massive surplus of un-development land left over from the current Local Plan where the Council had previous totally exaggerated the anticipated demand. We fail to see how the Council arrives at its ratio of houses to jobs which, for Swale, equates 13,500 houses needed to provide 8,500 jobs. That housing target could increase the population by over Development targets for jobs 25,000 which we feel would contain many more job seekers that the figure stated. The policy does Fiona Jackson Eastchurch Parish Council Objection LP812 Policy ST 2 and new homes 2011-2031 not compare like with like in that, should the plan be approved, developers will want to commence house building without delay whereas there is no guarantee that any commercial organizations will rush in to create jobs as the plan only provides an opportunity. The Draft plan provides "evidence" which we dispute, and according to our councillors this does not Development targets for jobs address any of the problems and would in fact cause huge liabilities for generations to come as well Mrs L Jordan Milstead Parish Council Objection LP807 Policy ST 2 and new homes 2011-2031 as for schools and medical care. Already schools and hospitals in this area are oversubscribed due to the housing expansion that has already occurred locally so we certainly cannot cope with even Object / Document Name Organisation Support Rep ID Title Consultee Response Part

more expansion. Swale Council should consider the views of the public, and not "push" for policies that are so obviously flawed and not thought through, therefore policies should not be signposted "just in case".

Let's get our borough in order before we push for unrealistic targets. Let's improve our public transport system, encourage healthy cycling and walking not make our country more congested that is more cost effective for everyone. We have found it very difficult to analyse the information regarding the quantity figures for development in the plan, especially the various sub-divisions made. Figures are inconsistent throughout the plan, depending on what the council is referring to. The figures must be presented Development targets for jobs Mrs L Jordan Rodmersham Parish Council Objection LP1098 Policy ST 2 more clearly, concisely and consistently in the final plan. We in particular refer to the quantum of and new homes 2011-2031 employment land given the radical reduction in employment yet the land requirement has not reduced in parallel. We therefore recommend that Swale Council significantly reduce the quantum of land and increase the density of employment on the land is does include within the plan. 1) We welcome the rejection of an even higher housing target, which was briefly entertained by the Council. To do so is entirely consistent with our analysis. However, the housing target of 10,800 dwellings has been set without a robust analysis of deliverability, which is a key element of the National Planning Policy Framework (NPPF). Our own work, as presented in Part 1 of our response, shows that for this target: a) there is a significant chance of under-delivery; and b) the target is higher than an objective approach would suggest. 2) The employment target is clearly "aspirational" and, not being based on an objective analysis of the data, is set too high to be achievable. 3) The consequence of setting unnecessarily high targets is that significant areas of greenfield land is identified for development which comprises grade 1 agricultural land, areas of high landscape value and/or areas important for maintaining separation between settlements; 4) The consequence of setting targets that are potentially undeliverable creates the risk of further speculative development of greenfield sites if the Council is unable to demonstrate an on-going deliverable supply of sites in accordance with the requirements of the NPPF. 5) Based on an analysis of ONS data and a detailed analysis of deliverability, we consider that the housing target Development targets for jobs should be reduced to 10,000 dwellings . This: a) enables full provision of housing for the local Mr Brian Lloyd Senior Planner Protect KENT Objection LP833 Policy ST 2 and new homes 2011-2031 population and continuing trend migration. b) allows for a 4% vacancy rate and a 5% buffer. c) has a 89% probability of being delivered. d) enables the removal of the following proposed sites from the Plan: - North East Sittingbourne (Policy A2); - Frognal Lane, Teynham (Policy A4); - Barton Hill Drive, Minster (Policy A5); and - Cryalls Lane and north of Key Street, Sittingbourne, and Belgrave Road, Minster (Policy A9). 6) We consider that the employment target should be 4,000 jobs , which would still provide a significant buffer over the requirements of the objectively assessed level of job requirements and be deliverable in the context of the "aspirations" of neighbouring districts. 7) We are concerned that the Plan strategy promotes significant road building that will increase the use of the private motor car above other modes resulting in increases in carbon emissions with resulting impacts on air quality and climate change. 8) However, the Plan fails to grapple directly with capacity issues at Junction 5 of the M2 Motorway. 9) We object to the identification of ‘Areas of Future Change' as by giving commitment now to undefined development in these locations for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. 10) The protection of important countryside gaps between settlements should be retained in the Plan. CPRE Protect Kent object to the level of development proposed in Policy ST2 as explained in Part 1 of our response. Notwithstanding this, the Policy should be amended as follows: · The sentence after the table should be amended to read as follows: " Planning permission will be granted on sites allocated for development in the development plan. Additionally, planning permission will be Development targets for jobs permitted where proposals accord with the policies of the development plan subject to:" · In the Mr Brian Lloyd Senior Planner Protect KENT Objection LP870 Policy ST 2 and new homes 2011-2031 second point 2 amend "past trend average" to "moving average" (if this is what is actually meant). The phrase past trend average is not a recognisable statistical concept and its meaning is not clear. Thus, the trigger to reviewing the plan is not actually defined by the second point. Also, as the analysis in Part 1 of our response shows, a moving average trigger of the type suggested would, in the past, have led to an increase in housing targets at the beginning of a downturn in the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

market. Delete the second point 3 as such progress with the delivery of the ‘Areas of Future Change' is contrary to the principle of the Plan-led planning system. The Local Plan contains no specific proposals or policies relating to these areas against which such progress can be made. Furthermore, the statement made in point 3 does not accord with that made in paragraph 4.5.52 of the draft Plan. This states that it is improvement in the "prospect" of delivery that will trigger the review, at which point the principle and detail of development will be considered. We would suggest that "tangible progress" on delivery, as expressed in Policy ST2, is somewhat different to the "prospect" of delivery and implies that development would have actually occurred. However, as we explain elsewhere, and contrary to the statement made in paragraph 4.5.52, the mere fact that ‘Areas of Future Change' are included in the Plan means that the in principle decision would already have been made. NOTE: These representations are submitted on behalf of the Peel Group, which includes Peel Land & Property (Ports) Limited and Peel Ports.

Development targets for jobs Peel Group reiterates the concerns it expressed in its response to the Swale Core Strategy (Bearing Peel Group Objection LP410 Policy ST 2 and new homes 2011-2031 Fruits) Consultation in May 2012 in respect of housing numbers. The arguments were made in full in that consultation response and are not repeated here. We also refer to our commentary on the Local Plan preamble page vii where we raise this issue. In summary, the housing target does not reflect objectively assessed need, and as such is contrary to national policy in the NPPF and does not reflect the evidence base. The draft Local Plan is therefore unsound in this respect. For the reasons set out below we strongly disagree with the housing target set out in policy ST2. We believe the target presented has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy as well as creating a significant barrier to the Council's own economic growth target. There are several reasons why the policy has not been positively prepared. The most recent Strategic Housing Market Assessment Update and Development Needs Assessment carried out for the Borough (Nathaniel Litchfield and Partners, 2013) identified an annual need of up to 1,186 dwellings with an ".....appropriate and justified scale of aligned economic and housing growth for Swale Borough Council to be considering would be within the middle of the 600-900 range of objectively assessed development needs" (NLP 2013). With this in mind the development target set by ST2 (540dpa) falls significantly below even the lowest figure of the objectively assessed need. This therefore runs contrary to paragraph 47 of the Framework which sets a requirement for local authorities to identify their objectively assessed needs then plan to meet them accordingly. The justification given by the borough for setting the lower housing target appears to be based on the past completion rates, risk of setting an unachievable housing target and that an early review would be an appropriate compromise (para's 4.4.20, 4.4.21, 4.4.22). There are several identifiable issues with this justification: firstly past completion rates were related to a considerably lower housing requirement. Most recently targets in the now revoked South East c/o Tetlow King Planning Kent Development targets for jobs Objection LP1313 Policy ST 2 Regional Strategy indicated an average annual requirement of 540 p.a. for the period 2006 to 2026. Developments UK Ltd and new homes 2011-2031 Far from underachieving against this average, the Annual Monitoring Report for 2011/12 shows that 3,635 net dwellings were delivered in the 6 years 2006 to 2012; that is about 606 dwellings per annum. The Borough's own consultants and officers recommended higher housing targets and not only are there sound reasons based on need to support these, but also there is no evidence that higher targets will not be achievable. The council has indicated (para 4.4.21) that it should not set an undeliverable housing target from the offset and risk being labelled as persistently under delivering against government policy. This in itself runs contrary to paragraph 182 of the Framework with states that all plans should be positively prepared and based on a strategy that seeks to meet objectively assessed need as well as para 47 of the Framework which requires authorities to ".....boost significantly the supply of housing.....". Furthermore, during 2006/7 and 2007/8 835dpa and 767dpa respectively were delivered, proving that in better economic times the borough has the ability to deliver at much higher levels than proposed in the draft Local Plan. There are signals that the economy is improving and plans should be prepared accordingly. It is not accepted that an early review is justification for setting a housing target that falls short of the objectively assessed need. Based on the review triggers presented by the council it would be at least 5 years before a review would even begin to take place during which time a significant backlog of need is likely to have been created exacerbating housing shortages in the future. Policy ST2 has not been Object / Document Name Organisation Support Rep ID Title Consultee Response Part

positively prepared The Framework requires authorities to plan positively (para 182) and to meet objectively assessed needs (para 47). Furthermore para 154 of the Framework states that local plans should be both aspirational and realistic. Setting a target that is proven to be below what is required is neither aspirational nor realistic. The officer's report to committee (February 2013) (see appendix 1) further confirms that setting a housing target below 741 (option 2 of the economic led scenarios) would neither be proactive nor aspirational (para 4.2). The Framework sets a presumption in favour of sustainable development requiring all planning policy and decisions to be in accordance with its principles of sustainability. Paragraph 14 requires authorities to ".....positively seek opportunities to meet the development needs of their area" (NPPF, 2012). The Draft Interim High Level Sustainability Appraisal of Development Target Options (February 2013) that accompanies the draft Local Plan, clearly sets out that a housing target of 741 pa as the most sustainable as it ".....provides a balance between aspiration and realism....." (pg 15). Clearly a target that does not meet or even seek to meet the development needs of its area does not meet the government's presumption in favour of sustainable development and is not sound. Further evidence that the plan has not been positively prepared is shown from committee meetings (Appendix 1) which set the steer for the housing target. The officer's report strongly recommended setting a housing target of 741dpa as it had "...... a strong evidence based behind it...... ". Despite the officer's advice and despite warnings that any lower target would have little to no justification, members voted to retain the low housing target of 540 (Local Development Framework Panel minutes 21st February 2013 - Appendix 2). This, therefore, shows that the authority has not taken steps to positively promote housing development or meet the housing needs of its constituents. Policy ST2 is Unjustified Paragraph 182 of the Framework requires all local plans to be justified and based on proportionate evidence. The NLP SHMA update (February 2013) report provides an up to date evidence base on which an appropriate housing target may be set. The study assesses several growth scenarios and proposes a number of potential housing requirements based on each. It concludes that the objectively assessed needs for the borough are in the range of 600 to 900dpa with a recommendation of 750dpa being achievable (NLP, 2013, para 9.15). However, the current housing target proposed (540dpa) is far lower than the recommendations of the evidence base. There is no evidence provided as to why the currently proposed target is more suitable than the recommendations set out in the Council's own evidence base. The justifications for the target as discussed above are clearly insufficient and in no way comply with the requirements of national policy. The borough commissioned an assessment of its approach to housing and employment targets (Nathaniel Litchfield and Partners, Nov 2012) for its previous Core Strategy. This plan proposed the same levels of housing and employment growth contained in the more recent Local Plan. This report concluded that there ".....is a real risk that the Core Strategy would be found unsound if taken forward in its present form" (NLP, 2012). One of the main reasons for this was the potential shortfall in housing which would lead to adverse impacts (para 5.11 NLP 2012). Again this shows that the proposed housing targets within policy ST2 have not been justified. The NLP Appraisal of Housing and employment targets (2012) highlight the importance of up to date housing projections and evidence on other Core Strategy or Local Plan Inspections especially the role of CLG projections. In the case of Swale the CLG projections (ONS, 2011 interim figures) highlight an annual need for 887dpa which is significantly above what is proposed in policy ST2. Again this highlights that policy ST2 is not based on proportionate evidence and cannot be justified. The emerging National Planning Practice Guidance, which is currently being consulted on, recommends that the starting point to establish need should be the Household projections published by the Department for Communities and Local Government and ONS population projections. Whilst it is recognised this guidance hasn't yet come into force, it is material and should be taken into account. In any event it is likely that it will be before the Local Plan goes to Examination and therefore should be incorporated into any current revisions. Policy ST2 is ineffective Paragraph 182 of the Framework requires Local Plans to be effective and "... the plan should be deliverable over its plan period and based on effective joint working on cross-boundary strategic priorities...." Policy ST2 is clearly ineffective as it will not meet the objectively assessed housing needs of the borough. Further evidence that policy ST2 is ineffective comes from examining affordable housing need. The SHMA update (NLP, 2013) identifies a need for 1,830 affordable homes each year over the next 5 years which it clearly states must be an influential factor in determining the actual level of housing growth (para 6.26). Whilst it is not suggested that Object / Document Name Organisation Support Rep ID Title Consultee Response Part

this is a viable or even a realistic figure to achieve, it does indicate the very high level of need for affordable housing. Given this scale of need the authority should be aiming to maximise the delivery of affordable housing, and this aim should be embodied within its housing policies. A higher housing requirement, and allocation of sites over the size threshold, will enable more affordable homes to be delivered. HSSA data shows the actual affordable housing stock in the borough has broadly remained constant with a minor reduction in the overall stock since 2008 (HSSA data sets, 2008- 2012). This further highlights the need to increase affordable housing delivery. Homelessness is also an issue within the borough. There has been a great deal of fluctuation in the number of priority need homeless persons over the last 9 years (HSSA live table 784), however over the past 5 years there has been a slight increase in overall levels. The NLP Appraisal of Housing and employment targets (2012) finds (table 4.4) that it is not clear whether affordable housing need influenced the target of 540dpa in the old Core Strategy. As the Council is sticking to 540dpa in the Local Plan there is nothing to suggest this has changed. The preamble to policy ST2 recognises the need for affordable housing is increasing across the authority (para 4.4.35), however the targets set do not seek to address this issue, again calling into question the effectiveness of the policy. Policy ST2 is not consistent with national policy Paragraph 182 of the Framework requires Local Plans to be consistent with national policy and objectives. As discussed above policy ST2 fails to remain consistent with national policy on a number of grounds. Namely it: fails to promote sustainable development, fails to meet objectively assessed need, will create a barrier to economic growth, shows little evidence of cross boundary working and it fails to be supported by a robust evidence base. Policy ST2 does not support sustainable economic growth Paragraph 19 of the Framework states that planning should do "..... everything it can to support sustainable economic growth." The growth in jobs as set by policy ST2 has been described as ‘ambitious' (NLP, 2012).However the housing target that has been proposed to support the economic progress will in fact create a significant barrier to growth and is counteractive to the employment target. The 2013 SHMA update identifies the borough will need to deliver 741 dwellings per annum to support an annual growth in jobs of 353. The NLP Appraisal of Housing and Employment Targets (2012) assesses the same targets that have been brought forward to policy ST2 and concludes that the level of economic growth proposed is "...... undermined by a lack of housing." It goes on to state that "...... this is a significant weakness if the plans economic growth levels are to remain as stated" (table 4.6). The need for a higher level of housing growth in the region of 741dpa was set out in the Officers report to committee (Feb 2013) which makes clear that this would be the level of growth needed to support the economic led strategy (para 2.48) this was also the recommendation of officers (para 3.7iv). It is therefore clear that the housing target set out in policy ST2 will be a significant barrier to the borough's own economic and jobs targets and does not support sustainable economic growth, thus being inconsistent with paragraph 19 of the Framework. Policy ST2 fails the Duty to Cooperate Paragraphs 178 to 181 of the framework places a Duty to Co-operate on local planning authorities on cross boundary issues. Authorities are expected to show collaborative working with relevant bodies and neighbouring authorities especially with regards to meeting unmet development needs. The preamble to policy ST2 has a short section on the duty to cooperate (para 4.4.25), however it provides no substantiated evidence that there has been any cross boundary interactions with neighbouring authorities. It argues that Ashford and Medway councils are not yet sufficiently advanced for allocations to be made however it could be argued that this presents an opportunity for early engagement and collaborative work to establish principles and broad parameters for growth, an opportunity that has clearly not been taken by Swale Borough. The emerging government guidance (online resource) states that even if Local Plans are at different stages of development then authorities should still be demonstrating a commitment to long term joint working. Again this is relevant to Maidstone and Canterbury councils who share boundaries. The final sentence of paragraph 4.4.25 appears to dismiss the need for further collaborative work due to the fact that policy ST2 provides a review mechanism for dealing with unmet housing need. This does not correspond with national policy which states that "Cooperation should be a continuous process of engagement from initial thinking through to implementation....." (NPPF, para 181) or the emerging NPPG which states that the Duty to Cooperate is an ongoing process. For the reasons set out above we strongly disagree with policy ST2 and have shown evidence that it does not meet the objectively assessed needs of the borough and therefore is unsound. The level of housing growth set out in policy ST2 is clearly insufficient and therefore should be raised as a minimum to at least Object / Document Name Organisation Support Rep ID Title Consultee Response Part

750dpa. This figure is in accordance with the range in the SHMA update (2013) and will provide sufficient homes to support the boroughs economic growth targets, as well as being more in line with the borough's objectively assessed need. This will however still leave a significant shortfall when set against the needs highlighted in the ONS growth projections which identify a need of 887dpa. A higher figure than 750dpa should also be considered to help address a backlog of need for affordable housing. Draft policy ST2 is objected to given that the specified housing target of 10,800 dwellings for the period 2011 to 2031 is considered to be too low. The use of an overall strategy that is based on an overtly pessimistic assessment of delivery is inappropriate and fails to respond to the need to significantly boost the supply of housing so as to meet objectively assessed housing needs. In this respect it is not consistent with national planning policy and the strategy is correspondingly unsound. We consider that the policy should be amended to include a minimum housing target of 14,800 dwellings (740 per annum) which would match the scale of local housing needed to provide for the anticipated level of economic development in Swale and move towards meeting the objectively assessed housing needs of the area. The policy should also include an amended threshold for any subsequent review of the plan, triggered through monitoring when the 5-year trend falls below 665 dwells per annum (i.e. 90% of the target). This would enable the Council to consider ways in which the housing supply could be encouraged, such as the allocation of additional more viable land and/or the relaxation of costs associated with community or infrastructure provision or the scale of affordable housing. In the context of meeting local needs the Development targets for jobs NPPF requires that it is necessary to identify ‘key sites which are critical to the delivery of the Vinson Trust - Lady Dane Farm Objection LP1340 Policy ST 2 and new homes 2011-2031 housing strategy' (para 47). These have been set out in the previous version of the draft plan. However, the anticipated programming of regeneration opportunities on Sheppey now means that there is no particular reason to identify a specific reserve housing site there at this stage. The deletion of the proposed site is therefore supported. We consider that the required flexibility within the plan could be achieved simply through the initial allocation of land, the identification of subsequent broad areas of growth and the careful monitoring of progress towards meeting the amended target. In our view this position also applies to Faversham. Here however, the primary issue is how to meet the requirement for a relatively small-scale employment site to replace those sites identified in the 2008 plan which have not come forward (para 6.3.79) as well as providing for local needs housing. As part of this justification it is recognised that the re-allocation of employment land would then ‘allow the release of poorer quality, older estates and upgrade the quality of the overall supply at the town' (ibid). It is of course the case that this strategy would also allow for the regeneration of obsolete employment land at the Western Link (under policy A6). We see no reason to object to this proposal given the evident failure of the market to deliver this long standing employment allocation. In addition to the comments made within the enclosed representations, HLM note that the draft Local Plan pays little regard to the Duty to Cooperate and the issue of whether or not Swale’s own Development targets for jobs unmet housing need, or indeed that of neighbouring authorities, should be addressed by way of Hallam Land Management Ltd Objection LP1459 Policy ST 2 and new homes 2011-2031 increased development targets. Not only should Swale Borough Council ensure that it is planning for its own full, objectively assessed development needs, but also those needs which are not being met by other authorities. Strategic Housing Market Assessment (SHMA) The National Planning Policy Framework dictates that Local Plan policies should be based on objectively assessed need and states that Local Authorities should prepare a SHMA to assess their full housing needs. Swale instructed Nathaniel Lichfield and Partners to undertake a SHMA, which updates the 2009 East Kent SHMA. The document was published in March 2013 and uses the most up to date data available. The c/o WYG Owners Norton Ash Garden Development targets for jobs baseline growth scenario for new jobs within the Borough (subject to delivery of new employment Objection LP1486 Policy ST 2 Centre and new homes 2011-2031 floorspace) indicates the potential growth of 4,370 jobs over the 2011-2031 plan period which equates to 220 jobs per annum. However, a higher growth rate scenario has been developed to reflect the Borough's potential which identifies a net increase of 357 jobs per annum. In order to support the minimum baseline economic growth in the Borough, a minimum of 600 dwellings per annum would be required. To support a higher rate of growth, which is believed the Borough could achieve, the SHMA identifies a requirement for 740 dwellings per annum which gives a total Object / Document Name Organisation Support Rep ID Title Consultee Response Part

requirement for 14,800 dwellings over the plan period. Therefore, it is clear to see that the current Local Plan target of 540 homes per annum is not based on objectively assessed need, and would not provide the level of homes required to support the successful economic growth of the Borough. The target of 540 has been derived from the South East Plan target which is now an out of date figure given that the plan has been revoked. Its' policies do not carry any weight in the determination of planning applications, nor the formation of new planning policy. The SHMA identifies areas within the Borough where significant constraints exist, such as Areas of Outstanding Natural Beauty and areas within Flood Risk Zone 3. This means that certain areas have less capacity to accommodate development. However, there are certain areas within the Borough that could accommodate significant development and it is therefore believed that a higher target of 740 dwellings per annum could be accommodated using tools such as the Community Infrastructure Levy and Section 106 agreements to upgrade existing infrastructure and to offset the impact of new development. The A2 corridor is identified as one of these areas. As concluded within the SHMA, a target of around 740 homes would meet a balanced view of what future demographic led needs would be, and would not place any undue constraints on meeting the economic potential of Swale. It would also support an alignment between higher employment growth and demographic need, in line with the ‘jobs-led' approach that Swale has previously promoted. It is therefore clear that this target has been derived from objectively assessed need and should be adopted by the Council to ensure consistency with the NPPF. Strategic Housing Land Availability Assessment (SHLAA) The NPPF also requires Local Authorities to prepare a SHLAA to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period. LPA's are also required to identify and update annually a supply of specific deliverable sites sufficient to provide five years worth of housing against their housing requirements. The NPPF states that land identified for the five year supply should be "available now, offer a suitable location for development now" and have "a realistic prospect that housing will be delivered on the site within five years and that development of the site is viable". The results of the 2011/2012 SHLAA indicated that a total of 11,601 homes would be achievable over the plan period. Whilst this is higher than the target originally set by the Council, it is not enough to meet the objectively assessed need of 14,800 dwellings. In addition, the number of completions taken place in the last year is well below the indicated rate required to meet projected and aspirational economic growth, at 397. Identification of a supply of sites suitable for housing is essential, and allocating enough housing land means that Local Authorities can be more secure against challenge at appeal if applications for new housing are refused. The August 2013 SHLAA provides a trajectory detailing the annual requirement (including a 5% buffer) and the target allocations over the plan period. This indicates that, and it is clearly stated within the text of the document, that there will be a lack of a five-year supply until 2016/2017. It is noted that a revised SHLAA will be prepared to inform the proposed submission version of the Local Plan and this opportunity should be used to address the issue of a lack of a five year supply. In addition, the Council should include a strategy to make up the housing shortfall. Even using the lower rate of 540 homes per annum, there is a shortfall of 142 dwellings per annum. Using the higher rate (which would fulfil the objectively assessed need for the area) would result in an under supply of 342 dwellings per annum. In the preparation of any future SHLAA, the Council should therefore clearly take note of the objectively assessed need for housing in the Borough, and identify a five year supply for that target should it wish to be successful at the examination stage. If this advice is undertaken, and further evidence is provided, it would be deemed prudent to undertake a further round of Preferred Options consultation. Consider revising the proposed housing growth target so that it can support the plan's economic Development targets for jobs URS SA Recommendations Objection LP1607 Policy ST 2 growth identified in Policies ST2 and ST4 and the delivery of housing based on objectively and new homes 2011-2031 assessed need. I do not agree with the scale of building that is planned for "Bearing Fruits" 2031. Development targets for jobs Mr & Mrs E McIntyre Objection LP328 Policy ST 2 and new homes 2011-2031 Wall to wall housing is not the answer look at London, how depressing it is. For every area of houses you need open space for people to be happy. Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1033 Policy ST 2 Development targets for jobs It is not considered that the plan has been 'Positively Prepared'; namely, it is NOT 'based on a Object / Document Name Organisation Support Rep ID Title Consultee Response Part

and new homes 2011-2031 strategy which seeks to meet objectively assessed development and infrastructure requirements'. The reason for this is as follows:

• The proposed minimum housing target of 10,800 houses (540pa) (Policy ST 2) for the period 2011 to 2031 is significantly below the target of 15,000 houses (750pa) recommended in the Nathaniel Litchfield & Partners Strategic Housing Market Assessment (SHMA) - Update and Development Needs Study, March 2013. It is also below the minimum housing target previously supported by the Council in the Swale BC Draft Core Strategy, March 2012; • The SHMA figure is credible because it is more closely aligned with the number of houses required in relation to demographic forecasts for the Borough (Including the Office for National Statistics) and the Council's jobs led approach based on a higher economic scenario (7,053 jobs 1357 additional jobs per annum). In view of the close relationship between the provision of houses and attracting new jobs to the Borough, it is evident that an artificially low housing target would significantly undermine the Council's ability to encourage new employment growth. This is directly contrary to Government advice (NPPF Para 19 & 21) which states that 'Planning policies should recognise and seek to address potential barriers to investment, including any lack of infrastructure, services and housing'; • The Council's 'cautious' approach of basing its proposed housing target on short, medium and long term housing delivery rates over the last 5, 20 and 30 years in the Borough is not justifiable. The fact that delivery rates for the last 2 years have been below past historically low delivery rates is symptomatic of the fact that there has been a perpetual lack of deliverable and developable sites for housing development within the Borough. This has created a self fulfilling prophecy; • Whilst the Council continually point to environmental and infrastructure constraints as a further reason for proposing a low housing target, it is not considered that these factors are in themselves sufficient reason for proposing a target below the objectively assessed mid range figure proposed by NLP; • The first fundamental weakness in the Council's housing strategy relates to the fact that it is still seeking to concentrate too many houses (3,519 dwellings / 33% of housing target) in the Sittingbourne Area (which is less attractive in location terms) and too few houses in the Faversham area (538 dwellings / 4.9%) where there is a strong housing market; low unemployment levels; healthy town centre; and excellent road and rail links (Policy STl; ST3; ST4). Clearly, the spatial distribution of proposed houses is not in accordance with the Council's own settlement strategy which identifies Faversham as the second principal town within the Borough for housing and employment growth and also with respect to the relative size of the town (24% of the Borough's Population; 20.6% of people in full time employment; and only 17% of the total housing stock); • The second fundamental weakness in the Council's housing strategy is that it is still too over reliant on sites in Sittingbourne (committed and allocations - 2,192 dwellings / 20%) which are not economically viable to develop (extraordinary development costs associated with contaminated land and high infrastructure costs) (Policy ST4). Clearly, this may also apply to the Council's proposed new green field site allocation on land to the North West of Sittingbourne (1,276 dwellings / 12%) where high infrastructure costs may make this site undevelopable in current market conditions (negative land value per hectare); • The Council state that a failure to deliver and develop sites in Sittingbourne will not be grounds for making up any shortfall in housing land supply on sites in Faversham. However, this approach is not consistent with Government advice which confirms that a shortfall in housing land supply across a Borough or District would give rise to a presumption in favour of housing development across a Borough or District. Clearly, this could give rise to the very problems the Council is current seeking to counter against by adopting a low housing target; namely a rush of ad hoc speculative housing applications in a uncoordinated manner on more sensitive sites. This would have the effect of creating planning uncertainty within the Borough; • Whilst it is acknowledged that the Council recognise in its draft plan that the current housing Object / Document Name Organisation Support Rep ID Title Consultee Response Part

target is too low to meet its jobs-led strategy and that it would be prepared to review the Local Plan once housing delivery rates hit 600 houses per annum (Policy ST 2), it is not considered that this provides a sound basis for meeting its housing and economic needs over the plan period. Whilst adopting a flexible approach is to be welcomed, it is considered that the Council should at least start with meeting its objectively assessed housing needs rather than having to try and meet them as part of a lengthy Local Plan Review in a few years time (NB: The current pickup in the housing market could easily make this the case within the Borough). It is considered that this approach would create further uncertainty within the planning system for local residents and communities contrary to Government advice; • In accordance with the NPPF, it is evident that in fixing housing land supply requirements, a 20% buffer should be added to the proposed figures to allow for the Borough's past under performance. On a mid range housing target of 15,000 houses, this would increase the total housing requirement by 3,000 houses to 18,000 houses. Further, the Council should be looking to identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and where possible, years 11-15; • Whilst it is acknowledged that the Council can rely on currently unidentified windfall sites to meet a proportion of its housing requirements, it is considered that the figure proposed of I,449 dwellings (110pa) is too high compared with past windfall housing rates. Further, it is considered that the Council's past over reliance on windfall sites as a means of meeting housing land supply requirements is not the proper way to plan for housing growth in the Borough; • It is noted that there is an existing 5 year housing land supply shortfall within the Borough which is projected to last until 2016/17 (SBC SHLAA).

In summary, a radical rethink is required within Swale BC as to its proposed housing strategy with more emphasis on settlements like Faversham in terms of meeting its future housing requirements. A failure to adopt this approach will result in a shortfall in housing land supply and undermine the Council's jobs led strategy. In promoting a jobs-led strategy, the housing target should be increased from 10,800 dwellings to 15,000 dwellings (2011 to 2031). If past non performance in delivering sites is factored in, a 20% buffer should be allowed for- a total of 18,000 dwellings (2011 to 2031); As part of the Council's housing strategy, it should at the very least seek to meet its 5 year housing land supply Development targets for jobs requirements. This would involve identifying a number of sites where there is a 'near guarantee' Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1044 Policy ST 2 and new homes 2011-2031 they are developable, deliverable and achievable in market terms; In addition to increasing dwelling numbers in Faversham, the Council needs to reconsider its proposed housing allocations in terms of whether they are deliverable, developable or achievable. It is considered that sites at Brogdale Road; the A2 / Western Link junction: and Queen Court Farm could make up any shortfall in the short term. They would contribute to the Council's existing 5 year housing land supply deficiency. Housing Targets I object to such a large amount of building unless and until supporting infrastructure is in place. It’s already difficult to find a GP and Medway Hospital struggles to meet demands on it. We need good quality schools, a further education facility and good local shops; Development targets for jobs Mrs K Murphy Objection LP737 Policy ST 2 otherwise Sittingbourne will only be a place to sleep in. We also need cultural facilities to encourage and new homes 2011-2031 an interest in the arts, accessible to all residents. Development on green field sites should be banned until all brown field sites have been used in Kent. Food security should be top of the agenda for the UK. We support the Council’s aspiration for housing delivery but recognise that meeting its full range of housing need, as required by the NPPF, may be a challenge. In light of the Council’s approach to meeting housing needs, we suggest the Council reassesses its housing allocations to determine Owner of land at Quinton Development targets for jobs whether more housing could be provided than anticipated in the consultation draft. We believe this c/o JB Planning Associates Objection LP1554 Policy ST 2 Road and new homes 2011-2031 to be an effective starting point. Based on our experience of past public examination, the Council is likely to face significant scrutiny on its housing numbers and it is important the Council get their proposition right prior to submitting the Local Plan. A new Local Plan is essential to deliver regeneration and not having a comprehensive evidence base will result in unnecessary delays and Object / Document Name Organisation Support Rep ID Title Consultee Response Part

frustrations. The SHMA Update Development Needs Study (March 2013) which forms part of the evidence base for the draft Local Plan states that there is a need in the borough for c750 dwellings to be delivered per annum across the Borough. This is based on the economic projections for the borough based on the jobs-led approach the draft Local Plan advocates. The Bearing Fruits draft Local Plan (August 2013) sets a housing target of 540 dwellings per annum, significantly lower than the needs study projects. This need is most acutely felt in the affordable housing sector where past trends indicate that there have been relatively low levels of affordable housing supply since 1996/97 which has coincided with significant increases in the housing waiting list, illustrating that new affordable housing supply has not necessarily been able to keep pace with demand for affordable housing. The SHMA Update Development Needs Study (March 2013) indicates that both overall housing completions are falling from their mid-2000's high and the previously high vacancy rate falling into line with the Kent average demonstrating that it is possible that whilst realisable demand Owner of land at Scocles Development targets for jobs and prices have fallen in the private market, supply has also tightened. This is supported by the Objection LP1015 Policy ST 2 Road and new homes 2011-2031 Swale District Housing Information Audit 2011/2012 edition which when assessed against the South East Plan housing target of 10,800 dwellings by 2026 (the South east Plan has now been revoked but at the time of publication set the Regional Spatial Strategy for housing grow1h) shows that that the district will start to fall behind its housing trajectory in 2013/2014 and will remain below the trajectory for a further 5 years. The NPPF requires the Council demonstrates sufficient sites to provide five years' worth of housing against their housing requirements. As evidenced, the Council is falling behind these targets. The NPPF further states in paragraph 47 that where there has been a record of persistent under delivery of housing, local planning authorities should provide a buffer to 20% of this target to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market. There is clearly a downward trend in the delivery of housing within the Borough, in particular affordable housing, the site at the east of Scocles Road provides a viable deliverable site that would ensure that the Council meets its housing targets and provides the type of housing that is most need in the Borough. Overall we are supportive of the Council's wider aspirations for the Local Plan but we believe the Council will struggle to meet the full range of ‘objectively assessed' housing needs, as required by the National Planning Policy Framework (NPPF), and as a result the Local Plan is likely to be found unsound at Examination in Public. The Plan is planning for a shortfall in homes over the 15 year period of the plan. To avoid a consequence of increased unaffordability, overcrowding, homelessness and pressure on neighbouring authorities to meet Swale's unmet housing needs, we believe the Council should be making more land available for the delivery of housing. Based on our experience of past public examinations, the Council is likely to face significant scrutiny on its housing numbers and it is important the Council get their proposition right prior to submitting the Local Plan. Evidence produced by the Council suggests the Local Plan is planning for the delivery of 540 homes per annum over the plan period which is significantly below the ‘objectively assessed' housing need target of between 604-887 homes per annum. The Council believe the 540 target is deliverable and a higher target would increase the requirement to bring forward more undeliverable Development targets for jobs Owners of land at Bapchild c/o JB Planning Associates Objection LP1124 Policy ST 2 and make communities vulnerable to speculative and uncoordinated release of land and new homes 2011-2031 development. Unfortunately this approach fails to recognise the Government's aim set out in the NPPF. The Government has been clear that at times of slow economic growth, Council's should be using their planning powers proactively, to promote opportunities for growth and ‘build our way out of recession'. Housing targets should be ambitious and should not be used as a tool for restricting housing growth. We are also concerned how the housing needs of those not being met by the Council, will be met. Should a Council be planning for a lower target than would meet housing needs, they are required under the Localism Act's ‘Duty to Co-operate' to work with neighbouring authorities to plan for meeting housing needs beyond borough boundaries. Paragraph 179 of the NPPF states that: ‘Joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas - for instance, because of a lack of physical capacity or because to do so would cause significant harm to the principles and policies of this Framework.' Evidence showing how the Council has met its duty to cooperate is not available. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

I was appalled at the artice in this weeks Sittingbourne News Extra which stated that the council will be limiting the building of new houses in the town to 540 per year. This is the equivalent to an estate Development targets for jobs almost the size of Eden village evey year for 20 years. I believe this is completely unsustainable. Mr B Read Objection LP27 Policy ST 2 and new homes 2011-2031 The people of Sittingbourne do not want this level of new houses without a supporting infrastructure and I do not believe SBC has the will or intention to improve the current facilities. The housing requirement is unsound because it is unjustified because it has not been derived in a manner that complies with national planning policy. We note that the Council plans to provide for 10,800 dwellings, or 540 dwellings per annum (dpa), over the plan period of 2011 to 2031. We do not consider that the proposed requirement is justified as the Council has not arrived at the proposed figure by way of an objective assessment of its housing needs. We are concerned that the figure of 10,800 has been determined as a consequence of certain policy considerations rather than an objective consideration of the evidence. This is hinted at by the discussion in paragraph 4.1.3 of the Local Plan which states that the housing requirement has been based on by the " long term average levels of delivery in Swale" and then goes on to state: "Setting a higher target would give us goals that are not attainable or viable at this time" . While all this may be the case, and these could be legitimate factors for the Council to consider when defining its housing requirement, the Council is still obliged by national policy to undertake an objective assessment of its housing needs first, and then exploring how it might accommodate these needs in full, unless there are "significant and demonstrable" reasons why doing so would bring the Council into conflict with other objectives articulated in the NPPF (i.e. paragraph 14). Even then, the duty to cooperate of the Planning and Compulsory Purchase Act 2004 (Amended) and the NPPF would oblige the Council to explore with its neighbours (or indeed further afield) how it could address these unmet needs if the Council is unable to accommodate these through the plan itself owing to significant and demonstrable planning constraints. On the question of constraints and what is legitimate to consider when assessing objective needs, the draft National Planning Practice Guidance (dNPPG) does caution against local planning authorities placing too much emphasis on past constraints: "Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing Development targets for jobs James Stevens Home Builders Federation Objection LP1427 Policy ST 2 evidence bases together to identify specific policies within development plans." (dNPPG, ref ID 2a- and new homes 2011-2031 004-130729). We therefore consider that failing to set a housing requirement that matches the objective needs of the district would not be in keeping with the spirit of the Government's exhortation to local planning authorities to ‘boost significantly the supply of housing'. The Council would need to demonstrate that there are significant planning constraints in the district that prevents the Council from planning for higher development needs before setting a housing requirement that is lower than the evidence of housing need. As we have stated, we remain concerned that the proposed housing requirement was agreed before the commissioning of new research to assess the objective needs of the borough. We note that the decision to adopt the requirement of 10,800 dwellings, or 540 dpa, pre-dated the commissioning of evidence from NLP. This is apparent when one considers the Strategic Housing Market Assessment Update and Development Needs Study of March 2013 (SHMA 2013). It is evident from the SHMA 2013 report that the Council had already determined its requirement before consideration of the evidence. Policy has therefore shaped the plan, rather than consideration of the evidence. The more proper planning approach would be to consider what the evidence is suggesting and then consider how these development needs could be accommodated unless doing so would conflict ‘significantly and demonstrably' with other national planning policy objectives. We note that the proposed housing requirement of 540 dpa is lower than all the other scenarios considered in the SHMA 2013 report (pages 47-53). Significantly, the housing requirement is lower than the level considered necessary to support the local plan's employment objective - to support employment growth of 353 jobs per year (policy ST 2). We note that 540 dpa figure will only support 154 new jobs. As the report says, this scenario constrains substantially the size of the labour force and the creation of jobs compared to the Baseline and 2011 Sub-National Population Projection scenarios (paragraph 5.26). The decision by the Council to set a housing requirement that would fail to support the plan's employment objective is questionable. Such a decision must be at odds with the Government's Planning for Growth Object / Document Name Organisation Support Rep ID Title Consultee Response Part

ambitions (the Ministerial Statement of March 2011), the guidance contained in the NPPF (e.g. paragraphs 18-22) and the dNPPG ( How should employment trends be taken into account?). We note that scenario G - the Higher Economic Scenario - would provide for 740 dpa. This level of housing supply would assist in supporting the local plan target to support the creation of 353 new jobs per year. Overall, this scenario would require 14,800 dwellings to be provided (housing figures rounded). This would indicate that the Council may need to be considering a figure in this area to ensure that it is setting a housing requirement that at least supports its employment objectives. However, an objective assessment of need should consider those other factors that drive household formation that are independent from employment considerations. We note that the What Homes Where website (a free-to-use, web-enabled toolkit, promoted by the LGA, PAS the RTPI, SHELTER, and others) which is based upon the 2008-based household projections, notes that the trend-based projection is for 704 dpa, or 14,080 over 20 years. This compares with scenario D in the SHMA: Long Term Migration Trend which indicates a need for 670 dpa and scenario E: the Short Term Migration Trend which indicates a need for 680 dpa. This would indicate that the Council should probably be considering a more realistic housing requirement - one that sits between 670 and 740 dpa. This would be necessary to address the long term trend projection for migration and to support employment generation. Given the uncertainties inherent with all projection-based modelling a reasonable compromise might be to set a housing requirement for 700 dpa. The housing requirement of 540 dpa is also lower than the scale of need suggested by the East Kent SHMA Update of 2013 which considers that 4,295 affordable homes would need to be provided to address the backlog together with a further 1,186 dpa to address newly arising need. The East Kent SHMA considers the need to provide between 600 to 900 dpa to help address problems of affordability in Swale. This range suggests that a housing requirement of at least 750 dpa should be considered by the Council. The SHMA observes considerable affordability pressures in the district. The SHMA records that in Swale the lower quartile house price to median earnings ratio increased from 7.24 to 7.35 over the last five years. Swale has become slightly less affordable as a consequence (paragraph 3.26). We note that the SHMA has assessed the affordable housing needs of the borough to be 1,522 per year (core output 5, page 63). The affordable housing needs of the borough exceed considerably the planned supply. The dNPPG advises that factors relating to affordability should be taken into account when establishing a housing requirement. Relying on projection modelling alone will tend not to account for errors made in the past when planning for needs (e.g. the section of the dNPPG entitled: What is the starting point to establish the need for housing? (Ref: ID 2a-015-130729). Against the background of the advice in the dNPPG, and in the light of the evidence of the affordability pressures in the district in the East Kent SHMA plus the level of provision necessary to support employment growth in the SHMA 2013, we consider that a requirement of the order of 750dpa should be considered by the Council. It is important for the Council to recognise that its decision to run with a policy-led housing requirement will not address its full objective housing needs as indicated by the various demographic projections deployed (scenarios B, D and E) or the level of need indicated is necessary to address its affordable housing needs. As such, we consider that the Council could be at risk of advancing an unsound strategy. The Local Government Association/Planning Advisory Service advice note entitled Ten Key Principles for Owning Your Housing Number - Finding Your Objectively Assessed Needs argues on page 11 that " all the identified requirement that exists within the area should be met within that housing market area, Not doing so is likely to lead to displaced demand, and also create considerable risks in relation to the duty to cooperate and the soundness test". Swale will have to meet its needs in full or approach its neighbours to agree an alternative means of provision. This seems likely given the decisions currently being made by those authorities neighbouring Swale. We will describe this situation below. Turning to the question of whether there are any ‘significant and demonstrable' constraints that might prevent Swale from considering a higher housing requirement that would address the Council's objective needs in full, we note that the Sustainability Appraisal: Non-Technical Summary (SA) does not really explore this question. The baseline context review provides a very general overview of the potential issues so it is hard to ascertain whether there are potential conflicts with other policies in the NPPF that are so significant that it would be unwise to plan for a higher level of housing supply. We do note, however, that on page 10 of the SA the report observes that the plan would not support the social and economic dimensions of the sustainability matrix because the plan is not based upon the objectively assessed housing needs of the future Object / Document Name Organisation Support Rep ID Title Consultee Response Part

because the level of housing proposed would be insufficient to support the labour supply needed for the level of economic growth proposed in the plan. Under the circumstances we consider that the Council should increase its housing requirement to at least 700 dwellings per year, if not the 740 per year necessary to complement the Council's employment strategy (or rounded up to 750dpa). Duty to cooperate We note that although the plan reflects upon Swale's position in relation to the Thames Gateway, and the borough's proximity to London, it says little about planning developments beyond its border. The decisions being made by Swale's neighbours could have ramifications for Swale that the Council should take this into account in assessing its housing needs. We note paragraph 4.4.25. The Council acknowledges here that it may have an unmet housing need, but it is unable to address this because the plans of Medway and Ashford are insufficiently advanced for allocations to be made. This begs the question when the right time would be for discussions about the potential for cross-border collaboration to occur. It would appear that there is never a good time to plan strategically: neighbouring plans are either too advanced or too embryonic. We do not consider this absolves Swale from engaging constructively and on an ongoing basis to explore means to accommodate its unmet needs. The Council also maintains that Canterbury and Maidstone will be addressing their own objective needs in full (which we dispute in the case of Canterbury and possibly Maidstone too - see more below) and accommodating Swale's unmet needs would detract from ‘sustainable development' in their area. This is a partial interpretation of what constitutes sustainable development especially when neither of these authorities have yet tested the NPPF constraints that may confront them. This reading would also imply that the duty to cooperate is inherently unsustainable because it requires unmet needs to be accommodated by another LPA. Swale will need to account for what is taking place on its borders. Swale will need to increase its level of supply to meet its own objective needs. It will need to do so because planned provision by its neighbours is inadequate and this will affect social conditions in Swale unless the problem is confronted. Canterbury Canterbury is advancing a local plan with a housing requirement for 15,600 dwellings to be provided between 2011-2031 or 780 dpa. This is inadequate to address the level of need identified by the SHMA which assess the affordable housing need to be 1,104 dwellings per year. In the case of the 2008-based household projections these indicate that some 16,760 households will form over Canterbury Council's proposed plan period of 2011 to 2031, or 840 per year. We would contest Swale Council's claim in paragraph 4.4.25 of its local plan that Canterbury will be addressing its objective needs. Like Swale, the Council has utilised scenario modelling (also by NLP). Like Swale, Canterbury has selected a scenario that is a policy-led scenario. Canterbury's Scenario E: futures ‘preferred scenario' serves as the basis for the derivation of its housing requirement. It is difficult to call this an objective assessment because it reflects a policy objective that the Council wishes to achieve by the end of its plan. This is not an objective assessment of need as such but an aim of the plan to attract more knowledge workers. Scenario E considers what is necessary to enhance the ‘knowledge economy'. While this may be a legitimate planning objective, it does not provide a robust basis for assessing the objective need. A housing target that is geared towards providing the scale of housing supply necessary to match the anticipated increase in knowledge economy workers ignores those other housing needs that will materialise during the life of the plan: namely the needs of those people who are not knowledge workers. Paragraphs 4.43 and 4.44 of the NLP report for Canterbury Council make clear the limitations inherent in such an assessment: that the work by Experian that has been used to inform this scenario has identified the projected employment growth under this scenario and then has related this to the number of new houses necessary to sustain employment in this sector. It follows, that the problem with this rationale is that if used on its own it will neglect the other components of the housing need, not least those who are unemployed, the economically in-active, or those who do not fall within the category of knowledge workers but are still working and still need housing. Basing your housing strategy upon what is necessary to match the needs of knowledge workers would ignore other components driving household formation. Therefore on the basis of current indications Canterbury is not advancing a plan that would address all its future housing needs. We think that Swale should object to this, with the aim of encouraging Canterbury to plan more responsibly. The alternative would be the need for Swale to increase its own housing requirement to account for the possibility of an influx of housing refugees from Canterbury. Ashford Ashford is preparing a new SHMA in concert with Maidstone and Tonbridge & Malling councils. The results of this work is anticipated in late Autumn. In the meantime Ashford has Object / Document Name Organisation Support Rep ID Title Consultee Response Part

an adopted plan that provides for 1,370 dpa. This compares to the 2008-based household projections that indicate a need for 14,700 dwellings over the same period. Ashford was once accorded Growth Point status under the SEP and was provided with additional money by central Government to facilitate this expansion. There is no evidence to suggest that Ashford wishes to continue to be growth point into the future, performing the role of a pressure-valve for the wider needs of the South East authorities by providing for more homes than its own objectively assessed needs would indicate are needed. Medway Examination of Medway's new local plan is underway. The Inspector has raised concerns that the new plan has not properly assessed the objective needs of the district in accordance with the consideration set out in the NPPF (letter from Inspector to the council dated 18 April 2013 and a concern repeated in her letter dated 7 August 2013) although this is disputed by Medway Council. It is unclear therefore at this juncture whether Medway is planning to address its own needs in full. What is evident when one considers Medway's plan is that it is not making provision to accommodate any of Swale's needs. Maidstone Maidstone is preparing a new SHMA in collaboration with Ashford and Tonbridge & Malling councils. The 2008-based household projections indicate a need for 15,000 dwellings for the period 2011-2031, or 750 per year. Emerging work on a new local plan suggests that Maidstone council may be considering a housing requirement of 14,800 dwellings over a 20 year plan period of 2011 to 2031. While this figure is broadly on a par with the 2008-household projection and this suggests that Maidstone may be addressing its objective needs (on the basis that 2008-based projection serves as a proxy in the absence of more up-to-date SHMA evidence) it is clear that Maidstone will not be providing any additional capacity for housing to provide for anyone else's unmet needs. London There is also the problem of London that Swale will need to contend with. The London SHMA that fed into the London Plan 2011 identified a need for 34,900 homes a year for ten years (2011-21), but the Panel Report on the Replacement London Plan concluded that this must be regarded as the very minimum and considered it more appropriate to postulate a range between 34,900 and 37,400 (see paragraphs 3.26-27 of the Panel Report). Furthermore, the Panel Report noted that housing provision in the East of England and South East Plans were already well below the 2006-based household projections (paragraph 3.25 of the Panel Report). What is more, the London Plan depends upon at least 20,000 households leaving the capital each year for the SHMA figure to be representative of future needs. If these households cannot leave, then the London requirement increases. The London Plan would therefore need to increase supply by an additional 20,000 households to consume its own needs. As London has no plan to do so, the trend for out-migration into Swale is set to continue. Table UKF8 reproduced from the What Homes Where toolkit shows the net inflows into Swale and the principal exporting authorities. The table demonstrates the large contribution made by the London boroughs to Swale's population with six London Boroughs in the top ten of exporters.

UKF8: Net flows into area 2010-11 net flow: Projected household growth SWALE number of people in 'sending' LA

Medway UA 330 21%

Bexley 80 24%

Greenwich 80 23%

Southwark 60 41%

Lambeth 40 24%

Lewisham 40 32%

Bromley 40 29% Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Thurrock UA 30 41%

Dartford 30 38%

Gravesham 30 27%

Tonbridge and Malling 30 33%

Southend-on-Sea UA 20 28%

Bedford UA 20 27%

Hackney 20 20%

Tower Hamlets 20 41%

Croydon 20 28%

Ealing 20 22%

Sutton 20 36%

Waltham Forest 20 16%

West Berkshire UA 20 32%

The Greater London Authority (GLA) is currently undertaking work on the new SHMA to inform revisions to the London Plan in line with the Examining Panel's recommendations. This is work that is in progress, but initial results indicate that over the new plan period of 2016-2031 (15 years) London could see an increase of 45,000 households a year. Other commentators, like London Councils, have assessed the rate of household formation in London to be higher - they consider that there will be a need for 52,600 homes per year between 2011-2021 ( The London Housing Challenge: A London Councils Discussion Paper . September 2013). Recent work on the London SHLAA/Housing Capacity Study is indicating that London may only have the capacity to accommodate 40,000 dwellings per year. There is therefore a considerable gap between need and supply in London. Swale and other authorities will need to account for this in their plans because such levels of need will begin to rebound on the authorities of the South East. It is also important to recognise that the GLA London household projections assume that the pace of outward migration will continue along the lines of past trends. If, however, the authorities of the South East and East of England are not planning to match their planned supply to their objective needs to a level indicated by at least the household projections, then London's needs will increase. There is now considerable evidence to show that this is the case (Reigate & Banstead Council provides a stark example of this tension. It is setting is housing requirement on the basis of zero net migration plus a little more on the basis that it no longer wishes to serve as a growth area for London). This will not just be a problem for London. It will have reverberations for Swale's plan. The consequence may be much greater levels of inward migration into Swale by relatively more affluent households who will out-bid locals for access to a scarce housing stock. The evidence that is emerging from Swale's neighbours would point to the need for Swale to build-into its housing requirement some contingency in case it is subject to much greater levels of inward-migration. Again, this would lend support to setting a housing requirement greater than 540 dpa. At the very least we consider that the Council should be meeting its trend-level projection of 700 dpa. However, to support the local plan's employment objectives and to provide an element of additional flexibility to accommodate potentially higher levels of need as a consequence of under-supply elsewhere, we consider that the Council should be consider a housing requirement of 740 dpa (or rounded up to 750dpa). Viability Object / Document Name Organisation Support Rep ID Title Consultee Response Part

of the plan and implications for delivery We read with interest in paragraph 4.1.9 that Swale Council relies heavily upon the viability of development to fund much of what it wants in terms of supporting infrastructure, services and affordable housing. We were therefore surprised that the Local Plan has not been accompanied by an integrated viability assessment that considers the cumulative cost of all the proposed local plan policies. We consider this necessary not only because it is a requirement of national policy but in order for the Council to assess what developers might be likely to be able to afford to fund and for this assessment to be used to inform the preparation of the plan and the policy choices to be made. I note that your Council are proposing the development of 540 dwellings per annum (dpa), as compared to an economic and housing need scenario of 740 dpa identified in the NLP report. The SA of the draft Plan seems to indicate that selected strategy would be negative as a result, in that it would not meet the economic strategy for the area or housing needs. Also, the draft Local Plan indicates (para 4.4.12) states that "Our evidence has concluded that it is difficult to demonstrate that growth at levels within the lower and middle bands of the 600-900 housing range would significantly adversely affect the Borough's principal environmental assets". The SA concludes, in relation to the level of development proposed in the draft Plan, that "its performance in terms of achieving the objectives 'to provide affordable and decent housing adaptable to future needs of the community' and 'to meet the challenges of a growing and ageing population' is limited. This is because it is not based on the needs of the future population or the number of houses potentially needed to support the labour supply for the economic growth proposed. Given that the housing growth proposed is not based on objectively assessed need this would also potentially limit the achievement of economic SA objectives" (p12, NTS). I note the view expressed in the draft Plan that Swale cannot deliver housing at the upper levels based on past delivery rates. However, it seems unlikely that this will be sufficient grounds on which to reject the recommended housing figures. In relation to the questions in your letter: (i) Our current housing target as set out in the most recent adopted Local Plan is likely to deliver about the same as the annual housing target of the former South East Plan. Although the adopted Local Plan sets a target of 440pa, the Council has effectively been working to the SE Plan requirement of 51Odpa since 2009. Housing completions have averaged about 550dpa over the last 20 years. (ii) A Development Requirements Study was undertaken by Nathaniel Lichfield & Partners in 2012. Although this slightly pre-dated the final version of the NPPF, the Development targets for jobs emerging principles from the draft NPPF were taken into account, and the study is therefore Mr A Verrall Canterbury City Council Objection LP818 Policy ST 2 and new homes 2011-2031 considered to be NPPF-compliant. (iii) Canterbury does have an identified housing land supply, including an appropriate buffer, of deliverable housing land, of about 6.5 years. (iv) The Council is intending to review its assessments once more reliable data is released from the Census regarding migration and household formation rates. It is anticipated that this review work will take place early next year. (v) The Strategic Housing Market Assessment, the Development Requirements Study and the Sustainability Appraisal all suggest a significantly higher housing requirement than that in the adopted Local Plan (see below). (vi) In terms of emerging/draft development targets, the draft Canterbury District Local Plan sets a total housing requirement of 15,600 units (780 dpa). (vii) It is highly unlikely that Canterbury City Council could assist in meeting Swale's unmet housing requirement, for the following reasons:

1. The Sustainability Appraisal of the DRS scenarios indicates that Scenario E (780dpa) represents the best balance between social, economic and environmental criteria. 2. The Development Requirements Study concluded that levels of development above 780dpa would be unlikely to be deliverable, given market capacity and demand. 3. The Habitat Regulations Assessment report of the draft Local Plan (based on 780dpa) identifies a potential risk that the implementation of proposed new developments in the draft Local Plan could result in significant effects on European sites from some development sites. Any increase in housing numbers would be likely to increase that risk. 4. There are unlikely to be any suitable sites in our SHLAA which could serve the needs of Swale. All the SHLAA sites in Canterbury have been subject to a Sustainability Appraisal and the vast majority of sites that have been assessed favourably have either been proposed for allocation or are sites which can come forward under the existing Local Plan Object / Document Name Organisation Support Rep ID Title Consultee Response Part

framework.

Set the Job target range as a minimum 7,140 ( 357pa) to 8,640 (432pa based on pre-recession Development targets for Swale Mr Howard Courtley Director Courtley Consultants Ltd Objection LP375 Table 4.4.1 growth levels) to allow flexibility over the plan period. Set the Housing Target for plan period as a 2011-2031 minimum 15,000 dwellings i.e.750 pa. These are the holding comments from Newington Parish Council until the full council meeting on the 1 st October.

These are the holding comments from Newington Parish Council until the full council meeting on the 1 st October.

Newington historically has been a large village with good services and in the past would have been classed as Rural Local Service Centre. This is when it had a doctor’s surgery, a choice of shops, three pubs and a social club, plus a half-hourly train service when over 50% of services stopped, M Harris Newington Parish Council Objection LP459 4.5.3 Paragraph and a road asset in the A2. It no longer has any health facilities; it is left with one pub and one shop. Now only 25% of trains stop at the village, and the main road has gone from being an asset to a problem. Very few people come to Newington from surrounding villages for any services except for a few using the station - and that is primarily because the station car park is free and there are no parking restrictions in the surrounding streets. Even these numbers are decreasing, as services from Newington are continually being cut. It is now no more than a large village that is located on a major road and has a railway line running through it. It should be moved from a rural local service centre to a village with built-up area boundaries. Klaire Lander (DHA) Owner of land at The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Support LP78 Table 4.5.1 Swale Retail Hierarchy Parsonage Farm, Newington Service Centre' (paragraph 4.5.7). The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Owner of land at Cellar Hill, Teynham Support LP89 Table 4.5.1 Swale Retail Hierarchy Service Centre' (paragraph 4.5.7). The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Klaire Lander (DHA) Owner of land at Support LP77 4.5.7 Paragraph Service Centre' (paragraph 4.5.7). Parsonage Farm, Newington

The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Owner of land at Cellar Hill, Teynham Support LP88 4.5.7 Paragraph Service Centre' (paragraph 4.5.7).

You state that the island comprises of 30% of the local population and 23-24% of its employment and new housing. Your developments will further broaden the gap between population and Mr Paul Hutchinson Objection LP147 4.5.12 Paragraph employment and new housing will increase. I only foresee that this will add further to the deprivation

of the area. I would welcome feedback on how you intend to attract new life to a deprived area with limited employment opportunities. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We note that Faversham has 24% of the population of Swale, 20.6% of its employment and only 17% of the residential development in Swale over the last ten years has been in Faversham. This reflects ongoing policies to protect the heritage of the town. There is an imbalance in housing and Anne Salmon Faversham Society Support LP1377 4.5.12 Paragraph employment in the town which is a justification for not adding large volumes of additional housing. We would agree with the urban hierarchy and resulting Swale Settlement Strategy as set out in policy ST3. While you acknowledge the constraints of Sheerness and therefore continued development is to be in the ‘triangle'; to continue to do so without due cognisance and mitigation will only stymie any Mr Paul Hutchinson Objection LP148 4.5.13 Paragraph development and exacerbate the issues already prevalent within the area ie congestion and deprivation. These are the holding comments from Newington Parish Council until the full council meeting on the 1 st October.

Newington historically has been a large village with good services and in the past would have been classed as Rural Local Service Centre. This is when it had a doctor’s surgery, a choice of shops, three pubs and a social club, plus a half-hourly train service when over 50% of services stopped, Qualified M Harris Newington Parish Council LP460 Table 4.5.2 Settlement categories and roles and a road asset in the A2. It no longer has any health facilities; it is left with one pub and one shop. support Now only 25% of trains stop at the village, and the main road has gone from being an asset to a problem. Very few people come to Newington from surrounding villages for any services except for a few using the station - and that is primarily because the station car park is free and there are no parking restrictions in the surrounding streets. Even these numbers are decreasing, as services from Newington are continually being cut. It is now no more than a large village that is located on a major road and has a railway line running through it. It should be moved from a rural local service centre to a village with built-up area boundaries. A change to the settlement confines of Newington, to be extended to include the Parsonage Farm Klaire Lander (DHA) Owner of land at Qualified site, School Lane, Newington is supported.The wording of this paragraph is not clear however that LP80 4.5.16 Paragraph Parsonage Farm, Newington support the settlement confines as illustrated on the Local Plan Proposals Map should be extended to include sites put forward within the Revised Consultation Draft Local Plan. Other than changes needed to reflect new development proposals, CPRE Protect Kent support the Mr Brian Lloyd Senior Planner Protect KENT Support LP873 4.5.16 Paragraph retention of the defined built-up area boundaries as shown on the existing Local Plan Policies Map. An area at Chilton Manor Farm, adjacent to the built area in south Sittingbourne was identified by the Swale Urban Extension Landscape Capacity Study as the only one in Southeast Sittingbourne MR DEREK EPSLEY Objection LP222 4.5.20 Paragraph having moderate potential for change. All of the major allocations are to the north of Sittingbourne.

Traditionally the market has always been stronger to the south of the A2 but the plan does not provide for a diversity of choice. Klaire Lander (DHA) Owner of land at Support the largest scale of growth in the settlements which have the largest existing Support LP81 4.5.22 Paragraph Parsonage Farm, Newington concentrations of population. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Support the largest scale of growth in the settlements which have the largest existing Owner of land at Cellar Hill, Teynham Support LP92 4.5.22 Paragraph concentrations of population We support identification of Faversham as ‘Other Borough Centre’ within the Settlement Hierarchy, Mr Neil Flanagan Support LP545 Table 4.5.3 Settlement categories second behind the main Borough Urban Centre of Sittingbourne. Mr Brian Lloyd Senior Planner Protect KENT Support LP872 Table 4.5.3 Settlement categories CPRE Protect Kent support the settlement categories presented in this table. Klaire Lander (DHA) Owner of land at The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Support LP79 Table 4.5.3 Settlement categories Parsonage Farm, Newington Service Centre' (paragraph 4.5.7). The inclusion of Newington as a 'Local Centre' is supported (table 4.5.1) and as a 'Rural Local Owner of land at Cellar Hill, Teynham Support LP90 Table 4.5.3 Settlement categories Service Centre' (paragraph 4.5.7). We support identification of Faversham as ‘Other Borough Centre’ within the Settlement Hierarchy, Ordnance Wharf Support LP591 Table 4.5.3 Settlement categories second behind the main Borough Urban Centre of Sittingbourne. We support identification of Faversham as ‘Other Borough Centre’ within the Settlement Hierarchy, Gibb Femco Support LP676 Table 4.5.3 Settlement categories second behind the main Borough Urban Centre of Sittingbourne. We support identification of Faversham as ‘Other Borough Centre’ within the Settlement Hierarchy, Mr Michael White Support LP637 Table 4.5.3 Settlement categories second behind the main Borough Urban Centre of Sittingbourne. We object to the wording:

“outside the Gateway, in the Faversham Area and the Kent Downs Area of Outstanding Natural Beauty, it remains the case that the natural and the historic importance of the areas should be the primary factors influencing the growth”.

This wording suggests a strict limitation on new development at Faversham town, whereas elsewhere, the Draft Plan recognises the need and opportunities for new developments at an appropriate scale and locations, including beyond the existing built-up area - Proposed Policies A7, Mr Neil Flanagan Objection LP547 4.5.24 Paragraph A8 and A9. This sentence should be redrafted to accord with the remainder of the Plan, i.e. that the level of growth should be in accordance with its position in the Settlement Hierarchy and that there are appropriate development opportunities. A differentiation should be drawn between the policy basis for:

• Faversham Town ; • the Kent Downs AONB; and • the remaining rural area

as the underlying approach will be different in these District Areas. We object to the wording: “outside the Gateway, in the Faversham Area and the Kent Downs Area of Outstanding Natural Beauty, it remains the case that the natural and the historic importance of the areas should be the primary factors influencing the growth”.

This sentence should be redrafted to accord with the remainder of the Plan, i.e. that the level of growth should be in accordance with its position in the Settlement Hierarchy and that there are appropriate development opportunities. A differentiation should be drawn between the policy basis for:

• Faversham Town; Object / Document Name Organisation Support Rep ID Title Consultee Response Part

• the Kent Downs AONB; and • the remaining rural area

as the underlying approach will be different in these District Areas. We object to the wording:

Gibb Femco Objection LP677 4.5.24 Paragraph This sentence should be redrafted to accord with the remainder of the Plan, i.e. that the level of growth should be in accordance with its position in the Settlement Hierarchy and that there are appropriate development opportunities.

A differentiation should be drawn between the policy basis for:

• Faversham Town ; • the Kent Downs AONB; and • the remaining rural area

Mr Michael White Objection LP638 4.5.24 Paragraph This sentence should be redrafted to accord with the remainder of the Plan, i.e. that the level of growth should be in accordance with its position in the Settlement Hierarchy and that there are appropriate development opportunities. A differentiation should be drawn between the policy basis for:

• Faversham Town ; • the Kent Downs AONB; and • the remaining rural area

as the underlying approach will be different in these District Areas. The penultimate sentence of this paragraph should be deleted as it suggests that development Mr Brian Lloyd Senior Planner Protect KENT Objection LP874 4.5.28 Paragraph other than that stated in point 4 of Policy ST3 will be acceptable. All other settlements and sporadic buildings are considered to sit within the open countryside where Owner of land at Funton policies to protect it from isolated and/or large scales of development are to be applied. However, Bloomfields Ltd Objection LP1463 4.5.29 Paragraph Brickworks even here some development may be essential for the continuance of the social, economic or environmental health of a community, unless other national or Local Plan policies specifically Object / Document Name Organisation Support Rep ID Title Consultee Response Part

restrict it, such as housing in remote locations. Previous comments apply to the above paragraph in that it should include reference to a positive approach being adopted towards the re-development of rural brownfield sites.

Policy ST3

The general settlement strategy is supported i.e with Hartlip identified as an "other village" where only small scale development, within the settlement confines may be appropriate. Qualified Mr Graham Addicott Hartlip Parish Council LP485 Policy ST 3 The Swale settlement strategy support Policy ST3, Point 4 Clarification is required as to what is meant by "appropriate modest development" that can "meet community needs" on the edge of built up area boundaries. Does this mean affordable housing and/or other facilities? The word "exceptionally" is welcomed i.e for when development outside of the village boundaries would be acceptable. A caveat should be included that such development would be subject to the provisions of policy DM6. AONB villages are vulnerable and need the highest possible quality of design. Suggest add 'in line with policy DM24 to point 4 and amend 5i to add Policy DM24

i.e.: Qualified Mrs Jennifer Bate Planning Officer Kent Downs AONB LP510 Policy ST 3 The Swale settlement strategy support '....of services for their home communities and where appropriate in accordance withfor t policy DM24'

5i should also mention policy DM24 CPRE Protect Kent support the Swale settlement strategy set out in Policy ST3, but we would wish to see the following amendments: Amend the opening paragraph of point 5 to read as follows: "Locations outside the built-up area boundaries shown on the Proposals Map fall in the countryside. Here national and Local Plan policies recognise and protect the intrinsic value, tranquillity and beauty of the countryside and seek to maintain or enhance the vitality of rural communities. Subject Qualified to these considerations, and other policies in the development plan, planning permission will only be Mr Brian Lloyd Senior Planner Protect KENT LP875 Policy ST 3 The Swale settlement strategy support granted for development involving:" · Delete all the Policy references in the sub-points to point 5 as these are covered generically in the amendment we suggest above. · In sub-point 5f reference is made to ‘ rural worker ' - a definition of what comprises a ‘rural worker' in the context of this Policy (and Policy DM12) should be included in the supporting text and/or in Appendix 6 Sub-point 5h should be amended to read: " a site to meet local needs for affordable housing or an essential community facility; or". In relation to para 4.5.20 we note reference is made to the Swale Urban Extension Landscape Capacity Study 2010 and how it found areas around east Minster had a low capacity for change and areas with high or moderate potential for changes included to the west of Minster/Halfway. However, as discussed further in relation to the proposed allocations, it has been identified that this Landscape Capacity Study is not intended to act as a veto to development. Indeed there are some sites originally identified by the study as being of low capacity for change but then following subsequent assessment were found to have a higher capacity for change. As such it is not considered this study is robust to be relied upon to guide allocations. We support in para 2 that c/o Tetlow King Planning Kent Qualified LP1314 Policy ST 3 The Swale settlement strategy Minster shall contribute to meeting the Island's wider development needs on previously Developments UK Ltd support development sites and at existing committed locations and allocations well related to the urban framework. The site at Wootton's Farm, Minster is considered to meet this criterion and is well related to the urban framework. Part 5 for locations outside the built up areas and the circumstances in which planning permission would be granted for appropriate development, should include circumstances where the LPA is not meeting housing targets and additional sites are required to come forward. We note a similar approach is proposed where accommodation for Gypsies and Travellers cannot be met at housing allocations and as such a similar approach should be applied for all housing needs. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Turning to where this housing land should be identified, we agree with the Council that Sittingbourne should be the focus for highest levels of growth. Sittingbourne is the largest settlement in the Borough with levels of services and facilities commensurate with that. However, we consider that a greater role can be played by Faversham in the accommodation of growth requirements. Faversham, along with Sheerness are the next largest towns in the Borough after Sittingbourne and as such, it is those settlements that should be the focus for the next highest levels of growth. However, we consider that Faversham presents a distinct advantage over Sheerness, in that it is located in the relatively unconstrained ‘North Kent Plain', whilst Sheerness is constrained by the coast and undeveloped flood plain. Furthermore, the southern parts of the Borough and the settlements contained within it are constrained in landscape terms by the North Downs Area of Outstanding Natural Beauty (AONB). The Local Plan proposes that at Faversham, the natural and historic importance of the area should be the primary factor influencing growth. Furthermore, Paragraph 5.8.9 remarks that ‘our vision here is for a different focus and scale of growth - gradual growth, not forced, artificial or overwhelming. The conservation and enhancement of the historic and natural environments of the town and its surrounding rural hinterland are the primary planning aims'. Within this context, the Local Plan recognises within paragraph 4.5.20 that ‘It is found that large areas around southern Sittingbourne, east of Minster and north of Faversham Planner Savills (L&P) Ltd (for St Qualified Mr William Lusty LP1440 Policy ST 3 The Swale settlement strategy have a low capacity for change, whilst areas having high or moderate potential for change were John's College, Cambridge) support identified to the east and north west of Sittingbourne, on Iand to the west of Minster / Halfway and to the south and east of Faversham'. We have reviewed the Council's Landscape Character Assessment and this identifies land to the west and north of Faversham as having high landscape sensitivity. Land to the east and south, lying within the ‘Faversham and Ospringe Fruit Belt' is considered to have moderate sensitivity. As such, we are of the view that it is land to the east and south of Faversham that presents the best capacity for growth, particularly in landscape terms. The Key Diagram shows Faversham as an ‘other Borough Centre' (Policy ST3 Constrained Growth Focus). This shows that the area south of Ospringe is covered by the designation of ‘Protection of wider countryside' (Policy ST3). However, as explained above, the land south of Faversham presents the best capacity for growth in landscape terms. The Borough Centre designation should therefore be extended southwards to include the area around Ospringe. The Settlement Hierarchy sets out that Faversham will have ‘secondary urban scale' of growth, taking account of its historical and natural assets. We therefore believe that the urban area of Faversham should be extended southwards, where development would be able to take place, whilst acknowledging the historic and natural assets of the town. In particular, Ospringe should be included within this area for growth. In terms of the land owned by our client at Upchurch, we consider this is a suitable location for additional growth. As such, we support Upchurch's identification as a Village. Kent Wildlife Trust has no objections to the settlement hierarchy detailed within this policy. However any housing numbers within areas that could impact on the Natura 2000 and Ramsar network will Conservation Officer, Policy and Qualified Miss Debbie Salmon LP1081 Policy ST 3 The Swale settlement strategy need to be assessed via the HRA process to ensure that the level of housing proposed, when Planning Kent Wildlife Trust support coupled with appropriate avoidance and mitigation measures, will not create impacts that will affect the integrity of the site either alone or in-combination with plans for other areas. We accept that there are development opportunities in the Swale Area. However we are very concerned about the issues (see other reps) that and not being addressed by the local plan. Also, Mrs Lynda Fisher Bobbing Parish Council Objection LP100 Policy ST 3 The Swale settlement strategy more development appears to be in Sheppey and Sittingbourne - can other parts of Swale share the burden of a growing population (i.e. East Swale and the villages)? Whilst we support the identification of Faversham as a second Settlement in the Hierarchy and as a settlement appropriate for ‘secondary urban scale of growth’, we object to wording ‘compatible to their historic and natural assets’ as this suggests a strict limitation on new development at Faversham town, whereas elsewhere, the Draft Plan recognises the need and opportunities for new Mr Neil Flanagan Objection LP548 Policy ST 3 The Swale settlement strategy developments at an appropriate scale and locations, including beyond the existing built-up area - Proposed Policies A7, A8 and A9.

Suggest delete ‘compatible to their historic and natural assets’. Ms D Haigh Objection LP426 Policy ST 3 The Swale settlement strategy 4.1.7 states ‘We are concentrating on regeneration sites and at locations that either have the

Object / Document Name Organisation Support Rep ID Title Consultee Response Part

facilities and services that can support new growth or can themselves be supported by growth'.

Newington has been identified as a Rural Local Service Centres which is 3rd tier. However, 4.5.26 describes why Newington has very limited development opportunities.

The village is too small and inaccessible in sustainable terms to be classified as Tier 3 in ST13. Its classification should be amended to Tier 4 (large village with train station) as this is the only differentiation from the other Tier 4s. The village cannot expand due to infrastructure so it is illogical that to have as a Tier 3. The overall strategy for GT provision is confusing. It is not clear from reading DM10 what this is. The clearest statement is in para 4.5.33 with Policy ST3. If I understand this correctly:

• priority is to be given to provision as part of major housing allocations • other need will be met by specific allocations or planning applications in accordance with Policy ST3. It is not clear what is meant by ‘specific allocations'

It is not clear how policy ST3 will work in relation to planning applications by Travellers. It is not clear what is meant by ‘the availability of sites at each settlement category shall be first dismissed before consideration of a site at a location within a lower category'. With reference to para 7.4.33 it would appear that applications for new housing estates in category 2,3 and 4 will not be considered Mrs Alison Heine Objection LP33 Policy ST 3 The Swale settlement strategy until all options in Sittingbourne are explored. Likewise a planning application from a Traveller for a site in category 2,3,4 settlements or in open countryside will not be considered until it is shown that sites are not available in Sittingbourne. This is unrealistic, unfair and unworkable. It will merely serve to thwart provision in most parts of the district. On this basis there could be a requirement that all 85 pitches identified in the need assessment would have to be provided in Sittingbourne offering no choice of location to Travellers. Most Traveller sites are at present at in open countryside as few/ if any sites have been found in settlement boundaries. If an application is made for a site in open countryside (e.g. to renew consent for a site with temporary permission) then it would appear the applicant has to prove first that there is no suitable site in settlement categories 1-4. But that is wholly unrealistic as most sites in settlements 1-4 will not come forward other than as part of a major housing scheme It is unclear where this puts all the families living on sites with temporary permissions on sites in open countryside outside any settlement boundary. It is requested that a change is made to the settlement confines of Teynham to be extended to Owner of land at Cellar Hill, Teynham Objection LP91 Policy ST 3 The Swale settlement strategy include land at Cellar Hill Teynham. Whilst we support the identification of Faversham as a second Settlement in the Hierarchy and as a settlement appropriate for ‘secondary urban scale of growth’, we object to wording ‘compatible to their historic and natural assets’ as this suggests a strict limitation on new development at Ordnance Wharf Objection LP593 Policy ST 3 The Swale settlement strategy Faversham town, whereas elsewhere, the Draft Plan recognises the need and opportunities for new developments at an appropriate scale and locations, including beyond the existing built-up area - Proposed Policies A7, A8 and A9. Suggest delete ‘compatible to their historic and natural assets’. Whilst we support the identification of Faversham as a second Settlement in the Hierarchy and as a settlement appropriate for ‘secondary urban scale of growth’, we object to wording ‘compatible to their historic and natural assets’ as this suggests a strict limitation on new development at Faversham town, whereas elsewhere, the Draft Plan recognises the need and opportunities for new Gibb Femco Objection LP678 Policy ST 3 The Swale settlement strategy developments at an appropriate scale and locations, including beyond the existing built-up area - Proposed Policies A7, A8 and A9. Suggest delete ‘compatible to their historic and natural assets’.

Whilst we support the identification of Faversham as a second Settlement in the Hierarchy and as a settlement appropriate for ‘secondary urban scale of growth’, we object to wording ‘compatible to Mr Michael White Objection LP639 Policy ST 3 The Swale settlement strategy their historic and natural assets’ as this suggests a strict limitation on new development at Faversham town, whereas elsewhere, the Draft Plan recognises the need and opportunities for new Object / Document Name Organisation Support Rep ID Title Consultee Response Part

developments at an appropriate scale and locations, including beyond the existing built-up area - Proposed Policies A7, A8 and A9. Suggest delete ‘compatible to their historic and natural assets’. Update Policy ST3 paragraph 4 to:

"Other villages with built-up area boundaries shown on the Proposals Map, smaller scales of infill Mr Beverley Willis Bredgar Parish Council Objection LP759 Policy ST 3 The Swale settlement strategy development within the built up area boundaries will be permitted where compatible with the settlement's character. Exceptionally, within the built up area boundaries, appropriate modest development will be permitted that respects the value of the surrounding countryside, can meet community needs and/or reinforce the settlements role as a provider of services for their home communities; Trenport supports the categorisations of Sittingbourne as the ‘Main Borough Centre’, and Teynham as a ‘Rural Local Service Centre’, for the reasons given in the draft Local Plan. Sittingbourne is the largest settlement with the greatest range of shops, services and employment opportunities and so is quite properly the main centre for the Borough. In respect of Teynham we note that the Borough Council’s Rural Sustainability Study (2011) finds that Teynham has:

• Extremely good range of services and facilities • Good public transport links with both buses and trains • Good employment opportunities • Chris Hall Trenport Investments Ltd Support LP787 Policy ST 3 The Swale settlement strategy Low unemployment rate • High capacity for change

Teynham has the greatest range of services and facilities of any of the 40 rural settlements looked at in the study, and so it must be concluded that Teynham is the most sustainable rural settlement in Swale. Although we have not undertaken a detailed comparison we suspect that Teynham may actually be a more sustainable location for development than a number of the ‘Other Urban Centres’, identified in the policy, bearing in mind its railway station and location on the North Kent Railway line, its location on the A2, which is served by a number of bus routes, and it’s easier access to existing services and facilities at Sittingbourne and Faversham compared to the Other Urban Centres located on the Isle of Sheppey. The identification of Newington as a centre which will be a main focus of rural scales of growth and Klaire Lander (DHA) Owner of land at Support LP82 Policy ST 3 The Swale settlement strategy a suitable place for delivering new houses is supported. Parsonage Farm, Newington

Response: The Crown Estate supports the settlement strategy and the allocation of housing sites in Minster

The Crown Estate supports the approach to spatial planning within policy ST3 over the plan period and, in particular, the recognition of Minster's role as a location for housing growth to support the employment investment around Sheerness and Queensborough (as set out in policy ST6 - Isle of Sheppey Strategy). We consider that sites in Minster are well placed to assist in housing delivery and in delivering a joint strategy for the provision of homes and jobs in tandem with the employment growth elsewhere on the island. Sites around Queensborough and Sheerness are restricted by The Crown Estate Support LP1434 Policy ST 3 The Swale settlement strategy environmental factors, particularly flood risk and cannot deliver housing growth for that reason. Minster has a good range of services and can play a key role in the delivery of the Local Plan, given the availability of sites, the range of services and lack of environmental constraints. The key theme running through the NPPF is to provide a presumption in favour of sustainable development (paragraph 14). Other guidance provided in NPPF seeks to ensure that sustainable development is delivered through a number of steps including managing patterns of growth to ensure development takes places in locations which are or can be made sustainable (paragraph 17) and facilitating the use of sustainable modes of transport. To contribute to the aims of achieving sustainable patterns of development as per the requirements of the NPPF, the Local Plan should ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

jobs, key services and infrastructure. Minster performs well in sustainability terms and has a good level of services including education, health and shops for example as well as public transport links to higher order settlements. Figure 4.5.1 on page 63 of the Local Plan indicates that Minster has good accessibility to key services. As such Minster can support further housing and employment development as set out in Table 4.1.

Services .· ·. . Comment . . Compliance with ·sustainable development objectives in NPPF Primary Doctors: Dr Ramu V K and Partner Minster Medical .J J healthcare Centre Dentist: Hilton Dental facilities Surgery Pharmacy: Minster Pharmacy Sheppey Hospital Pharmacy Halfway Pharmacy Schools Halfway Houses Primary School Minster and J J Sheppey County Primary School Elliott Park Independent Day School Minster in Sheppey Primary School The Isle of Sheppey Academy(11-19years) Organised sport Sheerness Golf Club Sheppey United Football J J Club Sheppey RFC Sheppey Cricket Club Retail and Service Six pubs in settlement Two Post Offices . Range of J J Provision shops and services including restuarants, takeaways,hairdressers,convenience shops and Co-op supermarket Minster Rd Baptist Church Access to higher Regular bus services to Maidstone J J order settlements TownCentre, Sittingbourne Town via public Centre,Rushenden.Service360 provides three buses transport an hour to Sheerness.

Key Does not contribute to sustainable development objectives X Contributes to sustainable development objectives J Exceeds sustainable development objectives J J

Table 4.1 demonstrates that Minster has a wide range of services and is not dependant on other settlements for access to services to meet everyday needs. As such the settlement can deliver sustainable patterns of development as sought in the NPPF. Furthermore, improving access to housing in Minster will help to support local services and thereby help to maintain and improve the self sufficiency of the settlement. Therefore, Minster provides a sustainable location for new development and the proposed allocations in Minster identified in Policy A9 can support sustainable patterns of growth as called for by the NPPF The development Plan will also comprise any Neighbourhood Plans prepared and agreed by referendum, and this should be acknowledged in this paragraph. We are aware of at least two Neighbourhood Plans being actively progressed in the Borough and at least one other Parish that will be commencing soon. CPRE Protect Kent find it a little unfortunate that, having decided to Mr Brian Lloyd Senior Planner Protect KENT Objection LP876 4.5.36 Paragraph prepare a single Local Plan, it will actually be presented in 3 parts. In particular we find it difficult to understand why the matters proposed for inclusion in Part 3 are not included in the plan currently under consultation in a comprehensive fashion. We would strongly urge the Council to address these matters and include them in ‘Part 1’ of the Draft Plan. We appreciate the Borough Council’s desire to increase employment opportunities, but we note that Mr Brian Lloyd Senior Planner Protect KENT Objection LP877 4.5.41 Paragraph the current land supply is significantly above that needed even for the higher economic growth scenario. See our comments in Part 1 of our response on employment growth. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Agree that for Faversham, some increase in housing is justified in support of its population and Mr Neil Flanagan Support LP549 4.5.44 Paragraph economic share, particularly as the area continues to be economically viable for the building of new

houses. Agree that - for Faversham, some increase in housing is justified in support of its population and Ordnance Wharf Support LP594 4.5.44 Paragraph economic share, particularly as the area continues to be economically viable for the building of new

houses. Agree that - for Faversham, some increase in housing is justified in support of its population and Gibb Femco Support LP679 4.5.44 Paragraph economic share, particularly as the area continues to be economically viable for the building of new

houses. Agree that - for Faversham, some increase in housing is justified in support of its population and Mr Michael White Support LP640 4.5.44 Paragraph economic share, particularly as the area continues to be economically viable for the building of new

houses. CPRE Protect Kent strongly support this intention, but it would be helpful to explain how the Council will do this given the requirements of paragraph 47 of the National Planning Policy Qualified Mr Brian Lloyd Senior Planner Protect KENT LP878 4.5.45 Paragraph Framework. For example, is it the intention of the Council to monitor five-year land supply support separately for both the Thames Gateway part of the Borough and for the rest of the Borough and use this as the basis for assessing five year land supply? Qualified Meeting the Local Plan Support the number of new dwellings and employment floorspace as identified in Table 4.5.5 - as a Mr Neil Flanagan LP550 Policy ST 4 support development targets minimum. The identification of the settlement of Newington as being suitable for the provision of fourteen dwellings is supported. Currently however, the Council is not identifying a sufficient number of sites to deliver the housing necessary to meet the identified need. This is contrary to the NPPF and will not deliver a robust and sustainable housing supply. The development of housing within Newington Klaire Lander (DHA) Owner of land at Qualified Meeting the Local Plan LP83 Policy ST 4 is therefore supported, since it is a highly sustainable settlement, with good public transport links, Parsonage Farm, Newington support development targets shops and services, as acknowledged by the Consultation document which identifies Newington as a Rural Local Service Centre. The Council's lack of a five year housing supply means that the delivery of the site identified at policy A9 i.e. the Parsonage Farm site, School Lane, Newington will help to meet rural housing needs. Qualified Meeting the Local Plan Support the number of new dwellings and employment floorspace as identified in Table 4.5.5 - as a Ordnance Wharf LP595 Policy ST 4 support development targets minimum. Qualified Meeting the Local Plan Support the number of new dwellings and employment floorspace as identified in Table 4.5.5 - as a Gibb Femco LP681 Policy ST 4 support development targets minimum. Policy ST4 provides for 538 houses to be developed in the Faversham area and 41000 square metres of employment floorspace. This includes the area in the Faversham Creek Neighbourhood Plan. No additional retail or leisure floorspace is expected to be provided for Faversham within the Plan period. It is probable that there will be some additional retail use and some additional leisure facilities as part of the Creek Neighbourhood Plan. The housing allocation includes 223 houses at Qualified Meeting the Local Plan the Western Link, 150 at either Oare Gravel Works (or far more in the landowner’s scheme) or at Anne Salmon Faversham Society LP1378 Policy ST 4 support development targets Love Lane ( the Love Lane site could provide more if laid out as in the Dane Park scheme and generate more affordable units) 35 houses at Ham Road, around 40 at Boughton and some at the police station and near Bysing Wood School. This still leaves some units within the projected 538 on the existing allocations that would need to be accommodated within the Creek Neighbourhood Plan area to be decided as part of the Neighbourhood Plan process and achieved as a result of redevelopment of some of the identified sites. Qualified Meeting the Local Plan Support the number of new dwellings and employment floorspace as identified in Table 4.5.5 - as a Mr Michael White LP641 Policy ST 4 support development targets minimum. Whilst the Bearing Fruits draft Local Plan August 2013 looks to allocate land at Cryalls Lane Meeting the Local Plan Sittingbourne so as to accommodate 80 dwellings in draft policy A9, and we support that proposed Judith Ashton Barratt Strategic Objection LP435 Policy ST 4 development targets allocation, we note that the plan provides for no new development at lwade at all, despite the fact lwade is identified as a Rural Service Centre in the Bearing Fruits draft Local Plan (table 4.5.3 Object / Document Name Organisation Support Rep ID Title Consultee Response Part

refers) and the SHLAA makes it clear in appendix 4 (p47), when it assesses SW126 that the site has no policy constraints to prevent development, is suitable for development, is located within a sustainable location, is available and achievable within the plan period. There is no justified reason to look to restrict development in lwade as proposed in the Bearing Fruits draft Local Plan August 2013. Given the objectively assessed housing needs of the area as set out in the East Kent SHMA, the ONS projections, What Homes Where toolkit and the Experian projections we believe the plan should provide for a higher level of growth than currently proposed i.e. circa 14,000 dwellings and that land at lwade should be included within the housing provision. Alternatively the draft LP should provide for reserve sites as a means of assisting in the maintenance of the 5 year housing land supply and land east of lwade (SHLAA ref SW123) should be included within the list of reserve sites. To ignore the development potential of lwade will in effect result in a plan that conflicts with its central aim of sustainability- as set out in draft policy ST1 and ST3. Draft policy ST4 should thus provide for more development at Iwade (circa 425 dwellings rather than the 42 stated at present), and a new policy should be included within the plan providing for the development of land to the east of lwade so as to provide for circa 310 dwellings and land south east of lwade so as to provide for circa 75 dwellings (SHLAA site SW183).

Conclusions:- We do not believe the level of housing proposed in the borough has been justified. It does not reflect the objectively assessed needs of the area and as such has not been positively prepared and will not 'boost significantly the supply of housing'. There is in addition nothing to demonstrate that the plan will be effective. The plan thus conflicts with the aims and objectives of national policy as set out in the NPPF and is unsound. The only recourse open to SBC is to review the housing requirement, increase the housing target and identify additional land through a review of the settlement boundaries of the more sustainable settlements such as lwade, to meet the objectively assessed needs of the district. Whilst we trust the above is of assistance we would be happy to meet with officers to discuss the concerns we have raised further if they felt this would assist them in moving the Borough Plan forward. I live on the Isle of Sheppey in Kent and have recently been made aware of the scale of new development planned for the Island all under the umbrella of your NPPF and SBC Bearing Fruit. It would be interesting for someone to visit our Island and see the problems we already have with infrastructure, facilities and unemployment, there are no jobs here to speak of. There has been vigorous house building on the Island for a few years now with no added facilities or infrastructure, I cannot see how we can sustain even more building as planned in Bearing Fruits. Developers often promise added community benefits but always find an excuse not to bring them to fruition. Our Island is overcrowded as it is with much congestion. There are numerous holiday camps all open from March to December, with caravan and chalet owners backwards and forwards during ten months of the year, with the summer months bringing so much more congestion and all using our limited facilities. We have nothing against all this, we are a 'Holiday Island' after all. We also have a large prison cluster at the eastern end, one of which is vastly overcrowded, thus adding to the congestion. To sum up, we have limited facilities, not enough schools, medical services-we have a Meeting the Local Plan Mrs M Aspley Objection LP97 Policy ST 4 small community hospital with just a minor injuries department more often than not we have to development targets travel to Medway or Maidstone for treatment, no maternity facilities, and scant community programmes. We have one of the highest unemployment figures, and with benefit cuts and people moving out of London for cheaper housing our benefits bill will be even higher, because obviously, much of our proposed new building will be for social housing. Many of our children travel off the Island to school due to overcrowding and less than perfect education including my grandsons one of whom attends a special school in Sittingbourne because there is nothing for him locally. We have today suffered catastrophe on the Sheppey Crossing with approx. 130 vehicles and two hundred people involved in crashes. This was all people going to work off the Island and those people are still stuck on the bridge five hours later how can you add to our congestion? Ours is a small community and everyone will know someone who knows someone who was involved in this heartbreaking event, for myself at this time I know of at least two, one being my nephew while not badly hurt is very shocked by what has happened. I would appreciate it if you could explain to me how you can justify even more building on our Island when we have so many problems already. Mr Mike Baldock Swale - UKIP Objection LP739 Policy ST 4 Meeting the Local Plan 1) The housing concentration: By focussing the major part of their housing plans along the A249 Object / Document Name Organisation Support Rep ID Title Consultee Response Part

development targets corridor and on Sheppey, Swale are providing an unbalanced future housing strategy. They are leaving huge swathes of the Borough around Faversham and towards the East and South-East of the Borough – near Canterbury and Ashford – without sufficient housing to accommodate the population growth in this area that they predict. This also cuts the Borough off from opportunities in the Ashford area and in the East of the county. 2) The A249 is already well over capacity due to the housing concentration in this area over the past 10-15 years – the Meads and Iwade developments as well as considerable housing projects around Minster-on-Sea. There is daily gridlock around the Key St roundabouts and even worse congestion around the Stockbury roundabout / J5 of the M2. There are regular accidents already at this roundabout and associated junction. The back roads are used as rat runs and even these are clogged up daily. There simply isn’t the capacity on these roads for another several thousand houses in this area. 3) Without guaranteed financial commitment to a flyover / underpass at the Stockbury Roundabout this Local Plan will bring a meltdown of the road network and exacerbate the already dreadful traffic conditions in the area. Basically, the whole plan is riven with faults, reckless speculation, inconsistency and an insistence on its ability to deliver that is beyond optimistic. It needs rejecting in its entirety and a sensible, Meeting the Local Plan realistic and deliverable Local Plan put in its place, with more affordable housing and dissipated Mr Mike Baldock Swale - UKIP Objection LP743 Policy ST 4 development targets across the whole borough, and a guarantee of proper infrastructure to meet existing demand let alone that created by the new Plan.

We are learning, with alarm, that SBC are planning yet more housing on greenfield sites on an already over-populated Sheppey (Barton Hill Drive and everywhere).

Please what can you all be thinking?! The Island simply isn't big enough and during the summer time it grows again with holiday visitors and day trippers. The planners need to think again, really. Not only are there no decent shops in town or a fully functional seaside (as it used to be when we were children, happily growing up here), but not enough Doctors' surgeries, hospital facility, schools or ROOM.

We are not alone with our feelings, it is unanimous amongst Islanders. No one is listening to our Meeting the Local Plan Mr & Mrs L Belcher Objection LP205 Policy ST 4 views again . development targets We all know what it will bring, don't we. More crime, parking problems, as seen in Holmside Avenue etc, lack of social facilities for children and teenagers. The whole of the Island's springtime fields look amazing and a pleasure to see. Fresher air now the steelworks is no more.

Please Swale Borough Council stop thinking of money and development of beautiful land and put you thoughts into enhancing a potential haven by making opur town attractive to people, and the seafront a real pleasure again.

Please listen to us - totally against new housing . Furthermore, research formed via MPC's partnership work alongside Mr. David Orpin (Chartered Civil Engineer) prompts the Parish Council to question the numbers of housing Swale is allocating for development on the Isle of Sheppey. This view is supported by site inspections which show that the following allocations are not included:- Parish Clerk Minster-on-Sea Parish Meeting the Local Plan Mrs Trish Codrington Objection LP231 Policy ST 4 • Council development targets Kingsborough Manor where it has been established that a net area of 8.23 ha has yet to be developed. This would yield 8.23 x 14dph= 115 dwellings. • Thistle Hill & Plover Road where a net area of 24.6 hi'\ has yet to be developed. This would yield 24.6 x 50 dph=1,230 dwellings. As SBC has only allowed for 630 dwellings, a deficit of 600 needs to be included. • Queenborough & Rushenden which with the acquisition of the lnvicta Merchant Bar Rolling Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Mill provides a Brownfield site of 3.03 ha which would yield 3.03 x 41dph =125 dwellings.

This indicates that an additional 840 houses has not been included by SBC for development on the Isle of Sheppey. Not only does this undermines Swale's proposal to develop the Barton Hill Site but it raises serious questions about the methodology Swale is using to determine housing need on the Isle of Sheppey in general. We act for G H Dean & Co Limited, the owner of various and substantial tracts of land in the Sittingbourne area. Objection is made to the inadequate housing target for the Borough set in Policy ST2. Consistent with that objection, the company now objects to the way in which the proposed housing target is to be met as set out in Policy ST4 in three ways: in relation to the principle of windfalls; the scale of the windfall allowance; and in the omission of sites to assist in achieving the proposed higher target of 740 dpa. With regard to windfalls, whilst it is acknowledged that the NPPF advice allows of a windfall allowance, in the context of NPPF advice to boost significantly housing supply, together with the Thames Gateway Growth Area concept, any contribution by windfall development should, in our view, be accepted as a bonus contributing a boost to supply. Instead, the Council maintains its antipathy to the growth concept and "builds-in" a significant windfall allowance as a fundamental early building block of its supply equation. In our view, the Council should delete the reliance on windfalls and add a footnote to the table to the effect that "we may be able to boost supply by a further x % if windfall sites continue to come Meeting the Local Plan forward at past rates". In our view there are no exceptional circumstances in Swale that warrant G H Dean G H Dean & Co Objection LP356 Policy ST 4 development targets the inclusion of a windfall allowance. The same arguments are advanced by the Council to try and justify lower housing targets (paras 4.4.11 - 4.4.25) but the case for a windfall allowance fails in the same way as the case for a lower housing target. With regard to the size of the windfall allowance contained in Table 4.4.5; at some 13% of total provision we consider this to be too high. The SHLAA process has scoured the urban areas for potential housing sites and with a substantial number of employment or former employment sites within the urban area now included, the likelihood of additional (larger) windfall sites coming forward is significantly diminished. Notwithstanding and without prejudice to the argument set out above that (any) windfall allowance should be dispensed with and notwithstanding previous windfall rates, at 13% of total provision the allowance is, in our view, too high. It is not clear whether the historic contribution from residential garden land has been discounted and at 1449 dwellings the windfall allowance exceeds the largest strategic allocation for housing. At best, the arithmetic allowance should be, say, 5% of total provision. If, in practice, actual delivery turns out to be higher than the assumed contribution then this should be viewed as a bonus to housing supply. We act for E J Mackelden & Sons (Bobbing) Ltd the owner of various tracts of land on the west side of Sittingbourne. Objection is made to the inadequate housing target for the Borough set in Policy ST2. Consistent with that objection, the company now objects to the way in which the proposed housing target is to be met as set out in Policy ST4 in three ways:

1. in relation to the principle of windfalls; 2. the scale of the windfall allowance; and 3. in the omission of sites to assist in achieving the proposed higher target of 740 dpa.

Meeting the Local Plan E J Mackelden & Sons Ltd Objection LP369 Policy ST 4 With regard to windfalls, whilst it is acknowledged that the NPPF advice allows of a windfall development targets allowance, in the context of NPPF advice to boost significantly housing supply, together with the Thames Gateway Growth Area concept, any contribution by windfall development should, in our view, be accepted as a bonus contributing a boost to supply. Instead, the Council maintains its antipathy to the growth concept and "builds-in" a significant windfall allowance as a fundamental early building block of its supply equation. In our view, the Council should delete the reliance on windfalls and add a footnote to the table to the effect that "we may be able to boost supply by a further x % if windfall sites continue to come forward at past rates". In our view there are no exceptional circumstances in Swale that warrant the inclusion of a windfall allowance. The same arguments are advanced by the Council to try and justify lower housing targets (paras 4.4.11 - 4.4.25) but the case for a windfall allowance fails in the same way as the case for a lower housing Object / Document Name Organisation Support Rep ID Title Consultee Response Part

target. With regard to the size of the windfall allowance contained in Table 4.4.5; at some 13% of total provision we consider this to be too high. The SHLAA process has scoured the urban areas for potential housing sites and with a substantial number of employment or former employment sites within the urban area now included, the likelihood of additional (larger) windfall sites coming forward is therefore significantly diminished. Notwithstanding and without prejudice to the argument set out above that (any) windfall allowance should be dispensed with and notwithstanding previous windfall rates, at 13% of total provision the allowance is, in our view, too high. It is not clear whether the historic contribution from residential garden land has been discounted and at 1449 dwellings the windfall allowance exceeds the largest strategic allocation for housing. At best, the arithmetical allowance should be, say, 5% of total provision. If, in practice, the actual contribution is higher than the assumed contribution then this should be viewed as a bonus to housing supply. From what I have read " bearing fruits " should be " beware of Greeks bearing gifts " ! I am extremely alarmed at Swale's cavalier attitude to the hard working and top rate ( E ) Band Council tax payers. It is difficult to start analysing the Council's thinking with regard the destruction of greenbelt land, complete chaos of road infrastructure , etc etc Probably Beruit has a much better Meeting the Local Plan Mr M Emmett Objection LP99 Policy ST 4 town centre than Sittingbourne. I was standing last week looking down Fremlin Walk , Maidstone development targets then up and down Week Street and thought I was on a parallel planet as I certainly didn't see any resemblance to Sittingbourne Earth. When will this Council come into the 21st century and wake up to the fact that Sittingbourne is like some third world back street market town needing massive development BEFORE further housing growth is considered At its meeting held in September, Members agreed that the Parish Council lodges a response opposing any housing development on land in Ruins Barn Road adjacent to the site put forward as Meeting the Local Plan Mrs Lynda Fisher Tunstall Parish Council Objection LP215 Policy ST 4 part of a KCC strategy for a possible new School in Tunstall Road. Councillors also expressed development targets concern about the amount of housing that is being proposed in the Plan without supportive infrastructure. The plan as it currently stands will not enhance existing communities in any way. It will only cause further social problems and put additional strain on an existing socially deprived area. Halfway Chairman Halfway Houses Residents Meeting the Local Plan Mr Paul Hayes Objection LP802 Policy ST 4 Houses residents state that they will not stand by and see their community destroyed any further, Association development targets just to meet, dubious housing targets for a population explosion that is not of their or any other Island community responsibility. The figures for housing being pushed onto Swale Borough Council, and our communities, seem arbitrary and draw our eyes away from some more fundamental truths about the needs of our communities. These target-led initiatives may cause us to take our eye off the needs of a deeply dysfunctional local economy in which poverty is commonplace and opportunities are few. Our comments are restricted to the principles governing the distribution of investment targets. The “Bearing Fruits” document does appear on the face of it to be coherent in the delivery of social and economic investments around core areas of need. And yet, we also see continued proposals for disproportionate and misdirected developments in rural and semi-rural environments. We believe it important that Swale Borough Council should keep their eye on the ball and stop being ‘seduced’ by disjointed and non-strategic proposals promoted by landowners and developers (who like greenfield sites rather than brown-field ones) and who have no responsibility for promoting the long-term Meeting the Local Plan health of our communities. Viewed from the margins of a semi-rural communities (Bapchild and Nigel Heriz-Smith Objection LP763 Policy ST 4 development targets Teynham ‘villages’) and truly rural communities (all points south of the A2), it is astonishing that anyone might be arguing for economic development outside the key urban centres of Sittingbourne, Faversham and (even more pressing) Sheerness. The plight of many in rural districts who have become progressively isolated from key social and economic resources is NOT going to be helped by increased population pressures in these communities without improved access to the necessary social and physical infrastructure. A piecemeal approach will never deliver the needs for regeneration of our local economy. The inexorable logic of a regional focus on economic development is to marry the stimulation of investment in physical infrastructure to the areas where social and economic resources can most readily be ‘flexed’ to support those social and economic changes. When public resources are as scarce as they are now and into the near future, public planning authorities should focus on evolutionary stimulation of population increase, improvement in housing stock and commercial investment where relatively minor changes are needed to match up Object / Document Name Organisation Support Rep ID Title Consultee Response Part

to the corresponding delivery of complex social and economic infrastructures necessary to support residents and businesses. At the same time, there is something obscene in principle about building on top-grade agricultural land rather than brown-field sites and areas adjacent to urban centres. We need food production to be sustained (or increased) to support our existing population, let alone any increase population and commercial activity. The same logic applies to photovoltaic “energy farms” – Swale Borough Council should only entertain applications near to urban centres or energy-hungry industries where less energy will be lost in transmission. It is already the case that energy production that is currently sited far from centres of population loses something like 40% of all energy produced through resistance in long transmission lines! So, placing “photovoltaic farms” in places like Queen Down Warren (Rainham/Hartlip) does not make sense because so much of this day-time power will be lost in the transmission. The current reality in our rural and semi-rural communities is that industrial and commercial properties are left derelict/boarded up or taken out of economic production or social use in favour of housing. So let’s not get deflected by the fatuous buzz-words of ‘balanced development’ when applied to a marriage of housing and commercial properties in entirely the wrong places. There isn’t a comparable demand for commercial premises outside the urban centres, so any justification for housing that is based on a palliative ‘ambition’ for commercial investment is, at best, unproven. At worst, it is just a prettily wrapped lie. The language of ‘balance’ is a fallacy outside the major centres of population and supporting infrastructures. In Teynham and Lynsted, applications have been made to take land and buildings out of commercial/industrial stock in favour of housing (recently the Bitufil site in Lynsted Lane) and the long-abandoned commercial site at Norton Crossroads. Other commercial properties along London Road in Teynham/Lynsted have remained derelict. So, the material evidence shows there is no real demand for building business/commercial investment in rural and semi-rural communities. Certainly, these elements of any planning application for ‘balanced’ development should be discounted. That position is not so surprising when the essential social and physical infrastructures are mostly concentrated in urban centres – that is where critical mass for these elements (e.g. dentists, GPs, social services, schools) is more readily achieved and investments more properly argued and delivered. So, Swale Borough Council’s contribution to regional regeneration should be based on a more ‘strategic’ perspective. SBC should step back from ‘white elephant’ developments like the Northern/Southern relief road (with the blight on all communities along the A2). SBC should also have the humility to accept the judgement of the wider economic considerations that led to the withdrawal of (e.g.) supermarkets from the dreams north of the Sittingbourne Station. SBC should stop meaningless tinkering with proposals for increased pedestrianisation of Sittingbourne centre that will reduce access to the resources of Sittingbourne, including medical facilities such as physiotherapists who will have vehicular access denied to their less mobile patients.. SBC should take a strongly focused lead in trying to regenerate the local economy around the hub of urban centres rather than the mosaic of disjointed initiatives that will not serve the interests of those living in the Borough. I wish to lodge my concerns of the over development on this island. I am a resident who lives and works on the island. There is nowhere near enough employment in this area to support extra housing and if the new owners are to work off the island I would like to point out the roads i.e. the Lower Road Minster. I work in Queenborough and live in Minster a journey which should take no more than 10 minutes. At prime times it takes half an hour! The main road in Minster is used like a race track. I remained on this island all my life despite the dreadful state of the town because there Meeting the Local Plan Marilyn Holmes Objection LP729 Policy ST 4 are not many places that you can travel to work passing fields but this appears to be all changing. development targets What happened to the not building on green sites? One rule for one and one for this island? The hospital is not geared to cater for us now in emergencies so what is the intention in the future? None I guess. There is far too much traffic on the roads around here now, the surfaces are really bad especially Barton Hill so will we be driving on a dirt track once all the tipper lorries go thundering past yet again???? Where is the police when they are racing up and down the roads??? There just is not the infrastructure on this island to keep on building. Meeting the Local Plan In summary Bapchild Parish Council does Mr A Hudson Chairman Bapchild Parish Council Objection LP1363 Policy ST 4 development targets Object / Document Name Organisation Support Rep ID Title Consultee Response Part

• not support the inclusion of any further employment land provision.

Like many people living on the Isle of Sheppey, I am deeply concerned that the proposals for more houses on the Island will simply turn Sheppey into even more of a "dormitory" than it is now. No more houses, please, unless the jobs and the infrastructure to support them are ALREADY in place . It is Island residents who have to live with the mistakes the planners/consultants have already made. They don't live here. We do. No more planning decisions based on nothing more than wishful thinking about jobs. Let's not have a repetition of the Thistle Hill fiasco, in which planning permission for these several thousand houses was predicated on the creation of some 2,500 new jobs at the Port of Sheerness. The jobs failed to materialise, yet the houses were built anyway. The result of this folly can be seen every morning and evening as hundreds of vehicles cause traffic queues up to a mile long from Cowstead Corner to Thistle Hill and beyond (to Kingsborough Manor) because the A2500 (re-classifying Lower Road as an "A" road is regarded locally as nothing more than a joke) is totally unsuitable for the amount of traffic it now has to take. I suggest the planners/consultants responsible for this disaster come out an have a look at it one evening around 5.30pm -6pm. The only infrastructure "improvement" was the new Sheppey Crossing, which simply allows people work off the Island to join the evening traffic queue at Cowstead Corner even more rapidly. The development at Thistle Hill has done little or nothing for the local economy as most of the residents - if they have a job at all -commute off the Island to Meeting the Local Plan work. The Bearing Fruits draft is somewhat economical with the truth concerning the history of Mr David Jones Objection LP335 Policy ST 4 development targets Thistle Hill, stating only that "this housing was to have been supported by new jobs, but only in recent times has land put aside for employment over 20 years ago at Neats Court begun to come forward." Indeed, Thistle Hill was to have been supported by new jobs, but planning permission was granted ONLY on the basis of the development going ahead once these jobs had been created. I invite the planners to take a walk around Thistle Hill. Even on a Saturday morning, it is a sprawling, soul-less desolate place, with no sense of community. Where are all these people going to work if Sheppey gets even more houses, at Barton Hill Drive/Queenborough/Rushenden etc? Excluding Thanet and Medway (a unitary authority with a population twice that of Swale Borough), Swale already has the highest unemployment rate in Kent (June, 2013) and this situation is unlikely to improve in the foreseeable future, given that the borough contains some wards, including some on Sheppey, which are among the most deprived in the South East. So, the Government wants "joined up" thinking on houses and jobs. We haven't seen any of that on the Isle of Sheppey, thanks to Swale's planners, none of whom, I suspect, live on Sheppey.. Thistle Hill, as mentioned about, being a prime example. Forget about weasel words like job targets, job creation etc. Let's have the jobs before the houses. - or we shall have a repeat of Thistle Hill. Worryingly, the new draftconsultation once again puts forward what is little more than speculation for employment growth on Sheppey. It's all smoke and mirrors to create the illusion ofpossiblejob creation, in order to justify more houses. We are rather surprised that the Council has rolled forward sites and we request that they reconsidered their appropriateness. We take the view that housing allocations and employment land should be fairly distributed across the 3 main urban centres of Swale; it appears that Sittingbourne and Sheppey have been excessively burdened with future development; this causes an issue for rural villages like us who then have to suffer the pressure of urban creep into the rural environment for example the construction of Eden Park development has eroded the gap between us and Sittingbourne and puts our local services/infrastructure under severe strain. Clearly there is a need for new housing and commercial development in Faversham that is not addressed in this draft Meeting the Local Plan Mrs L Jordan Rodmersham Parish Council Objection LP1103 Policy ST 4 strategy. It should be noted that the Eden Park housing development and Iwade developments development targets have resulted in our village school becoming severely overcrowded; its buildings are designed for max. 74 children but we now have 99 children crammed into its Victorian building and temporary out buildings. There was no provision in the Eden Park scheme for additional primary school places. Swale and Kent County Councils lack of planning for education places as a result of additional house building over the last 10-15 years has been poor and we as a parish have had to deal with the negative consequences; a school that is majorly overly subscribed, the consequential traffic and parking problems that arise from the overcrowding including the erosion of our village green from the additional traffic. The final local plan should spread the burden of development evenly around Object / Document Name Organisation Support Rep ID Title Consultee Response Part

the borough and be sited with the corresponding health and education infrastructure which has been lacking in previous local plans. I cannot believe you are still planning hundreds more houses off Scocles and Thistle Hill. Have you any brains at all? The impact on the Island is already terrible. The traffic on unsuitable roads is dreadful. A new school will probably take 2 years. I already have to wait 2 weeks for a doctor's appointment, an appointment made today for 7th October. The hospital often only has 1 person for taking blood tests with a long queue waiting. The list goes on. Who are the new homes meant for? I can't believe the local people on housing lists get them. I believe they are probably meant for Meeting the Local Plan London overspill who will probably never work as we have no jobs and therefore will not pay rent or Mrs June Kimber Objection LP711 Policy ST 4 development targets Council Tax, lucky them. As for putting gypsy camps in the middle of a housing estate, why, who would want to live near one? The Greyhound Road one has already grown rapidly but at least it's out of the way so they can live with their own mess. Most people bought property on the Island to see a bit of countryside which is rapidly disappearing. Where to now? I'm lucky I still get hedgehogs in my garden as I allow for them but with acres of concrete they cannot survive and building on fox's habitat they will soon be deemed another nuisance. What a terrible state for this Island to be in. I have only been here 40 years but hate the way it is becoming. See our comments in Part 1 of our response in regard to development levels. We have additional comments on this Policy as follows: Windfall Allowance: CPRE Protect Kent welcome and support the inclusion of a windfall allowance as a source contributing to future land supply. We agree with the Strategic Housing Land Availability Assessment (SHLAA) that past completions provide compelling evidence that such sites have consistently become available and therefore making an allowance complies with the National Planning Policy Framework (NPPF). However, based on this past performance, we consider that the allowance made in the draft Plan is an underestimate, and we believe that the SHLAA takes an overly cautious approach. From information supplied to us by the Borough Council we accept, as explained in the SHLAA, that as at 2011/12 the 20 year average for windfall completions is 145 dwellings per annum (dpa), i.e. a total of 2,900 dwellings. However, we would suggest that it would be more appropriate to take the average over a ten year period as this would better reflect what has happened in more recent years. In particular it would give more recognition to the impact of the economic recession since 2007/08 and reflect more recent changes in planning policy. However, despite the recession, the figures for the period 2002/03 to 2011/12 show that there has been an increase in windfall completions with the average rising to 160 dpa, i.e. 1,600 dwellings over the ten year period. We consider that this would be a more appropriate starting point for calculating the allowance to be included in the Plan. We note that the SHLAA then applies a discount of 35 dpa on the basis that national policy now excludes residential gardens. We assume that this is a reference to such sites now being defined as greenfield rather than brownfield. Meeting the Local Plan Mr Brian Lloyd Senior Planner Protect KENT Objection LP879 Policy ST 4 However, whilst we note the comment, the definition of windfall sites in the NPPF states that they development targets are normally previously-developed sites, though by implication not entirely. This would also seem to be the view of the Borough Council, because in Policy CP3 of the draft Plan point 1b states "windfall sites, including on previously developed land..." . Consequently we are not convinced that a discount for garden land should be made on this basis. However, we would accept that with the removal of the 30 dwelling per hectare density target from national policy in future there are likely to be fewer dwellings arising from garden land sites. On this basis we accept that it would be appropriate to make a discount . We do not accept, though, that this figure ( i.e. 35 dpa) in its entirety should be deducted from the total figure as presented in the SHLAA and would suggest that a discount of 60% would be reasonable. This would discount the ten-year windfall average to 139 dpa. The SHLAA then goes on to examine the issue of double counting in the short-term and to remove sites with planning permission and those identified in the SHLAA. This results in no allowance being made in the first five years of the Plan period and a reduced allowance being made for years 6 and 7. We consider that this is an over discount, as windfalls from currently unidentified sites will continue to come forward in the short-term as they will in the longer term. It is also the case that any site identified in the SHLAA, but not allocated in the Plan, will be a windfall if it comes forward by way of a planning application. The fact that a site is identified in the SHLAA does not make it an identified site in planning policy terms. Therefore we consider that whist some discounting is needed during the first five years an allowance none the less should be made. We would suggest a 50% discount for the first five years and a 25% discount for years 6 and 7. We do Object / Document Name Organisation Support Rep ID Title Consultee Response Part

not believe there is a need for any discount for the rest of the Plan period. Therefore, we consider that the windfall allowance should be as follows: Years 1 to 5: 69 dpa = 345 dwellings Years 6 & 7: 104 dpa = 208 dwellings Years 8 to 20: 139 dpa = 1,807 dwellings This gives a total windfall allowance of 2,360 dwellings for the 20 year period 2011/12 to 2030/31. This compares to 2,900 achieved for the 20 years prior to 2011/12 and 3,200 for a 20 year period implied by the rate achieved over the ten years prior to 2011/12. It is clearly a more realistic (and comparable) figure based on past trends than the 1,449 allowance currently made in Policy ST4, and underlines the extremely cautious approach taken in the SHLAA. It is clearly unreasonable to suggest that the windfall rate for the next twenty years will be just half of that achieved for the previous twenty years, even allowing for discounting in the short-term. Therefore, the windfall allowance made in Policy ST4 should be increased accordingly as we suggest. Allocations: As a result of the increase in the windfall allowance we advocate above and the analysis of deliverability we present in Part 1 of our response, the allocations needed to meet our suggested target (see Part 1 of our response) and even the Council's favoured housing target can be reduced. Such reduction would be in the order of 800 to 900 dwellings. As a result, it is our view that the following sites should be deleted from the Plan: North East Sittingbourne (Policy A2 - 120 dwellings);

• Frognal Lane, Teynham (Policy A4 - 300 dwellings); • Barton Hill Drive, Minster (Policy A5 - 500 dwellings); • those at Cryalls Lane and north of Key Street in Sittingbourne , and at Belgrave Road, Minster (Policy A9 - 250 dwellings in total).

Even though in total the dwellings from these sites amounts to more than the increase in the windfall allowance, we believe that all these proposed allocations can be deleted from the Plan because:

• an over provision is already included in Policy ST4 (provision is made for 11,065 dwellings against a target of 10,800 dwellings); and • a lower target should be employed as we suggest in Part 1 of our response; and • an increase in capacity can be secured at Queenborough and Rushenden and housing development should be included as part of a mixed-use development at Milton Creek.

We expand on this last point, and on our concerns with the sites that should be deleted, elsewhere in our response to the draft Plan. The identification of Teynham as a centre which will be a main focus of rural scales of growth and as a suitable place for delivering a large number of houses is supported. However,the reduction in housing numbers in the current Local Plan consultation (from 433 to 338) in Teynham is not supported. The Council's lack of a five year housing supply means that additional sites should be allocated within towns and sustainable Rural Local Service Centres in order to deliver sufficient Meeting the Local Plan Owner of land at Cellar Hill, Teynham Objection LP94 Policy ST 4 housing to meet the objectively identified need, in accordance with the National Planning Policy development targets Framework (NPPF). Currently the Council are not identifying a sufficient number of sites to deliver the housing necessary to meet the identified need. This is contrary to the NPPF and will not deliver a robust and sustainable housing supply. Teynham should therefore be identified to deliver a higher number of houses to that set out within the Local Plan, since it is a highly sustainable settlement, with good public transport links,shops and services. We strongly disagree with policy ST4. As discussed in our comments on policy ST2 the proposed housing numbers represent a significant shortfall in the actual need for the borough. As such the broad allocations set out in policy ST4 are insufficient to meet the borough’s objectively assessed need. The figures need to be increased to levels that will deliver the identified need and support the c/o Tetlow King Planning Kent Meeting the Local Plan Objection LP1315 Policy ST 4 borough’s economic strategy. As such we recommend the ‘number of new dwellings’ be increased Developments UK Ltd development targets to at least 15,000 dwellings (750dpa). Furthermore, Minster has the capacity to accommodate much higher levels of housing growth. We propose the inclusion of the land shown on plan no. at Woottons Farm as an allocation for the Minster/Halfway area as this presents an opportunity for a considerable boost to the housing stock. The site is capable of delivering around 1200 homes as Object / Document Name Organisation Support Rep ID Title Consultee Response Part

well as a range of wider community benefits including land for a new secondary school and community woodland. The site is available, has no physical or policy constraints meaning development can start quickly. The distribution of development at Faversham, whereby 538 new dwellings are proposed, does not correspond with the high amount of employment proposed. The Policy allocates 41,000 square metres of ‘B' Class employment floorspace, the third largest amount in the District. Whilst we agree with the approach to allocating employment in this area, this also needs to be supported by sufficient levels of housing development, encouraging more sustainable forms of transport to and from the employment area. The amount of development to be delivered by new allocations should therefore be increased, in order that objectively assessed needs can be met. Turning to sources of land for the proposed levels of housing development, we notice that the Council does not specify at this stage how much windfall housing will come forward. The NPPF states that ‘local planning Planner Savills (L&P) Ltd (for St Meeting the Local Plan authorities may make an allowance for windfall sites in the five-year supply if they have compelling Mr William Lusty Objection LP1441 Policy ST 4 John's College, Cambridge) development targets evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply'. Whilst the Council's Housing Technical Paper evidences that past supply delivers an average of 145 dwellings on windfall sites, this does not evidence that this level of supply will continue. Indeed, Annex 2 of the Housing Technical Paper states that ‘it is therefore concluded that there is insufficient evidence to determine whether there is a finite or dwindling supply of windfall sites and therefore any discount or inflation of the annualised figure would not have an evidence base. As a result, no change to the annualised rate of 145 dwellings is recommended'. We do not consider that this approach accords with the NPPF. The Council does not provide evidence that windfall development will continue to provide a reliable source of supply and as such, we are of the view that the Council should not make an allowance for windfall supply. General as regardsSheppey My impression, having lived here for almost 10 years, is that the island cannot sustain an increase in population/housing. These questions need detailed answers: Meeting the Local Plan Revd. M Mascall Objection LP717 Policy ST 4 development targets For a substantial number of additional houses: • Do we have adequate water supply? • Do we have adequate drainage/sewerage? • Do we have/would we have adequate local school and medical provision? • Can our roads cope with the extra traffic and number of vehicles likely to be involved? Serious concern has already been expressed in respect of the Council's spatial housing strategy for Swale Borough in which the current imbalance between the numbers of houses allocated to Sittingbourne and Faversham needs to be urgently rectified. In terms of the Council's current Meeting the Local Plan housing proposals for providing 538 dwellings in Faversham, it is evident that there are also Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1034 Policy ST 4 development targets significant concerns over whether the preferred site allocations are deliverable, developable or achievable. At the very least, there could be significant delays in bringing the preferred sites forward for development, which in turn would impact further on the Council's current shortfall in 5 year housing land supply provision. Faversham Creek - It is noted that this no longer forms part of the Council's housing strategy (100 Meeting the Local Plan houses). It is evident that the flood plain places a serious constraint on bringing forward new Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1042 Policy ST 4 development targets housing within this area, albeit in principle it represents a suitable location for new housing development. On balance, it is evident that the proposed housing allocation for Faversham is artificially low. Meeting the Local Plan Further, that there are serious questions to be answered as to whether the proposed site allocations Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1043 Policy ST 4 development targets are developable or deliverable. Once again, it is evident that a serious rethink is urgently required as to how the Council should meet its housing requirements within the Town to 2031. The spatial distribution of new housing growth should change, with fewer dwellings proposed at Meeting the Local Plan Sittingbourne and more dwellings proposed at Faversham; A further critical review should be Mr S Milliken Milliken & Co (for Shepherd Neame) Objection LP1045 Policy ST 4 development targets undertaken of existing commitments and allocations in Sittingbourne and Faversham to determine whether the Council's proposed housing land supply is developable, deliverable and achievable. Meeting the Local Plan I am very concerned about SBC Bearing Fruits and how it will impact on Swale particularly Sheppey Mr R Palmer Objection LP1578 Policy ST 4 development targets & North West Sittingbourne and the surrounding area, services and infrastructure. I am however in Object / Document Name Organisation Support Rep ID Title Consultee Response Part

favour of small developments that meet a local need but this is not clear in bearing fruits that housing is for local people. There appears to be a totally disregard for social housing which is urgently needed in the Borough. I live in Newington and feel that Bearing Fruits will further damage Newington. In general developments in the Church Lane, School Lane, Wardell Lane & High Oaks Hill area need careful consideration owing to the impact on the roads and infrastructure in the area. The junction of the A2 & Church Lane will affect the air quality in the village particularly as some 18- 20 new builds have already been given planning permission along the High Street and these will further affect the air quality. In general Bearing Fruits is a badly thought out policy which seems to favour housing over infrastructure, local services and local needs. Further housing, some 600 I believe is due for the A249 corridor between Iwade and Key Street roundabout which will cause delays on the A249/A2 at key street and A249/M2 junctions which will further lead to High Oaks Hill/Church Lane or High Oaks Hill/School becoming a ‘rat run' for vehicles traveling to Medway Towns from Iwade / Bobbing area etc. This potential increase in traffic will add further to the poor air quality in the village. The website seemed hard to navigate and seemed aimed at putting people off from reading and responding to the consultation. The North side of the village has problems with sewage and this should be addressed before any new building in that area. Newington is surround by farm land and areas of outstanding natural beauty and this doesn't seem to be taken into consideration. Newington is a large village but has no doctor. It has the worst air quality in Kent and is subject to air quality monitoring. Any new plans for housing in or which could affect/increase traffic through Newington via or close to the High Street must take this into consideration. This means the proposed housing at Kemsley, on Sheppey and along the A249 corridor will have a direct impact on vehicle movements through Newington which will further damage the air quality further in Newington which currently has air quality levels outside Government safe levels. During the planning & building of Vicarage Court and at the 2012 NPC AGM local residents raised concerns about the lack of housing for the elderly. This is not covered in Bearings Fruits and it would appear that the intended housing is for established families not for local people or for a local need. In Swale as a whole the housing seems to be in NW Sittingbourne and on Sheppey (these area seem to be taken again an unfair burden of housing within the Borough) while the jobs which the council feel will be created are in the Faversham area. This planning madness will lead to more traffic traveling either through Sittingbourne from Sheppey & NW Sittingbourne or along the A249 increase traffic problems at the A249/M2 junction and leading to increased traffic along the A2 at Newington. It would make sense to put the housing where the jobs are (which is in line with Governments policy) in the Faversham area. It is not clear if the council has consulted with KCC about school places being available for the increased population from this proposed housing madness. Has the council consulted with the Highways Agency as there will be a major impact on the A249, A2 & M2 which need addressing and planning for. The NHS in Medway & Swale should be consulted and what arrangements for adequate health service been discussed arranged. I am concerned that the jobs the council feel will arrive in the Borough is a pipe dream and the houses will bring more problems to over congested roads in the area. Will overstretch school, hospitals, infrastructure and local services. We don’t complain just get on with our lives, but I must say to build more houses on Sheppey is not the correct thing to do. Being Swampies both of us, and our parents and grandparents, we are Meeting the Local Plan really saddened to hear more houses are going to be built on our lovely Island. Gone are the days Mr & Mrs E Ralph Objection LP723 Policy ST 4 development targets of fruit trees and buttercups and daisy fields in which we played. Please consider carefully your decisions on this matter, as the people of Sheppey will no longer have any fields left to admire. Do you live here yourself? Most of the sites identified within Swale are likely to impact on the European network. Within Sittingbourne, Sheppey and Faversham this issue is particularly relevant as these settlements are Conservation Officer, Policy and Meeting the Local Plan adjacent to the SPA and will absorb much of the proposed development. It is therefore imperative Miss Debbie Salmon Objection LP1082 Policy ST 4 Planning Kent Wildlife Trust development targets that the allocations are assessed under the HRA process as soon as possible to ensure that the quantum of development in the identified locations can be delivered. (See previous comments for further details regarding the need to undertake a HRA) Meeting the Local Plan My husband and I are most angry and upset at the plans to build more houses on our Island. Mr & Mrs B Stanton Objection LP221 Policy ST 4 development targets "Bearing Fruits" indeed. I think it will be bearing misery for us and a lot of other people! We bought Object / Document Name Organisation Support Rep ID Title Consultee Response Part

our bungalow at the above address about four years ago. We overlook lovely farm land, open our back gate onto the playing field. Handy for walking our dogs and enjoying Sheppey's lovely countyside. A quiet residential area. We chose carefully, it was not in our search that building could take place to ruin all this! No one around here wants your plans to happen. The roads etc. are not built for yet more cars. It will be a nightmare trying to get on to the main roads - already crowded. Enough owners' cars are already parked along Belgrave and Holmside Avenue. You must all be blind to think of adding more! It is already a rat run trying to get out. Do you want more accidents to take place? We have a limited hospital requirements on the Island, loads of residents having to travel miles to other hospitals for most treatments. No maternity facilities etc. Surface water and drainage facilities are far from ideal. Add more concrete, not only will it be an eye sore on our countryside but a disaster!

Please think again! We are not a dumping ground on Sheppey! I am writing to you about the Bearing Fruits Plan. I disapprove of all the houses in view to be built on green field sites. It should be on brown field sites. There is some lovely wild life on this Island. We will all sink on this island. It appears to be a dumping ground. Before we have these houses approved you should stop and think about the infrastructure, will there be new jobs, new doctors' surgeries, hospitals and schools? The roads are jammed up already. What about new drainage? The drains are so old now will still get a lot of flooding on the island the drains don't cope with the situation. Will there be more firemen and what about more police to police the island for Meeting the Local Plan the extra houses for some of the crime that goes on. The new bridge was built just to take the work Mrs Linda Tress Objection LP709 Policy ST 4 development targets force off the island because there is no employment on the island. Come another ten to twenty years' time we will need another bridge to take all the traffic. It builds up now at Stockbury and key street roundabouts, what madness. One more factor with the housing people population the Halfway Cemetery is full, where are people going to be buried when they die? We desperately need a new one on the Island; it's not everybody's taste to be cremated. There are still brown field sites on the island if you look for them. Let's keep the island free of more houses and keep it green and pleasant. Please listen to the island people, we have Councillors on the island and it seems they are voted out. I am writing to protest about Swale Council's Bearing Fruits plans. If Sheppey must have more houses, all of the brownfield sites must be used first. the population of Sheppey is already at bursting point. There are no jobs, schools are overcrowded, getting a doctor's appointment is a nightmare and the main hospitals are 20 to 40 miles away. Getting from Sheppey to the M2 and M20 in the morning rush hour involves long delays. More traffic will lead to more and more disasters, such as the Sheppey Crossing accident a few weeks ago. The proposed housing Meeting the Local Plan Mr & Mrs J Tress Objection LP710 Policy ST 4 development to the west of Bartons Hill Drive on a greenfield site will be another step on the way to development targets ruining our lovely island. The route from Queenborough Corner towards Eastchurch has always been rural and attractive to locals and visitors. do not spoil it. No more houses must be built that can be seen from the Lower Road towards Eastchurch. The Lionhope development plans some years ago were turned down for this very reason and should not be overturned now. Let the people of Sheppey decide on the housing needs of the Island. Sheppey councillors are always outvoted in these decisions; please listen to the people that live on the Island. It is confirmed that ‘growth will be directed to the most sustainable locations’ and that these will ‘either have the facilities and services that can support new growth or can themselves by supported by growth’ (para 4.1.7). It is noted that Minster is regarded as a sustainable settlement which is appropriate to accommodate further large-scale housing development over and above that which has occurred at locations such as Thistle Hill for example. Meeting the Local Plan Mr P Aelen Abacus Developments Support LP820 Policy ST 4 development targets The Council proposes to continue with this strategy through the allocation of additional large sites at Minster. The acceptance by the Council that this is a sustainable approach and it is consistent with Government guidance in the NPPF is welcomed and supported. The provision of further allocations in the urban fringe at Minster is entirely appropriate in terms of this strategy. The need to avoid environmental assets and constraints such as flood plains and areas of high agricultural land is recognised as being in line with national policy (para 4.1.8) as a matter of principle. It is accepted Object / Document Name Organisation Support Rep ID Title Consultee Response Part

however that the provision of sustainable development is a balance and that the use of agricultural land in the urban fringe may be unavoidable in the most sustainable locations. In these areas there may also be a need to mitigate the impact of development on the local surroundings. This stance is supported as a pragmatic response to the need to allocate additional land in sustainable locations. Response: The Crown Estate supports the rate of growth outlined in Policy ST4 as a minimum rate of growth to 2031. We generally support the approach set out in policy ST4. In line with the NPPF local authorities will be expected to identify and manage the release of land to maintain the momentum of housing delivery. This should be achieved through adopting a flexible approach to delivery by not treating housing figures as ceilings whilst ensuring that sites and development is focussed on sustainable locations that can deliver the Plan's Spatial Strategy, such as Minster. Much of the housing supply identified in Policy ST2 is through saved allocations from the Local Plan. These have been identified and subsequently allocated for many years and have been slow to come forward. To save placing reliance on a few large greenfield options and windfall sites, we support the Council's approach of allocating a mix of Greenfield sites, including alternative smaller options such as The Crown Estate's land at Belgrave Road Minster to allow the Council to more quickly respond to fluctuations in supply than the approach set out in preferred options Core Strategy (March 2012). Allocating additional land for development is also consistent with the call for greater flexibility in managing the delivery of housing, as stated in paragraph 47 of NPPF. This recommends that to significantly boost supply, local planning authorities should "use their evidence base to ensure that their Local Plan meet the full objectively assessed needs for market and affordable housing." The SHLAA identifies that land at Belgrave Road (Ref: SW/165) has potential to deliver 140 new homes between 2015 and 2019. The Crown Estate is willing to bring the site Meeting the Local Plan forward and also has a track record of delivering land for development on Sheppey (see our The Crown Estate Support LP1435 Policy ST 4 development targets response to Policy A9 included in chapter 6). It is considered that the approach set out in this current Local Plan consultation will more adequately meet the four tests for soundness set out in NPPF against which local plans will be assessed (Paragraph 182). This includes the tests of 'positively prepared' and 'effective'. In order for the plan to meet these tests it should provide a responsive and flexible supply of housing to maintain housing delivery in line with other parts of NPPF and enable land to be brought forward quickly. Allocating additional land for development is also consistent with the call to significantly boost housing delivery as required by paragraph 47 of the NPPF. The guidance also calls on LPAs to ensure performance is within an acceptable range (20% of the planned supply).

To make the Local Plan sound in this regard it needs to allocate deliverable strategic sites such as Belgrave Road and make it clear that sustainable development (development in the right location, responding to needs and supporting the vitality of communities) will be supported. We consider that The Crown Estate's site at Minster is well placed to assist in housing delivery; particularly should other sites not come forward early. This approach would also be consistent with the presumption in favour of sustainable development set out in the NPPF (paragraph 14). In addition, Paragraph 15 requires local planning authorities to include policies which: "follow the presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay" (emphasis added). A Gypsy and Traveller Accommodation Assessment has now been undertaken which KCC supports and there is a now a target of 85 pitches to 2031 included in the Plan these sites will be allocated in Principal Planning Officer Kent Meeting the Local Plan by a separate Part 2 Local Plan. There is also a requirement for larger housing developments (50 Miss Elizabeth Shier County Council (Planning and Support LP1143 Policy ST 4 development targets dwellings or more) to include provision within their schemes for pitches for Gypsies and Travellers Environment) or to provide a commuted sum. KCC support SBC approach to Gypsy and Traveller sites and offer continuing support in meeting needs for well-managed, socially-rented sites. Since 2008 our local council has been telling us what a wonderful new town centre we are going to have. Initially in conjunction with Spenhill (Tesco) and latterly with the consortium, Spirit of Mr David Hawkins Objection LP557 4.5.49 Paragraph Sittingbourne. Here we are 5 years later with one new supermarket and a new road system which

gridlocks at weekends and times of high demand. Spenhill have pulled out due to the intervention of the Highways Agency which leaves a massive whole in grand plan and Eurolink Way remains a blot Object / Document Name Organisation Support Rep ID Title Consultee Response Part

of the landscape and is likely to remain so until Spenhill release the land.

In addition to this the land behind the new supermarket looks like a bomb site and there is no sign of this area being developed in the immediate future. I really feel sorry for the residents of Charlotte Street having this on their doorstep.

Lastly the area in Bell Road also looks like a bomb site due to the council allowing the developers of the proposed hotel there to knock down the existing buildings and then walk away until they have renegotiated a better deal.

So here we are 5 years later and the town is in a worse state than it was before and I cannot see any room for an improvement to this situation in the foreseeable future.

This paragraph will need to be up-dated to reflect the resolution to grant planning permission for the Qualified ‘Eurolink V’ site. Elsewhere in our response we raise objections to the proposed allocation of the Mr Brian Lloyd Senior Planner Protect KENT LP882 4.5.50 Paragraph support land for development south of Kemsley Mill and at Teynham. We accept the list of existing strategic employment sites. CPRE Protect Kent consider that Sittingbourne town centre presents the best and most sustainable option for increasing office supply, and this intention should provide the focus of the paragraph. We believe that new office floorspace would ideally be accommodated within a mixed-use redevelopment of the Milton Creek site, which is very sustainably located adjacent to the railway Mr Brian Lloyd Senior Planner Protect KENT Objection LP894 4.5.52 Paragraph station. We would not support out of town office development along the A249 or at the Kent Science Park, and these suggestions should be deleted from the paragraph. The references to potential expansion of the Kent Science Park should also be deleted from the Plan as this is not proposed in the Draft Plan. The reference to the completion of the Sittingbourne Northern Relief Road and the proposed ‘Area Mr Brian Lloyd Senior Planner Protect KENT Objection LP895 4.5.55 Paragraph of Search’ should be deleted – see our comments on Policy AS1 for detail of our concerns about this proposal. CPRE Protect Kent object to the failure of the Draft Plan to grapple with Junction 5 of the M2 Motorway, which ‘Statement 1’ openly acknowledges “ lacks capacity ” and “is the single greatest transport constraint in the Borough” . All hopes of dealing with this, though, are deferred to the future and hinge primarily (if not entirely) on the provision of the Sittingbourne Southern Relief Road (SSRR) at some point in the future, even though there is no evidence to suggest that this will do anything to relieve congestion at Junction 5 in any meaningful way or indeed that it will be provided. Dealing directly with Junction 5 should be the top transport priority for the Plan, and the focus of attention and resources should be on finding a solution at Junction 5 rather than on an aspirational and unproven SSRR. The identification of an ‘Area of Future Change’ to accommodate the SSRR should be deleted . We consider that giving commitment now to the provision of this road in this fashion is contrary to the Plan-led approach that is central to the UK planning system. If the road is to be pursued during the Plan period, even if development is not envisaged during the Plan Mr Brian Lloyd Senior Planner Protect KENT Objection LP896 4.5.57 Paragraph period itself, then the Plan should put forward policies setting out the proposal in detail. This will also provide the opportunity for people to comment on it and for the claims made about it to be explored in detail at the Examination in Public. The approach advocated deprives people of this opportunity and promotes ‘back door’ planning. It predetermines that the road will be provided without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the ‘Area of Future Change’ is identified in this Plan will be used as justification for its development in principle in future plans even though for this Plan no evidence would have been tested to endorse its claimed benefits. Consequently, the Council should either remove all references in the Plan to the ‘Area of Future Change’ for the SSRR or present a specific policy that clearly sets out the Council’s intentions for the area together with the necessary supporting evidence. See also our response to Policies AFC2 and 3. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Mr Brian Lloyd Senior Planner Protect KENT Objection LP897 4.5.58 Paragraph This paragraph will need to be up-dated in accordance with our comments on Policy ST4. This paragraph will need to be up-dated in accordance with our comments on Policy ST4 and our Mr Brian Lloyd Senior Planner Protect KENT Objection LP898 4.5.60 Paragraph objection to further housing development in north east Sittingbourne. This paragraph will need to be up-dated in accordance with our comments on Policy ST4 and our Mr Brian Lloyd Senior Planner Protect KENT Objection LP899 4.5.61 Paragraph objection to housing development at the Cryalls Lane and north of Key Street sites in south west Sittingbourne. This paragraph will need to be up-dated in accordance with our comments on Policy ST4 and our Mr Brian Lloyd Senior Planner Protect KENT Objection LP900 4.5.62 Paragraph objection to development at Frognal Lane, Teynham. Mr Brian Lloyd Senior Planner Protect KENT Objection LP901 4.5.64 Paragraph This paragraph will need to be up-dated in accordance with our comments on Policy ST4. Principal Planning Officer Kent Miss Elizabeth Shier County Council (Planning and Objection LP1202 4.5.67 Paragraph Object to para. Environment) CPRE Protect Kent strongly endorse this paragraph, but we are disappointed that Policy E7 of the currently adopted Local Plan is not to be retained. We consider that the comments made about Qualified safeguarding separation contained in draft policies ST1, 5, 6 and 7 do not provide a robust Mr Brian Lloyd Senior Planner Protect KENT LP902 4.5.68 Paragraph support alternative to Policy E7 which specifically defines the gaps to be protected on the Policies Map. Policy E7, therefore, should be retained in the Plan and sensitive countryside gaps should continue to be identified on the Policies Map. The Councils " Sittingbourne area strategy" should provide for an appropriate mix of housing to Qualified Mr Howard Courtley Director Courtley Consultants Ltd LP376 Policy ST 5 The Sittingbourne area strategy meet the housing needs of the town and maximise the use of allocated sites so the housing yield support makes efficient use of land to help meet those needs. eg Land at Manor Farm, Sittingbourne. Trenport generally supports the strategy for the Sittingbourne area. However, paragraph 4.5.50 could be amended to recognise that Eurolink V has a resolution to grant planning permission for Qualified 43,000 sqm. Trenport welcomes the recognition that, in addition to Eurolink V, these is scope for Chris Hall Trenport Investments Ltd LP788 Policy ST 5 The Sittingbourne area strategy support 120 new homes to the east of East Hall Farm once the alignment of the Sittingbourne Northern Relief Road is fixed and for 338 dwellings at Teynham where sites well related to the village and close to a range of services and public transport choices have been chosen. CPRE Protect Kent generally support the strategy for the Sittingbourne area as presented in this Policy. However, we would wish to see the following amendments made: · In point 1, change “at Existing…” to “within Existing…” . This would be consistent with the wording used in Policy ST6. · Qualified Mr Brian Lloyd Senior Planner Protect KENT LP903 Policy ST 5 The Sittingbourne area strategy In point 1, delete the second sentence. · In point 3 delete all after “west Sittingbourne” . · In point 4 support delete the references to north east, south west and Teynham. Amend point 8 to read as follows: “Improve the condition and quality of landscapes in the area and maintain separation between Sittingbourne and nearby settlements by the definition of sensitive countryside gaps.” The Sittingbourne area strategy seeks to achieve a strong, competitive economy, necessitating improving the availability of employment land at the town. Eurolink is identified as an 'Existing Strategic Employment Site' and with a further 43,000 sqm allocated as a extension to it to the north east of the town. In addition, 8,000 sqm is identified on land to the south of Kemsley Mill, whilst at Teynham, some 26,840 sqm of rural employment is allocated as part of a mixed use extension to the village. Other 'Existing Strategic Employment Sites' are identified at Ridham and Kemsley, Kent Science Park and Sittingbourne town centre. Mr Kevin Bown Asset Manager Highways Agency Objection LP1367 Policy ST 5 The Sittingbourne area strategy The policy suggests that these developments do not rely on the delivery of the Southern Sittingbourne relief Road or a new M2 J5A. However, the HA has not seen any evidence to substantiate this claim, nor evidence demonstrating that this claim has taken into account any committed or planned development beyond Swale borough boundaries. Therefore the HA will require the preparation and submission of such evidence before the plan progresses to submission for examination if it is to be able to support the plan’s policies and ambitions. Mr Richard Calvert Sittingbourne Society Objection LP813 Policy ST 5 The Sittingbourne area strategy The Sittingbourne Society objects to the numbers of houses proposed in the document on the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

grounds that too little infrastructure is proposed.In particular, there are no proposals for the completion of the Northern Relief Road through to the A2. The Society does not agree with the implicit assumption that proposals for a completed Northern Relief Road can be delayed until the adoption of a Southern Relief Road. It was a huge disappointment when Tesco withdrew their plans for the Town Centre redevelopment, Mrs M L Edwards Objection LP1536 Policy ST 5 The Sittingbourne area strategy a return of smaller retail units in the town would be welcome. There is no proper retail/town long term development plan since Tesco pulled out. Mrs Lynda Fisher Bobbing Parish Council Objection LP102 Policy ST 5 The Sittingbourne area strategy

Stop the piecemeal development along the Old Sheppey Way before Bobbing and lwade become a Mrs Lynda Fisher Bobbing Parish Council Objection LP105 Policy ST 5 The Sittingbourne area strategy continuous area of ribbon development. Within Policy ST5 (The Sittingbourne area strategy) incorporate policy wording that emphasises the URS SA Recommendations Objection LP1610 Policy ST 5 The Sittingbourne area strategy importance of new development addressing the risks of flooding. I personally think the councils attention would be off better else where by maybe sorting out the Natasha Mannering Objection LP768 Policy ST 5 The Sittingbourne area strategy redevelopment of the town centre this subject has been in discussion since I was a Saturday girl

some 22 years ago!!! and yes I do work in the town centre in the same shop !!!!!!! Town Centre Redevelopment We need shops and facilities brought in that employ local people, pay Mrs K Murphy Objection LP738 Policy ST 5 The Sittingbourne area strategy full UK taxes and bring in money that stays in this area. We need a Local Plan that helps local

people, not just big business and wealthy landowners. Point 2a should mention the north-south routes that we are pushing for from SCF and have been drawn up in the Swale Cycling strategy. Adrian Oliver Swale Cycle Forum Objection LP1114 Policy ST 5 The Sittingbourne area strategy Point 6 should mention particular improvement to the Cycle network. Kent Wildlife Trust understands that as the main centre, development is likely to be focused within Sittingbourne. We welcome the ambitious plans to enhance and extend Church Marshes Country Park, provide alternative natural open space within development and green up the urban area. However, as noted in previous responses we have serious concerns regarding both the location of the majority of the development to the North West and East of Sittingbourne and the proposal to open up Milton Creek to public access.

In the case of North West and East Sittingbourne the development proposed brings the built development significantly closer to the SPA, Ramsar and SSSI designations and, as acknowledged within the consultation document is very likely to increase recreational pressure on Natura 2000 and Ramsar network. We welcome the changes to the policy since the last iteration of the Local Plan. The clause Manage recreational pressures arising from development proposals to safeguard international biodiversity sites and achieve net gains in biodiversity and natural/semi-natural Conservation Officer, Policy and greenspace at development sites, especially within allocations to the north west and east of the Miss Debbie Salmon Objection LP1083 Policy ST 5 The Sittingbourne area strategy Planning Kent Wildlife Trust town; shows that thought has now been given to the recreational pressures and some safeguards are in place to increase the semi natural open space within the area.

It is important to note that that all development within Sittingbourne is likely to have recreational impact on the designated sites due to Sittingbourne's location. The above clause should not only relate to developments nearest to the SPA and Ramsar but significant areas of natural open space should be required in all Sittingbourne developments, with provision being made either on site or as a contribution to the ambitious plans for extension of Church Marshes Country Park and other identified projects.

Swale Borough Council has been an important member of the North Kent Environment Planning Group and I know that officers are aware that alternative natural open space is likely to comprise only part of the mitigation for impacts on the Natura 2000 network. A Sustainable Access Management and Monitoring Strategy, is being prepared, which will provide on-site measures to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

control visitor impact. Within the final Policy it will be important to ensure that all development impacting on the SPA/Ramsar designations contribute to the funding of this package. An additional clause requiring contributions should be inserted within Policy ST4.

The location and quantum of development proposed within Sittingbourne will need to be assessed as part of the HRA process to ensure that the SPA can accommodate the increases in pressure likely to ensue from the development.

In relation to Milton Creek Local Wildlife Site, we have historically expressed serious concerns regarding plans to open the creek to the public and provide development within this area. Although we understand the need to ensure the adjacent industrial estate has a functional use, Milton Creek provides supporting habitat for a number of SPA species of bird. Of particular note is an important redshank roost that could suffer disturbance from increases in visitor pressure. We would at the very least expect a clause to be inserted into Policy ST4 to ensure the biodiversity value of the LWS is not compromised by development or recreational impact with details as to how this protection is to be achieved within the supporting text. We hope we can discuss the safeguarding of the LWS with Swale Borough Council before submission. (See comments on site specific policies for ecological issues on individual sites.) As a footnote, have we ever considered either reducing car parking fees, or totally eliminating them, as a positive step to the re-generation of the Town Centre. All the time Sittingbourne people can Mr & Mrs Dennis & Objection LP532 Policy ST 5 The Sittingbourne area strategy shop outside of Sittingbourne with no parking costs or worries, why should they bother to pay the Doreen Taylor ridiculous parking fees of Sittingbourne, where the worthwhile shops are closing at such an alarming rate ? Like most residents of Sittingbourne I am disappointed with the very slow progress in regenerating the town centre. We get more and more housing and fewer and fewer facilities. We are all so used Mrs M E Trott Objection LP1591 Policy ST 5 The Sittingbourne area strategy to going elsewhere to do our shopping, except supermarket shops, that it would take some dramatic improvements to entice us back to shop locally. We are writing to you after finding out about the proposed planning for building up to 80 houses on the countryside opposite our house (Cryalls Lane). There really cannot be a good reason to further take land away for the development of buildings. How long before the 'town' ends up with a barren High Street, Industrial Units, Assisted Housing and land proposed for a fantastic new development which still remains empty. Having been a 'victim' of the decision to TAKE Sittingbourne Industrial Mr & Mrs P Wood Objection LP1538 Policy ST 5 The Sittingbourne area strategy Estate for the benefit of TESCO, I fear that I will now be a victim of yet another plan - perhaps you could build the Housing on Sittingbourne Industrial Estate? After all, it is centrally located and ready immediately. The 'town' that I grew up in has changed so much - and not for the better. The real industry has disappeared and we now have so few shops in the High Street - other than Charity Shops and the European Supermarkets that serve the Morrison workers. Sub policy 7) refers to managing recreational pressure, linking in to Policy ST1, together with David Hammond Natural England Support LP1564 Policy ST 5 The Sittingbourne area strategy safeguarding international biodiversity sites, whilst also achieving net gains in biodiversity and natural green-space at development sites. This is welcomed and to be supported. Sittingbourne continues to be the main focus for development and concentration of public services and facilities, and Policy ST5 sets out how this will be achieved. The document identifies strategic Principal Planning Officer Kent sites for mixed use development in Sittingbourne, located to the north west and north east of the Miss Elizabeth Shier County Council (Planning and Support LP1139 Policy ST 5 The Sittingbourne area strategy town and at Teynham. An ‘area of search’ has now been identified for the Bapchild sections of the Environment) Sittingbourne Northern Relief Road (SNRR) (Policy AS1), alongside a number of 'Areas of Future Change’. Unlike the SSRR the SNRR is likely to be deliverable within the plan period, and the route of the road will be sought and allocated either by Part 3 of the Local Plan or via its own SPD. Regarding 4.5.73 (p.81) which reads: "The remainder of Neatscourt land will be required to meet Parish Clerk Minster-on-Sea Parish the need for industrial floor space on the Isle of Sheppey" prompts MPC to ask how many times this Mrs Trish Codrington Objection LP226 4.5.73 Paragraph Council land which was initially allocated for Thistle Hill and then to support the development of the Queenborough / Rushenden site can be "re-used" at the taxpayer's expense? Object / Document Name Organisation Support Rep ID Title Consultee Response Part

You state that: ‘Building a strong, competitive economy for Sheppey is especially important for the Island. Despite investment in new road infrastructure, its economy is the poorest performing with the highest levels of unemployment, poor levels of skills within an economy that has borne the brunt of the economic recession in Swale' yet you wish to add a further 2500 homes. You ‘mitigate' this by stating you wish to take advantage of the investment in road infrastructure which sounds very grand, but that infrastructure is essentially access to the island not ON THE ISLAND (with the exception of course to the Rushenden by-pass). Incidentally, these investments have provided Mr Paul Hutchinson Objection LP149 4.5.73 Paragraph much needed relief to the significant amount of haulage on and off the island which is now at capacity (car imports/exports, fresh fruit and veg etc) with very limited potential for expansion, particularly if the unfounded aspiration for a wind-farm manufacturing facility at Sheerness is ever realised. I am afraid; once again, statements such as this hide the true condition. You wish to invest in new housing in an already deprived area. To avoid further deprivation you need to first develop what is already there otherwise what is (or may) be developed will inevitable get dragged down. This is a fact, it is called human factors. You once again mention a wind farm manufacturing facility; it is only planning permission in the event someone wishes to, or is found to want to provide that facility. To date, this has failed and provides false optimism and more importantly a false picture. Likewise, Sheerness port development is also mentioned. Again, caution should be exercised, any possible development will Mr Paul Hutchinson Objection LP150 4.5.74 Paragraph be very limited particularly with the development of the new and very large deep water facility in the Thames Estuary. Why would someone who requires deep water facilities come to Sheerness when there are more modern capabilities nearby? I am certainly not a glass half empty person, quite the opposite, but my half full glass is measured with confidence, not speculation. CPRE Protect Kent object most strongly to the identification of an ‘Area of Future Change’ at Sheerness. We consider that giving commitment now to undefined development in this location for the future, but which will be actively pursued during the Plan period, is contrary to the Plan-led approach that is central to the UK planning system. If this area offers development potential that the Council will be pursuing during the Plan period, even if development is not envisaged during the Plan period itself, then the Plan should put forward policies setting out the development potential to provide the context for subsequent work. This will also provide the opportunity for people to comment on the suitability of the area for future development as envisaged by the Council and for it to be explored at the Examination in Public. The approach advocated deprives people of this opportunity and promotes ‘back door’ planning. It predetermines that the area will be developed without the appropriate justification and gives the Council carte blanche to do as it wishes during the Plan period without any public endorsement and will result in a fait accompli when the Plan is reviewed. Inevitably, the fact that the area is identified as an ‘Area of Future Change’ in this Plan Mr Brian Lloyd Senior Planner Protect KENT Objection LP904 4.5.74 Paragraph will be used as justification for development in principle in future plans even though for this Plan no evidence would have been tested to endorse the specific development potential. We note that in part the ‘Area of Future Change’ reflects the permission already granted for the manufacture of wind-turbines. This is the only detail currently available relating to the ‘Area of Future Change’. However, given that the promoter of that development has withdrawn, it is difficult to see how it is likely to progress and what will happen when the planning permission expires. Will the Council apply to have the planning permission extended if a new operator is not found? In any event, though, it is concerning to see the statement in this paragraph that if the planning permission is implemented it will be necessary to review the plan because of the economic and housing implications that the development would trigger. As an extant planning permission, those considerations should have already been taken into account and, in our view, provides no justification for the ‘Area of Future Change’ being identified. Consequently, we consider that the ‘Area of Future Change’ should be deleted from the Plan . At last there is acknowledgement that transportation infrastructure is fragile. The ‘well-connected' statement for the western part of the island is inaccurate. Of course the new bridge provides excellent movement onto and off the island (I have chosen to ignore the incident on 4 Sep 13 as an Mr Paul Hutchinson Objection LP151 4.5.78 Paragraph isolated case) and with the exception of the bespoke Rushenden by-pass/link-road, therein ends the ‘well-connected'. Any regular visitor to the island will despair at the numerous bottlenecks particularly during the peak periods and school opening/closing time, on the western part of the Object / Document Name Organisation Support Rep ID Title Consultee Response Part

island these include the Cowstead roundabout, Lower Road, the Thistle Hill development, Queenborough Road and Minster Road. The ‘well-connected links' highlighted are good and directly support the commercial infrastructure in place. Mention is made of bus and rail enhancements and these are always welcomed, but it should not be to the disadvantage of road infrastructure as this is by far the more popular means of transport due, in main to the incited dormitory as opposed to commercial status of that part of the island. Whilst CPRE Protect Kent support the removal of land to the east of Scocles Road as a reserve Qualified Mr Brian Lloyd Senior Planner Protect KENT LP905 4.5.79 Paragraph housing site, we are concerned that the housing numbers at Queenborough Rushenden have been support so dramatically reduced. We comment further on this in response to paragraph 6.2.40. The Thistle Hill development highlights what happens when road infrastructure is not addressed in the planning stages and also predicating housing development to potential jobs. If there is ever an example of how not to plan development, the Thistle Hill development stands out and while the plan in some ways acknowledges this, it does not appear to be taking heed of it and that is alarming. Instead, it seems that the island and its inhabitants are going to made to suffer more congestion, an even bigger increase in dormitory status in order to meet council housing targets, all be it they are Mr Paul Hutchinson Objection LP152 4.5.79 Paragraph reduced. This is not considered a fair and practical means of planning distribution. To create more

hardship and infrastructure problems will only exacerbate the current deprived areas and counter any hope of practical development. Using population as statistical measurement to justify more housing is one method, even though earlier it is acknowledged that the job to house ratio is stymied; how about looking at useable land areas as an indicator instead; I think you may find there is a different conclusion. My message is; statistics can be used in any way you wish to gain a result, but is the statistics you are using the right ones or just convenient to provide the desire result? This new phrase ‘...triangle' seems to have been created to cover a number of major and minor development plans. Once again, and I make no apology for repeating it (as a resident I do and will Mr Paul Hutchinson Objection LP153 4.5.82 Paragraph suffer the effects), road infrastructure development to cope with demand needs to be carried out as a pre-condition, not as an implied requirement. This paragraph will need to be up-dated in accordance with our comments on Policy ST4 and our Mr Brian Lloyd Senior Planner Protect KENT Objection LP906 4.5.82 Paragraph objection to the allocations of land at Barton Hill Drive and Belgrave Road. Mr Brian Lloyd Senior Planner Protect KENT Objection LP907 4.5.83 Paragraph This paragraph will need to be up-dated in accordance with our comments on Policy ST4. The houses at Thistle Hill were built on a promise of work at Neats Court. One supermarket, a garage and a Kentucky Fried chicken does not constitute the work needed to employ the people on this island. Engineering jobs and the likeare being sacrificed at Rushenden for new housing developments. The Government are not prepared to help firmsto relocate by giving them special terms. They only state that there is a two year gap; enough time for the firms to move. People need Qualified The Isle of Sheppey area Mrs Linda Brinklow LP236 Policy ST 6 to work on the island. Ridham Docks and Sittingbourne are not far away, but the means to get to support strategy work, if you live at the other end of the island, is almost impossible without personaltransport. We have lost the steel works and Klippons at Halfway, among many of the industries that have vanished. We do not want to be an island of commuters at the end of the line. We want our own work and our own industries. Even the tourist industry on the island, is happening in spite of government help and not with it. CPRE Protect Kent generally support the strategy for the Isle of Sheppey area as presented in Qualified The Isle of Sheppey area this Policy. However, we would wish to see point 10 amended to read as follows: “Improve the Mr Brian Lloyd Senior Planner Protect KENT LP908 Policy ST 6 support strategy condition and quality of landscapes in the area and maintain separation between Halfway/Minster, Queenborough and Sheerness by the definition of sensitive countryside gaps.” NOTE: These representations are submitted on behalf of the Peel Group, which includes Peel Land & Property (Ports) Limited and Peel Ports. Qualified The Isle of Sheppey area Peel Group LP411 Policy ST 6 Peel Group supports the commitment in Policy ST 6 to granting planning permission for economic support strategy development at the Port of Sheerness but would request that the following text is added:

1. Bring forward economic development on allocated sites and, as available, within the "Existing Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Strategic Employment sites", including, at the Port of Sheerness , supporting diversification of its activities as a centre for the location of low carbon industries which could include physical expansion of the Port itself and other associated development .

Peel Group supports the acknowledgement in policy ST 6 that planning permission will be forthcoming for proposals which regenerate Queenborough and Rushenden but would reiterate comments made elsewhere that this area should be the subject of a proper, up to date allocation of land in this Local Plan, and that the Council cannot rely on continuing to save policies from the 2008 Local Plan which must be superseded once the new Local Plan is adopted. A cross reference to a new land allocation should be included in policy ST 6 for clarity. As things stand, the plan is not positively prepared in this respect and so is unsound . Development proposed on the Isle of Sheppey is to enable the economic regeneration of Sheerness Port and sites along the A249. There is also a strategic opportunity for regeneration at Queenborough and Rushenden primarily for housing and employment with associated social and Principal Planning Officer Kent community provision. Qualified The Isle of Sheppey area Miss Elizabeth Shier County Council (Planning and LP1140 Policy ST 6 support strategy Environment) KCC support the approach to development of the main urban areas of Sittingbourne, the Isle of Sheppey and Queenborough & Rushenden. The Homes and Communities Agency however still anticipate that 1800 homes will be built at Queenborough and Rushenden compared to 900 suggested by the Plan this could impact on infrastructure delivery. I've lived on Sheppey all my life, I'm 39 years old, the island is very over populated as it is, with very The Isle of Sheppey area Mr S Allan Objection LP1497 Policy ST 6 little work opportunities as it is especially with the steel mill, now gone where I previously worked, strategy the last thing we need now is more houses. Halfway & Minster used to be nice places to live. I live on the Isle of Sheppey in Kent and have recently been made aware of the scale of new development planned for the Island all under the umbrella of your NPPF and SBC Bearing Fruit. It would be interesting for someone to visit our Island and see the problems we already have with infrastructure, facilities and unemployment, there are no jobs here to speak of. There has been vigorous house building on the Island for a few years now with no added facilities or infrastructure, I cannot see how we can sustain even more building as planned in Bearing Fruits. Developers often promise added community benefits but always find an excuse not to bring them to fruition. Our Island is overcrowded as it is with much congestion. There are numerous holiday camps all open from March to December, with caravan and chalet owners backwards and forwards during ten months of the year, with the summer months bringing so much more congestion and all using our limited facilities. We have nothing against all this, we are a 'Holiday Island' after all. We also have a large prison cluster at the eastern end, one of which is vastly overcrowded, thus adding to the congestion. To sum up, we have limited facilities, not enough schools, medical services-we have a The Isle of Sheppey area Mrs M Aspley Objection LP98 Policy ST 6 small community hospital with just a minor injuries department more often than not we have to strategy travel to Medway or Maidstone for treatment, no maternity facilities, and scant community programmes. We have one of the highest unemployment figures, and with benefit cuts and people moving out of London for cheaper housing our benefits bill will be even higher, because obviously, much of our proposed new building will be for social housing. Many of our children travel off the Island to school due to overcrowding and less than perfect education including my grandsons one of whom attends a special school in Sittingbourne because there is nothing for him locally. We have today suffered catastrophe on the Sheppey Crossing with approx. 130 vehicles and two hundred people involved in crashes. This was all people going to work off the Island and those people are still stuck on the bridge five hours later how can you add to our congestion? Ours is a small community and everyone will know someone who knows someone who was involved in this heartbreaking event, for myself at this time I know of at least two, one being my nephew while not badly hurt is very shocked by what has happened. I would appreciate it if you could explain to me how you can justify even more building on our Island when we have so many problems already. I'm an Islander born and bred, now reaching the age of 40 and still living on the Island however The Isle of Sheppey area Ms Joanne Baskerville Objection LP58 Policy ST 6 working off (no jobs on the Island). The constant congestion on the lower road to Cowstead Corner strategy drives me insane on my return home from work. Why oh why do you intend building more houses Object / Document Name Organisation Support Rep ID Title Consultee Response Part

on the Island when we are already saturated? I've seen many new housing developments over the years, Lovell Road, Scrapsgate, Redrow (continuing over the old Danley School) Kingsborough Manor, the old Minster Hospital, Thistle Hill which is on going. We were promised infrastructure and jobs when all of these developments were proposed and built which clearly hasn't materialised. We have no infrastructure for the proposed 500 homes for the Barton Hill project. I'd also like to comment on the 5 pitches for Gypsies and Travellers allocation, I do hope if the go ahead is given, these pitches will be charged council tax, as a council tax payer myself I hope that these will contribute their fair share! At rush hour the Halfway area is now beginning to also build up with traffic due to the long queues at Cowstead Corner. How do you intend to justify this housing? no jobs, no infrastructure, no shops, schools, hospital, what do you expect children to do - no shopping centres, cinemas!? I can't see how you can! The frontage of Sheppey will be a wall of houses as you approach over the bridge. I'm angry, upset, and quite frankly disgusted LEAVE US BE!! I would like to raise objection to this proposed development, apart from the fact that more housing is ruining the island there isn't the infrastructure to support it. I along with quite a few islanders shall The Isle of Sheppey area D Benson Objection LP1496 Policy ST 6 be demonstrating our views against these proposed developments if the planners give permission strategy for this build. We will take it as high as we need to, to prevent more housing being built.That is a promise! Like most of the country I watched in horror as the recent events on the Sheppey Bridge unfolded.

I attend many of the council meetings at Minster,at Halfway Houses Residents Association and at Queenborough.

I am more than aware of the problems already existing on the island.

Lack of island based jobs being the main problem.

Poor infrastructure ,lack of parking facilities at the railways stations,trains where you have to change at Sittingbourne to get any where

inadequate bus services,both on and off the island ,no adequate infrastructure to cater for working people that have to use public transport and who work off the island and do shift work;the necessity of having a car/motor bike and of being able to drive;then the cost of getting to work even if you have a job. The Isle of Sheppey area Mrs Linda Brinklow Objection LP235 Policy ST 6 Apart from the new Morrisons store,the island has been losing jobs and not gaining them.Even strategy more jobs could go when and if the developments take place at Queenborough/Rushenden.Even now,the Minster development lacks the local shops,promised at the outset of the building programe.

You promise much and deliver as little as possible.

Residents in the Thistle Hill developments, leave the island in their droves. Most of the people leave and return to the island during a two hour slot in the morning and the evening.

A minority use public transport; it is simply not adequate to meet their needs..

An additonal 500 houses in Minster added to the houses planned for Rushenden/Queenborough and any more that get through planning for Halfway and you have a recipe for even more disasters on the bridge and else where on the island.

What happened to the ideas of protecting green field lands?

Already the Rushenden/Queenborough development is looking shaky.The plans for a marina look Object / Document Name Organisation Support Rep ID Title Consultee Response Part

as if they are going to be put on the back burner.

Instead,you want to increase the number of houses built in Minster.Have you tried to negociate the congested areas of Minster when they are clogged up with cars left by commuters catching the bus to London?

Have you tried to park at the shops in Halfway when the car park is full of commuters cars and cars for sale?

500 more houses means 500 more families with one or two cars,with children to go to school,with the need to have doctors dentists etc. It takes 3 weeks to get an appointment with our GP at present.This government is cutting back on services.Your policy document talks about the island as being included in ever thing and not being on the end.Well,just load us up with houses and nowhere to work and inadequate provisions and just see how well your plan for a sustainable future works for Sheppey! MPC fully supports point (5) to bring forward improvements to the A2500 Lower Road. Regarding point (6) MPC wants the word "urban" relating to the framework at Minster/Halfway changed to Parish Clerk Minster-on-Sea Parish The Isle of Sheppey area "suburban". Mrs Trish Codrington Objection LP225 Policy ST 6 Council strategy MPC fully supports point (10) to maintain the separation of the settlements of Minster / Halfway, Queenborough and Sheerness. We object to any more houses being built on the Island. We have not enough facilities: car-parking space ,doctors, schools, hospital facilities etc etc. We are already overloaded. Every street in The Isle of Sheppey area Sheerness, Minster, Eastchurch, Queenborough etc is jam-packed with vehicles so that there is Mr & Mrs C Corder Objection LP1499 Policy ST 6 strategy danger on every corner when driving or walking. The plan to build 1800 houses in the Rushenden/Queenborough area is not a help with jobs, but a hindrance for the above reasons. The Island with its present infrastructure cannot support further housing. The Isle of Sheppey area This policy area may benefit from consideration of a sub clause similar to that in the Sittingbourne David Hammond Natural England Objection LP1565 Policy ST 6 strategy Policy 7). The Island infrastructure cannot sustain any more building on the Island. Even with improvements The Isle of Sheppey area to the lower road (which needs to be done even if this plan does not go ahead) the island roads are Mr Stephen John Harcup Objection LP111 Policy ST 6 strategy overcrowded already. There is inadequate parking. The water is getting worse. And where are the fulltime jobs coming from. Looking at the general policies for Sheppey we are of the opinion that the case for the substantial increase in house building is fundamentally flawed. The Council's case is built around policies for job creation and, whilst we would welcome an increase in employment provision there is only a small chance that it will move forward to the levels shown in the plan. Much was made in the previous plan about the proposal by Vestas to construct wind turbines in the port of Sheerness, despite their being no confirmation that the proposal would go ahead, which it did not, before the plan was delivered. The current plan continues to show proposed turbine constmction at the port which is not substantiated by any firm contract. Neats Court is, yet again, shown as a major potential source of employment to back the housing figures yet we recall that this site was also used The Isle of Sheppey area Fiona Jackson Eastchurch Parish Council Objection LP811 Policy ST 6 to back the proposals at Thistle Hill 12 years ago ! What the plan does not cover and we appreciate strategy that the plan can only cover issues over which the Council has direct control, is the provision of services- many of which are already lacking and will be unable to cope with any increase in house building on the Island. Whilst we now have the new crossing, the internal road network on Sheppey is poor and at times, particularly during the now extended holiday season, totally inadequate. Primary school provision is already over-subscribed with the County Council failing to heed the local predictions of an increase in school age children and failing to take forward the originally proposed school on Thistle Hill and the redevelopment of the Danley Site. The proposed 500 homes at Barton Hill, the 1200 at Rushenden and the 860 for which planning already exists could provide another 1000 children in need of primary education and there are no existing plans to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

accommodate this increase. Healthcare is a major concern for Sheppey with an on-going GP shortage and poor hospital provision. The greater pali of hospital treatment is cunently dealt with at Medway Hospital which is already mnning over capacity and struggles to cope with its catchment area, paliicularly for A and E services. Additional residential population in Swale and Medway will make it impossible for it to function effectively. We have a hospital on Sheppey which has never been able to deliver much needed services and, any plan which seeks to increase population, must make the case for a substantial increase in hospital provision including A and E and maternity care on the Island. Public services are also a strong concern, many of which have been reduced over recent years and would need to be improved should the proposed increase in population happen. On Sheppey we are now reduced to having only one full time manned fire pump and recent events have proved this to be inadequate, despite the efforts of the firefighters. Our ambulance station is now reduced to a single vehicle at most times with ambulances required to travel from Medway to deal with emergencies. All of these services are working to capacity with the current level of population. They will not be able to cope with the numbers proposed without significant investment by the statutory bodies to protect the residents. It is our opinion that much of the plan is based on suppositions which are used to provide what the Council presents as facts and there is little regard for the implications it poses for current residents with particular emphasis on services and infrastructure Given the above responses, Eastchurch Parish Council is unable to support the plan and will continue to raise our concems and objections throughout the process and we urge the Council to look closely at how the plan affects residents and how it arrives at many of its conclusions. Para 4.5.79 - We do not agree that the fact the Island exports more of its workforce each day than it receives can be used to assume that immediate development needs can be met from the Thistle Hill area. As identified above the housing target identified will not support the economy led approach and unless more housing is allocated then this could suppress the economy on the island even further. We agree that the island must meet its housing needs and contribute toward meeting housing targets, and it is for these reasons the Council should be looking to allocate more land on the Isle of Sheppey for housing rather than reduce numbers or remove allocations, such as the land to the east of Scocles Road, which is to the west of Woottons Farm. Para 4.5.80 – 4.5.81 – The allocations for Queenborough are discussed further in section 4 below, however it is considered that there is still a level of uncertainty of the numbers that will come forward due to market conditions and also the land constraints (contamination, flooding etc). The Council make reference to continuing to work to ensure provision is made where required as a result of new development, however it is clear only phase 1 is likely to come forward at the moment, and there still remains uncertainty over the other phases with just ‘further land acquisitions being contemplated’. 2.51 4.5.82 – Our comments on the allocations proposed for Minster are included in section 4. We c/o Tetlow King Planning Kent The Isle of Sheppey area consider that the site at Woottons Farm, Minster should be allocated and that it scores higher in Objection LP1316 Policy ST 6 Developments UK Ltd strategy terms of sustainability than other sites identified. We note the council refer to the vulnerability of the Island to flooding and landslip will strongly influence where development can take place, yet sites which face these potential threats are put forward for allocation ahead of sites, such as Woottons Farm, with no constraints. This continues to suggest that a consistent approach has not been applied to the assessment of the site selection and this is also discussed further in section 4. We support that the ‘west Sheppey triangle’ settlements, which include Minster, are the focus of development and long term change. We support part 5 that development proposals will be supported by the LPA where they are well located in respect of the most accessible locations of the Island and where appropriate bring forward improvements to the A2500 Lower Road. The site at Woottons Farm, Minster has the potential to bring improvements to the Lower Road. We support part 6 which supports sites within urban areas and on allocated sites well related to the urban framework at Minster. We support that part 7 will look to bring forward measures that help reduce deprivation within the most deprived wards by providing sports and open space, together with new and/or expanded schools, health services, social care and libraries at Sheerness, Minster and Queenborough. The site at Woottons Farm, Minster has the potential to provide such benefits. This policy is considered further against the site at Woottons Farm and it’s suitability in section 7. The Isle of Sheppey area I write with regard to proposed developments on Sheppey and OBJECT most strongly to the Mr P J MacDonald Objection LP1019 Policy ST 6 strategy conclusions and recommendations of the development strategy 'Bearing Fruits'. Over the past 30 Object / Document Name Organisation Support Rep ID Title Consultee Response Part

years the Island has been subjected to rampant development by large scale national speculative developers, who cut and run at the end of the development with little requirement to provide necessary infrastructure. Despite vast enhancement of land values, only paltry sums have been required by planners which fail to cover the minimal infrastructure costs of these new developments, the provision of which will ultimately be a charge on Local and County Taxpayers. The economic base of the Island was destroyed with the closure of the Royal Dockyard 55 years ago. Through Government grants at the time some respite was achieved with the conversion of the dockyard into a commercial port, the construction of the steelworks, and a number of other industries. Sadly most have subsequently closed leaving large numbers of unemployed, or iflucky enough to obtain higher paid skilled employment by the necessity to commute off the Island with it's subsequent transport, environmental, and social costs. There has been a significant reduction in employment in the commercial port despite a very large expansion in surface area including the reclamation and absorption ofland outside the port historically allocated for employment. All the traditional heavy industries of Queenborough :- Potteries, Sheet glass, Bottle works, Chemical/Fertilizer production, the small steel rolling mill and the metal casting industry have all closed. Swale Borough Council however should be congratulated with their recent involvement and encouragement of 'The Spittlefields Trust' in the restoration of the Georgian Dockyard Houses and the Dockyard Church. Although offering small employment opportunities, there could be a limited chance of Heritage employment if other parts of the Historic Dockyard were to be eventually encompassed. The recent expansion of Aseco Pharmaceuticals is a very bright star and a move in the right direction, congratulations to the owners and all involved including Swale Borough Council's input. The opening of the new Morrisons supermarket although employment is relatively low paid, will help to a small degree with the Island economy. It will take at least a decade with no further house building to have the possibility of a catch-up. There is no justification for any allocation of land for further residential use. The exception being land already allocated , and effective consolidation with the careful allocation of small in-fill plots to improve the area, a concept which has consistently failed to be understood by planners whose policies have allowed the wholesale rape of the countryside and destruction of wildlife habitats, whilst persistently refusing planning to individuals intent of building the odd property of quality, fortunately the Council has lost the subsequent appeals to HMI . Effectively over the past few decades, the Island has been trashed by plarmers leaving a resultant visual and economic mess. It is now high time for a far more rigorous approach with efforts to improve the area, rebuild the economic base, and provide a more balanced socio -economic mix to attract genuine inward wealth and investment. (1) Any further allocations of residential land over 1 acre, other than existing brown land would be the height of irresponsibility and would compound the already serious problems. (2) The residential allocation of Queenborough I Rushenden should represent the bulk of the Island's contribution. Under NO circumstances should the proposed land North of the Lower Road A2500 and West of Barton Hill Drive should be allocated. In fact HM Inspectorate already refused the top end of the site for residential planning, stating that this proposed development would be visually intrusive from the Lower Road which area should remain an open aspect. (3) High density residential development will only encourage inward migration from other more expensive areas including London & Abroad. Without employment opportunities, there will be increased pressure on Social Services, Benefits, Health, Education, existing failing Utilities, and other infrastructure, all a further charge on hard pressed Kent County Council and Swale Borough ratepayers. (4) The largest multi vehicle pile up historically recorded on the UK road system, which took place on the A249 (T) at 07:15 in morning is an indictment of past planning policies which FAILED to ensure that employment opportunities on the Isle of Sheppey kept pace with speculative house building, forcing those who wanted to work to commute sometimes large distances. The elected members of Swale Borough Council should be further congratulated on their rejection of the half baked earlier proposals put forward by Consultants & Planners who generally would not have to live with the consequences of their proposals. There is already at least a 10 year supply of house building land on Sheppey, (As proved by Mr Orpin), and with minor tweaks of consolidation, only brown land should be developed. I ask Swale Borough Council members to go the full mile and reject the irresponsible ' Bearing Fruits' proposals. The Isle of Sheppey area point 5 there should be an aim to have a whole cycle loop around the island. from the old bridge all Adrian Oliver Swale Cycle Forum Objection LP1116 Policy ST 6 strategy the way around to Harty Object / Document Name Organisation Support Rep ID Title Consultee Response Part

I agree houses need to be built to house a growing population. Sheppey has taken a fair proportion of these new homes as I have seen Minster and the surrounding area develop over more than 60 years since I was born here.

Sheppey can take NO MORE BUILDING in it's present state and this is why....

Sheppey is different to ALL other areas in Swale, and most areas within the UK, in that it is a small island with only one main route on and off - the Swale Crossing. If that crossing is closed (which it is several times a year due to accidents or bad weather) the Island almost comes to a standstill. The new bridge was built under a Labour government (after cancelling a perfectly good proposal by the Conservative government) after Prescott wanted thousands of homes built in the Thames Gateway. We got a cheaper crossing to compensate for the extra homes planned for Sheppey - which is okay so long as the bridge is open 24/7 365 days a year. On the days it is closed, we can not get to work, to school, to A&E hospital, or many other places Islanders need to go - because facilities are not available here. If an accident happens on any other road in Swale - or most of the UK, closing that road, then traffic can usually find several alternative roads out of the town or village and continue to their destination. On Sheppey all these extra cars only have one route out - on the old Kingsferry Bridge, that was designed for a small fraction of the cars that cross the Swale daily.

The Isle of Sheppey area Mr Charles Partington Objection LP1583 Policy ST 6 Even when the new crossing is open, the traffic build up at rush hour - especially coming towards strategy Minster and Leysdown is not only very bad for the environment with vehicles pumping out fumes as they crawl along the Lower Road, but also very dangerous as they queue around TWO roundabouts, as well as try to push in and race towards the single carriage of Lower Road. It is a nightmare.

Before another house is built on this Island we need a better road system to the new estates, another dual carriage crossing, more jobs, schools, and services on the Island so people are not driving off, and a hospital that provides ALL NHS services - but especially A&E and Maternity as this is more important than general non-emergency or geriatric services that are less likely to need a 999 response - especially as we do not have ambulances on the Island now like we used to when the population was half what it is now! (I know this because when I needed an ambulance, an estate car arrived at 02:00 and when the paramedic called for a 999 ambulance to take my partner to hospital, he was told the nearest was in Canterbury and on it's way to another 999 call! If this happened at 08:00 and the new crossing was closed, it would have taken hours for the ambulance to arrive - and get off again to go to Medway.

Sheppey is a small island with very limited services - sewers, drains, water supplies, roads - not to mention the points I have raised above. Minster has developed from a nice country village that I remember in the 50's and 60's into a town. Enough is enough, IF green fields need to be built on, Sheppey is not the only place that has them! It's great to see that the Swale area has some focus for development. However, I believe the council are being shortsighted on how we develop. Building numerous houses on the Isle of Sheppey without an employment infrastructure does not seem logical. Surely we need businesses, industrial development shopping centre to entice people to want to come and live here? I am all up for the further development of the land adjacent and surrounding the new Morrisons store. If this is grown in the right way, then we should follow on with housisland for the development of The Isle of Sheppey area Mr Chris Philpott Objection LP21 Policy ST 6 Sittingbourne High Sreet, that's great news too, but there is no mention of Sheerness High Street ? strategy What not develop the empty shops and buildings in flats/apartments and houses instead of building more new housing. Also, what are you proposing to do about the extreme high unemployment on the island seem to be sending our employment off the Island?

My suggestion would be attract more businesses, attract some industrial infrastructure, promote growth and employment, build housing. We seem to be in the last stage first? Object / Document Name Organisation Support Rep ID Title Consultee Response Part

I went to view the unmanned exhibition in the Sheppey Gateway this morning and met likeminded The Isle of Sheppey area neighbours. We were all furious at the proposals for further housing and gypsy/traveller sites on Mrs Joyce Roullier Objection LP116 Policy ST 6 strategy Sheppey - especially in Minster. We came to the conclusion that very few planners live on our Island!!! Although less housing is proposed within the Isle of Sheppey than at Sittingbourne this remains a sensitive area that combined with plans for Sittingbourne is likely to have significant impacts on the SPA/Ramsar designations within the area. Many of our comments to development at Sittingbourne also apply to this area. We welcome the commitment to "Establish the Island as a focus for Conservation Officer, Policy and The Isle of Sheppey area achieving net gains in biodiversity both through the appropriate mitigation and compensation of Miss Debbie Salmon Objection LP1084 Policy ST 6 Planning Kent Wildlife Trust strategy projects within the Borough and further afield;" , however it will be important that the proposed development is assessed as part of the HRA, both individually and in-combination with other development, to ensure that the location and quantum of development can be accommodated without the integrity of the European designations being compromised once mitigation is in place. (See comments on site specific policies for ecological issues on individual sites.) I write with regard to proposed developments on Sheppey and OBJECT most strongly to the conclusions and recommendations of the development strategy 'Bearing Fruits'. Over the past 30 years the Island has been subjected to rampant development by large scale national speculative developers, who cut and run at the end of the development with little requirement to provide necessary infrastructure. Despite vast enhancement of land values, only paltry sums have been required by planners which fail to cover the minimal infrastructure costs of these new developments, the provision of which will ultimately be a charge on Local and County Taxpayers. The economic base of the Island was destroyed with the closure of the Royal Dockyard 55 years ago. Through Government grants at the time some respite was achieved with the conversion of the dockyard into a commercial port, the construction of the steelworks, and a number of other industries. Sadly most have subsequently closed leaving large numbers of unemployed, or iflucky enough to obtain higher paid skilled employment by the necessity to commute off the Island with it's subsequent transport, environmental, and social costs. There has been a significant reduction in employment in the commercial port despite a very large expansion in surface area including the reclamation and absorption ofland outside the port historically allocated for employment. All the traditional heavy industries of Queenborough :- Potteries, Sheet glass, Bottle works, Chemical/Fertilizer production, the small steel rolling mill and the metal casting industry have all closed. Swale Borough Council however should be congratulated with their recent involvement and encouragement of 'The Spittlefields Trust' in the restoration of the Georgian Dockyard Houses and the Dockyard Church. Although offering small employment opportunities, there could be a limited chance of Heritage The Isle of Sheppey area L Tansley Objection LP1020 Policy ST 6 employment if other parts of the Historic Dockyard were to be eventually encompassed. The recent strategy expansion of Aseco Pharmaceuticals is a very bright star and a move in the right direction, congratulations to the owners and all involved including Swale Borough Council's input. The opening of the new Morrisons supermarket although employment is relatively low paid, will help to a small degree with the Island economy. It will take at least a decade with no further house building to have the possibility of a catch-up. There is no justification for any allocation of land for further residential use. The exception being land already allocated , and effective consolidation with the careful allocation of small in-fill plots to improve the area, a concept which has consistently failed to be understood by planners whose policies have allowed the wholesale rape of the countryside and destruction of wildlife habitats, whilst persistently refusing planning to individuals intent of building the odd property of quality, fortunately the Council has lost the subsequent appeals to HMI . Effectively over the past few decades, the Island has been trashed by plarmers leaving a resultant visual and economic mess. It is now high time for a far more rigorous approach with efforts to improve the area, rebuild the economic base, and provide a more balanced socio -economic mix to attract genuine inward wealth and investment. (1) Any further allocations of residential land over 1 acre, other than existing brown land would be the height of irresponsibility and would compound the already serious problems. (2) The residential allocation of Queenborough I Rushenden should represent the bulk of the Island's contribution. Under NO circumstances should the proposed land North of the Lower Road A2500 and West of Barton Hill Drive should be allocated. In fact HM Inspectorate already refused the top end of the site for residential planning, stating that this proposed development would be visually intrusive from the Lower Road which area should remain Object / Document Name Organisation Support Rep ID Title Consultee Response Part

an open aspect. (3) High density residential development will only encourage inward migration from other more expensive areas including London & Abroad. Without employment opportunities, there will be increased pressure on Social Services, Benefits, Health, Education, existing failing Utilities, and other infrastructure, all a further charge on hard pressed Kent County Council and Swale Borough ratepayers. (4) The largest multi vehicle pile up historically recorded on the UK road system, which took place on the A249 (T) at 07:15 in morning is an indictment of past planning policies which FAILED to ensure that employment opportunities on the Isle of Sheppey kept pace with speculative house building, forcing those who wanted to work to commute sometimes large distances. The elected members of Swale Borough Council should be further congratulated on their rejection of the half baked earlier proposals put forward by Consultants & Planners who generally would not have to live with the consequences of their proposals. There is already at least a 10 year supply of house building land on Sheppey, (As proved by Mr Orpin), and with minor tweaks of consolidation, only brown land should be developed. I ask Swale Borough Council members to go the full mile and reject the irresponsible ' Bearing Fruits' proposals. I write with regard to proposed developments on Sheppey and OBJECT most strongly to the conclusions and recommendations of the development strategy 'Bearing Fruits'. Over the past 30 years the Island has been subjected to rampant development by large scale national speculative developers, who cut and run at the end of the development with little requirement to provide necessary infrastructure. Despite vast enhancement of land values, only paltry sums have been required by planners which fail to cover the minimal infrastructure costs of these new developments, the provision of which will ultimately be a charge on Local and County Taxpayers. The economic base of the Island was destroyed with the closure of the Royal Dockyard 55 years ago. Through Government grants at the time some respite was achieved with the conversion of the dockyard into a commercial port, the construction of the steelworks, and a number of other industries. Sadly most have subsequently closed leaving large numbers of unemployed, or iflucky enough to obtain higher paid skilled employment by the necessity to commute off the Island with it's subsequent transport, environmental, and social costs. There has been a significant reduction in employment in the commercial port despite a very large expansion in surface area including the reclamation and absorption ofland outside the port historically allocated for employment. All the traditional heavy industries of Queenborough :- Potteries, Sheet glass, Bottle works, Chemical/Fertilizer production, the small steel rolling mill and the metal casting industry have all closed. Swale Borough Council however should be congratulated with their recent involvement and encouragement of 'The Spittlefields Trust' in the restoration of the Georgian Dockyard Houses and the Dockyard Church. Although offering small employment opportunities, there could be a limited chance of Heritage The Isle of Sheppey area Mr K P White Objection LP1021 Policy ST 6 employment if other parts of the Historic Dockyard were to be eventually encompassed. The recent strategy expansion of Aseco Pharmaceuticals is a very bright star and a move in the right direction, congratulations to the owners and all involved including Swale Borough Council's input. The opening of the new Morrisons supermarket although employment is relatively low paid, will help to a small degree with the Island economy. It will take at least a decade with no further house building to have the possibility of a catch-up. There is no justification for any allocation of land for further residential use. The exception being land already allocated , and effective consolidation with the careful allocation of small in-fill plots to improve the area, a concept which has consistently failed to be understood by planners whose policies have allowed the wholesale rape of the countryside and destruction of wildlife habitats, whilst persistently refusing planning to individuals intent of building the odd property of quality, fortunately the Council has lost the subsequent appeals to HMI . Effectively over the past few decades, the Island has been trashed by plarmers leaving a resultant visual and economic mess. It is now high time for a far more rigorous approach with efforts to improve the area, rebuild the economic base, and provide a more balanced socio -economic mix to attract genuine inward wealth and investment. (1) Any further allocations of residential land over 1 acre, other than existing brown land would be the height of irresponsibility and would compound the already serious problems. (2) The residential allocation of Queenborough I Rushenden should represent the bulk of the Island's contribution. Under NO circumstances should the proposed land North of the Lower Road A2500 and West of Barton Hill Drive should be allocated. In fact HM Inspectorate already refused the top end of the site for residential planning, stating that this proposed development would be visually intrusive from the Lower Road which area should remain Object / Document Name Organisation Support Rep ID Title Consultee Response Part

an open aspect. (3) High density residential development will only encourage inward migration from other more expensive areas including London & Abroad. Without employment opportunities, there will be increased pressure on Social Services, Benefits, Health, Education, existing failing Utilities, and other infrastructure, all a further charge on hard pressed Kent County Council and Swale Borough ratepayers. (4) The largest multi vehicle pile up historically recorded on the UK road system, which took place on the A249 (T) at 07:15 in morning is an indictment of past planning policies which FAILED to ensure that employment opportunities on the Isle of Sheppey kept pace with speculative house building, forcing those who wanted to work to commute sometimes large distances. The elected members of Swale Borough Council should be further congratulated on their rejection of the half baked earlier proposals put forward by Consultants & Planners who generally would not have to live with the consequences of their proposals. There is already at least a 10 year supply of house building land on Sheppey, (As proved by Mr Orpin), and with minor tweaks of consolidation, only brown land should be developed. I ask Swale Borough Council members to go the full mile and reject the irresponsible ' Bearing Fruits' proposals. I write with regard to proposed developments on Sheppey and OBJECT most strongly to the conclusions and recommendations of the development strategy 'Bearing Fruits'. Over the past 30 years the Island has been subjected to rampant development by large scale national speculative developers, who cut and run at the end of the development with little requirement to provide necessary infrastructure. Despite vast enhancement of land values, only paltry sums have been required by planners which fail to cover the minimal infrastructure costs of these new developments, the provision of which will ultimately be a charge on Local and County Taxpayers. The economic base of the Island was destroyed with the closure of the Royal Dockyard 55 years ago. Through Government grants at the time some respite was achieved with the conversion of the dockyard into a commercial port, the construction of the steelworks, and a number of other industries. Sadly most have subsequently closed leaving large numbers of unemployed, or iflucky enough to obtain higher paid skilled employment by the necessity to commute off the Island with it's subsequent transport, environmental, and social costs. There has been a significant reduction in employment in the commercial port despite a very large expansion in surface area including the reclamation and absorption ofland outside the port historically allocated for employment. All the traditional heavy industries of Queenborough :- Potteries, Sheet glass, Bottle works, Chemical/Fertilizer production, the small steel rolling mill and the metal casting industry have all closed. Swale Borough Council however should be congratulated with their recent involvement and encouragement of 'The Spittlefields Trust' in the restoration of the Georgian Dockyard Houses and the Dockyard Church. Although offering small employment opportunities, there could be a limited chance of Heritage The Isle of Sheppey area Mrs P M White Objection LP1022 Policy ST 6 employment if other parts of the Historic Dockyard were to be eventually encompassed. The recent strategy expansion of Aseco Pharmaceuticals is a very bright star and a move in the right direction, congratulations to the owners and all involved including Swale Borough Council's input. The opening of the new Morrisons supermarket although employment is relatively low paid, will help to a small degree with the Island economy. It will take at least a decade with no further house building to have the possibility of a catch-up. There is no justification for any allocation of land for further residential use. The exception being land already allocated , and effective consolidation with the careful allocation of small in-fill plots to improve the area, a concept which has consistently failed to be understood by planners whose policies have allowed the wholesale rape of the countryside and destruction of wildlife habitats, whilst persistently refusing planning to individuals intent of building the odd property of quality, fortunately the Council has lost the subsequent appeals to HMI . Effectively over the past few decades, the Island has been trashed by plarmers leaving a resultant visual and economic mess. It is now high time for a far more rigorous approach with efforts to improve the area, rebuild the economic base, and provide a more balanced socio -economic mix to attract genuine inward wealth and investment. (1) Any further allocations of residential land over 1 acre, other than existing brown land would be the height of irresponsibility and would compound the already serious problems. (2) The residential allocation of Queenborough I Rushenden should represent the bulk of the Island's contribution. Under NO circumstances should the proposed land North of the Lower Road A2500 and West of Barton Hill Drive should be allocated. In fact HM Inspectorate already refused the top end of the site for residential planning, stating that this proposed development would be visually intrusive from the Lower Road which area should remain Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We object to the wording “the conservation and enhancement of the historic and natural environments of the town and its surrounding rural hinterland as the primary planning aims”. Ordnance Wharf Objection LP596 4.5.89 Paragraph

locations, including beyond the existing built-up area.

We would suggest that the text should be redrafted to indicate that the appropriate level of growth should be in accordance with the Town’s position in the Settlement Hierarchy and that there are appropriate development opportunities to assist in maintaining the status and role of the town. Mrs Jennifer Bate Planning Officer Kent Downs AONB Support LP511 4.5.89 Paragraph Support. We agree with concept set out in paragraph 4.5.91 of safeguarding the existing employment sites to the north- west of the town and along the Western Link, and are concerned that this policy should be continued if the Gist depot at the Western Link is vacated by Marks and Spencer as this site is a large employer in the town. The brewery is also an important local employer and should be retained. We support the redevelopment and extension of the Nova site at Graveney Road for employment but are concerned at the development of the site beyond the former nursery at Selling Road rather than just the former nursery itself as this is south of the A2 and sets a precedent for other similar development. We would have preferred that some provision for employment should be retained on at least part of the brickfield site adjacent to the Western Link as the road was built to serve industry and take traffic for business away from the town. However, this area is at the edge of Qualified existing residential areas at the west side of the town and would be screened from the road by Anne Salmon Faversham Society LP1380 4.5.91 Paragraph support planting. It would serve to improve the character and mix of housing in this part of the town and is close to an existing school. In view of the explanation given in the site allocations chapter, we understand the Local Plan strategy for development of the site at Oare Gravel Workings for industrial and residential development and substantial landscaping. The site could incorporate better presentation of the gunpowder heritage because it is near to other gunpowder sites such as the Oare Works. However, this site is only accessible by road through Ospringe and via the Western Link, which is unlikely to be popular with employers and difficult to market. It is understood that this has already proved to be the case on the foundry site on Oare Road. The alternative at Love Lane was the favourite in the last round of consultation and is much closer to good road links such as Brenley Corner and based on the Dane Park scheme could prove more flexible in terms of the uses it could offer. It would seem more logical to support employment opportunities on sites near the Western Link, Ms Hilary Whelan Objection LP490 4.5.91 Paragraph and to allocate the Nova site - which is closer to the town centre - for housing, rather than vice-

versa. We support recognition of the need to provide improved quality, choice and quantity of employment Mr Neil Flanagan Support LP553 4.5.92 Paragraph land. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

We support recognition of the need to provide improved quality, choice and quantity of employment Ordnance Wharf Support LP597 4.5.92 Paragraph land. We support recognition of the need to provide improved quality, choice and quantity of employment Gibb Femco Support LP683 4.5.92 Paragraph land. We support recognition of the need to provide improved quality, choice and quantity of employment Mr Michael White Support LP644 4.5.92 Paragraph land. It is not at all clear why development at Oare Gravel Works is a better fit with the council's strategy than the Love Lane site, given the numerous constraints (flood risk, the nature of the land, environmental issues) and disadvantages (distance from town centre, lack of amenities, lack of Ms Hilary Whelan Objection LP488 4.5.93 Paragraph public transport, increase in traffic on narrow roads in Davington, encroachment on the separation

between Faversham and Oare) of the Oare site. By contrast, the Love Lane site is closer to the town centre, on a bus route, and seems to be well-designed with public amenities, and with a high level of affordable housing which is defined as a priority elsewhere in the Plan. Using the brickworks area for housing development conflicts with the policy of maintaining the compact nature of the town. This area is remote from the centre and will create a demand for out-of- town facilities which will detract from the centre. It is not well-supplied with public transport and will Ms Hilary Whelan Objection LP489 4.5.93 Paragraph generate more vehicle traffic. It is implied that there is no demand for employment use, but how actively has the site been marketed? What actions have the council taken to support and assist the development of employment uses? CPRE Protect Kent support and welcome the Council’s change of heart over the options presented in the previous consultation, and we agree that the Oare Gravel Workings site presents an achievable development opportunity. However, we do not agree that this it is either necessary or Mr Brian Lloyd Senior Planner Protect KENT Support LP909 4.5.93 Paragraph appropriate to identify the site at Love Lane as a ‘reserve site’ as this will only serve to undermine the delivery of the Oare Gravel Workings site, which, as acknowledged in the draft Plan, is not without challenges already. Object to “primary planning aims of conservation and enhancement”.

This wording suggests a strict limitation on new development at Faversham whereas elsewhere the Draft Plan recognises the need and opportunities for new development at an appropriate scale and locations, including beyond the existing built-up area. Mr Neil Flanagan Objection LP554 4.5.94 Paragraph We would suggest that the text should be redrafted to indicate that the appropriate level of growth should be in accordance with the Town’s position in the Settlement Hierarchy and that there are appropriate development opportunities to assist in maintaining the status and role of the town.

As acknowledged in NPPF, a balance may need to be struck, in some circumstances, to ensure that Heritage Assets have viable new uses. Object to “primary planning aims of conservation and enhancement”.

This wording suggests a strict limitation on new development at Faversham whereas elsewhere the Draft Plan recognises the need and opportunities for new development at an appropriate scale and locations, including beyond the existing built-up area. Ordnance Wharf Objection LP598 4.5.94 Paragraph We would suggest that the text should be redrafted to indicate that the appropriate level of growth should be in accordance with the Town’s position in the Settlement Hierarchy and that there are appropriate development opportunities to assist in maintaining the status and role of the town.

As acknowledged in NPPF, a balance may need to be struck, in some circumstances, to ensure that Heritage Assets have viable new uses. Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Object to “primary planning aims of conservation and enhancement”.

This wording suggests a strict limitation on new development at Faversham whereas elsewhere the Draft Plan recognises the need and opportunities for new development at an appropriate scale and locations, including beyond the existing built-up area. Mr Michael White Objection LP645 4.5.94 Paragraph We would suggest that the text should be redrafted to indicate that the appropriate level of growth should be in accordance with the Town’s position in the Settlement Hierarchy and that there are appropriate development opportunities to assist in maintaining the status and role of the town.

As acknowledged in NPPF, a balance may need to be struck, in some circumstances, to ensure that Heritage Assets have viable new uses. We agree that the North Kent Marshes and the Kent Downs and other more local countryside serve as important resource for leisure which complements the heritage of the town. The idea of promoting the town for its heritage of food and drink is one that the Society has been suggesting Anne Salmon Faversham Society Support LP1381 4.5.94 Paragraph since the Issues and Options consultation. These promotions are already making a significant contribution to tourism numbers in the area, although the town does not have the extensive draw of independent shops and the seaside that benefit Whitstable. Object to “primary planning aims of conservation and enhancement”.

This wording suggests a strict limitation on new development at Faversham whereas elsewhere the Draft Plan recognises the need and opportunities for new development at an appropriate scale and locations, including beyond the existing built-up area. Gibb Femco LP684 4.5.94 Paragraph We would suggest that the text should be redrafted to indicate that the appropriate level of growth should be in accordance with the Town’s position in the Settlement Hierarchy and that there are appropriate development opportunities to assist in maintaining the status and role of the town.

As acknowledged in NPPF, a balance may need to be struck, in some circumstances, to ensure that Heritage Assets have viable new uses. Mrs Jennifer Bate Planning Officer Kent Downs AONB Support LP512 4.5.95 Paragraph Support. Paragraph 5.5.95 refers to the Kent Downs AONB and is one of a number of references to the David Hammond Natural England Support LP1566 4.5.95 Paragraph AONB which is acknowledged and welcomed.

It is suggested in paragraph 4.5.99 that new housing sites are likely to come forward in the centre of town. It is difficult to envisage where these might be as all of the upper parts of Tesco have now been developed and there are no other large vacant buildings or sites. There is scope for more residential use above shops. There are sites around the creek but it is agreed that these may only be acceptable if they support employment and retail uses and do not compromise the Vision and Qualified Anne Salmon Faversham Society LP1382 4.5.99 Paragraph Objectives of the Neighbourhood Plan. There is no target for housing numbers around the creek as support these are expected to be determined through the Creek Neighbourhood Plan. Paragraph 4.4.102 refers to Faversham Creek as a new mixed use community as proposed in Policy NP1 and this policy is open-ended in terms of what the mix of uses could result. The main objectives are regeneration of key creekside sites, improvement of footpaths and public access and provision of a linked network of open spaces. Since it is stated that there is no social or economic need for significant numbers of new housing in Faversham, apart from affordable housing, why is so much being proposed, and how much of it will be affordable? There seem to be no plans for significant improvements in infrastructure (transport, Ms Hilary Whelan Objection LP482 4.5.99 Paragraph schools, health, water supply and sewerage, etc) to support this level of population increase. With respect to the Faversham Creek Neighbourhood Plan area, there is public opposition to creekside housing - none of which will increase the stock of affordable housing - and a clear preference for Object / Document Name Organisation Support Rep ID Title Consultee Response Part

maritime/employment/tourism development. Support acknowledgement of the need for the provision of new housing, including to support regeneration objectives and the vibrancy of the community. Mr Neil Flanagan Support LP555 4.5.99 Paragraph

Support acknowledgement that sites will come forward within the central areas of Faversham, including within the Neighbourhood Plan at Faversham Creek. Support acknowledgement of the need for the provision of new housing, including to support regeneration objectives and the vibrancy of the community. Ordnance Wharf Support LP599 4.5.99 Paragraph

Support acknowledgement that sites will come forward within the central areas of Faversham, including within the Neighbourhood Plan at Faversham Creek. Another element not considered yet in the CNP but part of the plan for Oare Gravel Workings is a new footpath link across Ham Farm to the creek bank. This would be welcome if it could form part Anne Salmon Faversham Society Objection LP1383 4.5.100 Paragraph of a heritage trail linking the gunpowder sites from Oare to Faversham Creek. It is not shown in the developer’s proposals. Public opinion does not favour "mixed use" development on Faversham Creek; it favours Ms Hilary Whelan Objection LP483 4.5.102 Paragraph maritime/employment/tourism. It is not clear what is meant be "a linked network of spaces and

routes between Faversham and Oare creeks". Support acknowledgement of development opportunities at Faversham Creek through the Neighbourhood Plan and Proposed Policy NP1. Mr Neil Flanagan Support LP556 4.5.102 Paragraph

Support the regeneration of key Creekside sites. Support acknowledgement of development opportunities at Faversham Creek through the Neighbourhood Plan and Proposed Policy NP1. Ordnance Wharf Support LP600 4.5.102 Paragraph

Support the regeneration of key Creekside sites. Support recognition that, at the developed areas of Faversham Creek, a flexible response to the Mr Neil Flanagan Support LP558 4.5.103 Paragraph issue of flood risk will be necessary to enable regeneration to take place. Ordnance Wharf Support LP601 4.5.103 Paragraph Support recognition that, at the developed areas of Faversham Creek, a flexible response to the

Object / Document Name Organisation Support Rep ID Title Consultee Response Part

issue of flood risk will be necessary to enable regeneration to take place. Support recognition that, at the developed areas of Faversham Creek, a flexible response to the Gibb Femco Support LP688 4.5.103 Paragraph issue of flood risk will be necessary to enable regeneration to take place. Support recognition that, at the developed areas of Faversham Creek, a flexible response to the Mr Michael White Support LP648 4.5.103 Paragraph issue of flood risk will be necessary to enable regeneration to take place. Principal Planning Officer Kent Refers to the need for an Appropriate Assessment to be carried out on other documents but it is not Miss Elizabeth Shier County Council (Planning and Objection LP1203 4.5.104 Paragraph clear whether an Appropriate Assessment has been carried out for this plan. Environment) Mrs Jennifer Bate Planning Officer Kent Downs AONB Support LP513 4.5.105 Paragraph Support. Particularly welcome is the reference to the AONB’s Management Plan under paragraph 4.5.105 David Hammond Natural England Support LP1567 4.5.105 Paragraph which should be referenced in all planning applications with potential to impact on the AONB.

Paragraph 4.5.106 gives an analysis of the character of Faversham. 40% of the town is in a conservation area and the town has had a long span of occupation. It has a waterway used since pre- Roman times, a market established since the 10 th century, two 12 th century monastic foundations and early prosperity reflected in buildings at the creek and in Abbey Street, Court Street and West Street, a brewery which advertises that it has operated since 1698 but brewing can be traced much further back and the remains of the gunpowder industry and more extensive Anne Salmon Faversham Society Support LP1384 4.5.106 Paragraph brickmaking, together with a built heritage which shows considerable 19 th century expansion following the coming of the railways. What should be added in this section is the legacy of local charitable giving in the mid to late 19 th century including the Recreation Ground, Wreights School in Church Road, the Almshouses in South Road and William Gibbs School in Orchard Place. The urban form of Faversham is described as part of its uniqueness. At the northern edge are views of barges, the abbey barns and of the spire of the parish church and to the west the wooded ridge of Bysing Woods with most development north of the A2. This paragraph rightly acknowledges that "creek side and maritime cores of the town" are among its outstanding features, along with old wharves and sailing barges. However, this is in conflict with Ms Hilary Whelan Support LP484 4.5.107 Paragraph other parts of the plan which seek to develop housing on the creekside at the expense of maritime heritage. Mrs Jennifer Bate Planning Officer Kent Downs AONB Support LP528 4.5.109 Paragraph Support. CPRE Protect Kent generally support the strategy for the Faversham and Kent Downs area as Qualified The Faversham area and Kent presented in this Policy. However, we would wish to see the following amendments made: · Mr Brian Lloyd Senior Planner Protect KENT LP910 Policy ST 7 support Downs strategy Remove the final sentence of point 2; Amend point 14b to read as follows: “the setting and separation of settlements close to Faversham by the definition of sensitive countryside gaps.” We support policy ST7 in general, but comment that: no. 1 should say ‘maintain existing land and buildings in employment use and bring forward saved local plan allocations (with the exception of Selling Road, but maintaining the Brents Industrial Estate) No 9 refers to Davington and states that Qualified The Faversham area and Kent efforts should be made to ‘improve’ levels of deprivation. This should say ‘reduce’ Nos 10 and 12 Anne Salmon Faversham Society LP1385 Policy ST 7 support Downs strategy which refer to using the creek area as a tourist hub and a place of special interest and activity and achieving net gains in biodiversity from the Creek Neighbourhood Plan are items that are already part of the CNP Objectives. How to achieve these is a matter to be decided from the ongoing Creek Neighbourhood Plan process. There are many aspects of the vision and strategy with which I agree, but there are major inconsistencies throughout between the strategy, the proposals, and actions required. Lip service is Qualified The Faversham area and Kent Ms Hilary Whelan LP491 Policy ST 7 paid to concerns such as flood risk, but there are no concrete proposals. Many elements of the plan support Downs strategy are over-prescriptive and are unlikely to ever be implemented; it would be better to focus on a smaller number of the most important and achievable developments. The Faversham area and Kent The Parish Council would like to give evidence of inappropriate locations such as windmill farm, Mr Graham Addicott Hartlip Parish Council Objection LP726 Policy ST 7 Downs strategy Yaugher Lane where development has impacted on the countryside, visible from multiple locations Object / Document Name Organisation Support Rep ID Title Consultee Response Part

and is far from any services. The cumulative effect of piecemeal development over a large area forever changing the character and nature of the area. These submissions should be read in conjunction with those previously submitted on the draft Core Strategy in 2010, which also included a plan of the adjacent area of worked out mineral extraction. It is recognised and accepted that Faversham is one of the most sustainable settlements in the Borough and has a range of services and facilities that confirm it as a location suitable to accommodate further housing and employment development. In this context, the Council’s strategy for the introduction of major housing development at the town is welcomed and supported. It is noted that one of the main areas for development is proposed at Oare Gravel Works on the north side of Ham Road. This location is proposed under draft policy A7 to be the focus of major development for 20,000 sq m of Use Class B (business) development together with 150 homes. As part of this initiative it is proposed that the scheme will have to meet the infrastructure The Faversham area and Kent Mr Philip Aelen Trustees GBH Wheler Will Trust 1960 Objection LP773 Policy ST 7 needs arising from the site’s development such as health and education facilities and provide for Downs strategy community facilities and affordable housing. These measures will serve not only to secure the restoration of this area for environmental reasons but will also enhance the sustainability of this area and provide for an expansion of the town along Ham Road. This overall strategy to focus development in this part of the town is fully supported.

It is evident that the plan as drafted does not meet the objectively assessed housing needs of the borough in full and accordingly it is considered that the identified allocations may need to be supplemented so as to cater for the minimum necessary to comply with the NPPF. Under these circumstances we submit that there should be a priority given to the urgent release of unconstrained land such as at Ham Road which can make a contribution to housing supply as a matter of urgency. Whilst the Plan subdivides the geographical areas of the District to create the ‘Faversham Area’, we would comment that the Area Policy ST7 should draw a distinction between the constituent parts of that area as follows:

Faversham Town ;

• the Area of Outstanding Natural Beauty; and • the remaining rural hinterland.

The planning approach will be different within these sub-areas and the policy wording needs to reflect these differences.

We object to first sentence: The Faversham area and Kent Mr Neil Flanagan Objection LP562 Policy ST 7 Downs strategy “Within the Faversham Area, the conservation and enhancement of the historic and natural environment are the primary planning aims.”

This wording suggests a strict limitation on new development at Faversham Town, whereas elsewhere the Draft Plan recognises the need and opportunities for new developments at an appropriate scale and location, including beyond the existing built-up area.

We would suggest that the first sentence should be deleted and replaced with text that acknowledges the three differing planning context within the ‘Faversham Area’.

Object to Item 1 - “Maintain existing land and buildings in employment use.”

Whilst good quality employment land buildings should be kept for employment use as recognised in NPPF, Paragraph 22, there are other sites and buildings which are no longer appropriate for employment use. In this respect we would comment that Proposed Policy CP1 - Item 6, D, Object / Document Name Organisation Support Rep ID Title Consultee Response Part

acknowledges that existing sites and allocations should only be safeguarded ‘where appropriately located and suitable’.

This item should be reworded, as follows:

“Existing land and buildings in employment use at ‘existing strategic employment sites’ and at ‘saved’ Local Plan allocations should be maintained”.

Item 2 - Suggest rewording:

“Deliver new employment opportunities as part of Neighbourhood Plans (where appropriate)...”

Item 3 - We support the intention to safeguard, diversify or expand the tourism focus of the area.

Item 8 - We support the acknowledgement to:

“Provide housing at allocations, and as appropriate, within Neighbourhood Plans or other appropriate locations where the role and character of Faversham and its rural communities can be maintained or enhanced.”

Item 10 states:

Accord with the Faversham Creek Neighbourhood Plan, enhancing this locality as a tourist hub and a special place of interest and activity, with strong associations with the water and improvements to the town centre.

We would suggest that cross-reference is made here to Proposed Policy NP1 which recognises a range of land uses which could be accommodated within the Faversham Creek Plan Area which extend beyond the Creek merely being a ‘tourist hub’. Whilst the Plan subdivides the geographical areas of the District to create the ‘Faversham Area’, we would comment that the Area Policy ST7 should draw a distinction between the constituent parts of that area as follows:

• Faversham Town ; • the Area of Outstanding Natural Beauty; and • the remaining rural hinterland.

The planning approach will be different within these sub-areas and the policy wording needs to reflect these differences. The Faversham area and Kent Ordnance Wharf Objection LP602 Policy ST 7 Downs strategy We object to first sentence:

“Within the Faversham Area, the conservation and enhancement of the historic and natural environment are the primary planning aims.”

We would suggest that the first sentence should be deleted and replaced with text that Object / Document Name Organisation Support Rep ID Title Consultee Response Part

acknowledges the three differing planning context within the ‘Faversham Area’.

Object to Item 1 -

“Maintain existing land and buildings in employment use.”

Whilst good quality employment land buildings should be kept for employment use as recognised in NPPF, Paragraph 22, there are other sites and buildings which are no longer appropriate for employment use. In this respect we would comment that Proposed Policy CP1 - Item 6, D, acknowledges that existing sites and allocations should only be safeguarded ‘where appropriately located and suitable’.

This item should be reworded, as follows:

“Existing land and buildings in employment use at ‘existing strategic employment sites’ and at ‘saved’ Local Plan allocations should be maintained”.

Item 2:

Suggest rewording:

“Deliver new employment opportunities as part of Neighbourhood Plans (where appropriate)...”

Item 3 - We support the intention to safeguard, diversify or expand the tourism focus of the area.

Item 8 - We support the acknowledgement to:

Item 10 states:

We would suggest that cross-reference is made here to Proposed Policy NP1 which recognises a range of land uses which could be accommodated within the Faversham Creek Plan Area which extend beyond the Creek merely being a ‘tourist hub’ . Whilst the Plan subdivides the geographical areas of the District to create the ‘Faversham Area’, we would comment that the Area Policy ST7 should draw a distinction between the constituent parts of that area as follows:

The Faversham area and Kent Faversham Town ; Gibb Femco Objection LP689 Policy ST 7 Downs strategy • the Area of Outstanding Natural Beauty; and • the remaining rural hinterland.

The planning approach will be different within these sub-areas and the policy wording needs to Object / Document Name Organisation Support Rep ID Title Consultee Response Part

reflect these differences.

We object to first sentence:

“Within the Faversham Area, the conservation and enhancement of the historic and natural environment are the primary planning aims.”

We would suggest that the first sentence should be deleted and replaced with text that acknowledges the three differing planning context within the ‘Faversham Area’.

Object to Item 1 -

“Maintain existing land and buildings in employment use.”

Whilst good quality employment land buildings should be kept for employment use as recognised in NPPF, Paragraph 22, there are other sites and buildings which are no longer appropriate for employment use. In this respect we would comment that Proposed Policy CP1 - Item 6, D, acknowledges that existing sites and allocations should only be safeguarded ‘where appropriately located and suitable’.

This item should be reworded, as follows:

“Existing land and buildings in employment use at ‘existing strategic employment sites’ and at ‘saved’ Local Plan allocations should be maintained”.

Item 2:

Suggest rewording:

“Deliver new employment opportunities as part of Neighbourhood Plans (where appropriate)...”

Item 3 - We support the intention to safeguard, diversify or expand the tourism focus of the area.

Item 8 - We support the acknowledgement to:

Item 10 states:

The positive impact of Policy ST7 (Our approach to the Faversham area and the Kent Downs) could be further strengthened to ensure development proposals coming forward in this area do not The Faversham area and Kent increase the levels of pollutants at the A2 section through Ospringe which is an Air Quality URS SA Recommendations Objection LP1606 Policy ST 7 Downs strategy Management Area (AQMA). This could be included by adding an additional criterion which expects development to not increase the levels of pollutants at the identified AQMA at Ospringe and where possible improve air quality in this area of the Borough. Amend Policy ST7 point 9 as follows: Improve Reduce levels of deprivation in Davington and East The Faversham area and Kent URS SA Recommendations Objection LP1608 Policy ST 7 Downs Wards and/or facilitate as required, increased capacity in infrastructure and services in Downs strategy accordance with the Local Plan Implementation and Delivery Schedule. The Faversham area and Kent Adrian Oliver Swale Cycle Forum Objection LP1115 Policy ST 7 point 7 encourage cycling around Faversham for tourism, school routes and commuting. Downs strategy We welcome the commitment to promote the conservation and enhancement of the natural environment as one of the principal aims within this strategy and the commitment to achieve a net gain for biodiversity. We would value further details regarding how this is to be achieved. Within the supporting text we can at present see little that will enhance the natural environment. There is mention of linked spaces between Faversham and Oare Creeks, however there is no indication that the spaces will be natural and increasing access to Oare Creeks will increase impact on the SPA/ Ramsar designation. The habitat contained within Oare Gravel Pits is known to provide supporting habitat for wintering birds and therefore cannot be counted as alternative natural open space to deflect visitors from the SPA. If development is agreed the site is likely to require rigorous mitigation measures in its own right and there is unlikely to be gains for the SPA species using the site. At Conservation Officer, Policy and The Faversham area and Kent Miss Debbie Salmon Objection LP1085 Policy ST 7 best, the value of this site to SPA species may be able to be maintained. Any increases in pressure Planning Kent Wildlife Trust Downs strategy on the SPA and residual impacts to on-site biodiversity interest would need to be mitigated by contributions to the overall Sustainable Access Managment and Monitoring Strategy.

We note however that the level of housing is relatively low within the Faversham area and therefore residential pressure will not be at the same level as at Sittingbourne or the Isle of Sheppey. It will be important that the proposed development and the increases in tourism are assessed as part of the HRA, both individually and in-combination with other development, to ensure that the location and quantum of development and rises in tourism can be accommodated without the integrity of the European designations being compromised once mitigation is in place. (See comments on site specific policies for ecological issues on individual sites.) Whilst the Plan subdivides the geographical areas of the District to create the ‘Faversham Area’, we would comment that the Area Policy ST7 should draw a distinction between the constituent parts of that area as follows:

Faversham Town ;

• the Area of Outstanding Natural Beauty; and • the remaining rural hinterland. The Faversham area and Kent Mr Michael White Objection LP649 Policy ST 7 The planning approach will be different within these sub-areas and the policy wording needs to Downs strategy reflect these differences.

We object to first sentence:

“Within the Faversham Area, the conservation and enhancement of the historic and natural environment are the primary planning aims.”

This wording suggests a strict limitation on new development at Faversham Town, whereas elsewhere the Draft Plan recognises the need and opportunities for new developments at an Object / Document Name Organisation Support Rep ID Title Consultee Response Part

appropriate scale and location, including beyond the existing built-up area.

We would suggest that the first sentence should be deleted and replaced with text that acknowledges the three differing planning context within the ‘Faversham Area’.

Object to Item 1 -

“Maintain existing land and buildings in employment use.”

Whilst good quality employment land buildings should be kept for employment use as recognised in NPPF, Paragraph 22, there are other sites and buildings which are no longer appropriate for employment use. In this respect we would comment that Proposed Policy CP1 - Item 6, D, acknowledges that existing sites and allocations should only be safeguarded ‘where appropriately located and suitable’.

This item should be reworded, as follows:

“Existing land and buildings in employment use at ‘existing strategic employment sites’ and at ‘saved’ Local Plan allocations should be maintained”.

Item 2:

Suggest rewording:

“Deliver new employment opportunities as part of Neighbourhood Plans (where appropriate)...”

Item 3 - We support the intention to safeguard, diversify or expand the tourism focus of the area.

Item 8 - We support the acknowledgement to:

Item 10 states:

We would suggest that cross-reference is made here to Proposed Policy NP1 which recognises a range of land uses which could be accommodated within the Faversham Creek Plan Area which extend beyond the Creek merely being a ‘tourist hub’. The Kent Downs area is a beautiful and valued part of the Borough. The protection of the Downs is a NPPF strategic directive. Yet in the strategy for Faversham and the Kent Downs (DLP Chapter 4) they appear to be included as an afterthought, with most of the content focussed on Faversham and Blean. The rural villages and hamlets across the AONB will all find it difficult to fund and resource The Faversham area and Kent Mr Beverley Willis Bredgar Parish Council Objection LP758 Policy ST 7 production of Neighbourhood Plans, resulting in reliance in most cases on the Local Plan. BPC Downs strategy recommends that this Chapter of the DLP should be more inclusive of all parts of the AONB.

For example, BPC proposes some simple improvements: Object / Document Name Organisation Support Rep ID Title Consultee Response Part

Add a new paragraph within the section that gives examples of the characteristics of the AONB rural communities. Taking Bredgar as an instance; a village; nestling unobtrusively within the AONB countryside; with its housing along ancient tracks, historical church and buildings, central village pond and recreation ground. Similar examples will apply for all the rural communities. Update Policy ST7 paragraph 8 to:

"Providing housing at allocations and as appropriate, within the Neighbourhood Plans or other appropriate locations where the character of Faversham and the Kent Downs rural communities can be maintained and enhanced." The Faversham area and Kent Mr Beverley Willis Bredgar Parish Council Objection LP760 Policy ST 7 Downs strategy 9.04 Update Policy ST7 paragraph 13 to:

"Ensure the landscape qualities and distinctive features of the Kent Downs AONB remain valued, secure and strengthened, alongside the local landscape designations within and around the North Kent Marshes and The Blean; and the rural communities south of the M2; and" Text- The Faversham area and Kent Mrs Jennifer Bate Planning Officer Kent Downs AONB Support LP514 Policy ST 7 ST7 point 9 Downs strategy Should this read 'Improve areas of deprivation' Or ' reduce levels of deprivation'? Policy ST 7 sets out within point 8 that the Local Plan should ‘provide housing at allocations and, as Planner Savills (L&P) Ltd (for St The Faversham area and Kent appropriate, within Neighbourhood Plans or other appropriate locations where the role and Mr William Lusty Support LP1442 Policy ST 7 John's College, Cambridge) Downs strategy character of Faversham and its rural communities can be maintained or enhanced’ in relation to development within the Faversham area. In response to the previous consultation, SBC have brought forward the Oare gravel workings site as a mixed use allocation for 150 homes and 20,000sqm of B use class employment land. The Principal Planning Officer Kent The Faversham area and Kent Council however intend to continue with the previously favoured location on land to the east of Love Miss Elizabeth Shier County Council (Planning and Support LP1142 Policy ST 7 Downs strategy Lane, which will now function as a ‘reserve’ site because of the challenges the Oare site Environment) faces. KCC supports the policy emphasis for Faversham, and the allocation of a new employment site at Oare gravel workings. Faversham is a successful town within Swale Borough, with a strong and popular housing market, relatively low levels of unemployment and a successful town centre (para. 4.5.99 of the Draft Core Strategy refers). This success has been driven in part by the town's accessibility to the strategic highways and train network, as well as its important historic and natural environment. Given these characteristics, there are significant development pressures on Faversham to grow. Policy ST7 rightfully achieves a balance between boosting the local supply of housing and employment land, whilst also seeking to preserve and enhance the historic and natural environment, via a number of measures, including the priority afforded to the use of previously developed land for development purposes. Key strategic sites are identified in Policy ST7, namely Land at the Western Link and the Oare Gravel Works. As the only two strategic sites identified at the town, the delivery of the spatial The Faversham area and Kent W.T. Lamb Holdings Ltd Support LP1599 Policy ST 7 objectives for Faversham are interlinked with the delivery of these strategic sites. Downs strategy Historically, previous Local Plans have allocated land for development at Faversham without a consideration of the mix of land uses proposed, the strength of the local commercial property market and the financial burdens placed on development by planning obligations and the necessary infrastructure requirements. This has stalled the delivery of some allocated sites within the town, which in turn resulted in the failure to deliver previous town wide strategies and objectives. A more pragmatic view has been adopted in the emerging Local Plan, with evidence base documents more carefully considering the viability of development. The strategy proposed in the Policy results in Policy ST7 providing a modest increase in the focus and scale of growth at Faversham when compared to previous Development Plans. There are however sound planning reasons for adopting Object / Document Name Organisation Support Rep ID Title Consultee Response Part

such a strategy, which include:

• The retention and development local skills;

• The development of a greater diversity and quality in employment provision;

• The achievement of a greater diversity in housing provision which will meet housing need and demand;

• To support Faversham’s role as a local tourism and cultural centre;

• Not to worsen housing affordability in the local area;

• To maintain levels of self-containment; and

• Rectify deficiencies in certain types of public open space.

This modest increase in the role and function envisaged for Faversham in the emerging Local Plan would maintain and enhance the strategic significance of the town within the eastern area of Swale Borough. Its significance stems from its geographic location, strategic connections and the wider rural hinterland to which it serves. Other key characteristics associated with the settlement include:

• Being the third largest town in the Borough, with over 13% of the District’s population (18,000 residents);

• Providing around 13% of all the District’s jobs (5,400 jobs);

• The East Kent Strategic Housing Market Assessment identifies that migration patterns into Faversham are relatively self-contained (para. 9.2.34 refers);

• Being identified as a key local service centre in local planning policy – the Local Plan identifies it as being the primary centre for eastern Swale;

• Being a major employment hub, particularly for the manufacture of food and beverages which relates to the towns long standing role in the brewing industry;

• Policy documentation identifies strengths in the leisure, tourism and culture sectors with further opportunities to develop these sectors;

• Having a retail role within the Borough as a Urban Service Centre;

• Having a range of education opportunities for all age ranges (from nursery schools through to adult education facilities);

• Having a full range of health facilities, including a cottage hospital.

• Having a full range of leisure and cultural facilities, including swimming pools, sports halls, skate parks, MUGAs, children’s playgrounds, sports pitches, a library, community centres and a cinema; and

• Having a railway station which is on the main railway line from London to Canterbury, Dover Object / Document Name Organisation Support Rep ID Title Consultee Response Part

and Ramsgate. Trains from London - Victoria normally run every half hour with a fastest journey time of 70mins. Trains from Canterbury East (journey time 15 minutes), Dover (journey time 33 minutes) and Ramsgate (journey time 37 minutes) normally run every half hour.

The strategy for Faversham as outlined in Policy ST7 has been assessed by a Sustainability Appraisal and found to be appropriate. Accordingly it is considered to be a settlement at which strategic development as outlined in the emerging Local Plan is a sound proposition. The general tenor of this policy fits with the views of the Town Council. Concerns are noted The Faversham area and Kent elsewhere on site specific policies. Ms Jackie Westlake Faversham Town Council Support LP1465 Policy ST 7 Downs strategy