Main Changes to Local Plan 2030

Strategic Development Requirements and Policy SP2 (MC4)

Pages 12 to 22 Paras 3.15 to 3.80 and Policy SP2

Update to Strategic Approach

Delete all existing paragraphs within Strategic Development Requirements (paras 3.15 – 3.80) and Policy SP2 - The Strategic Approach to Housing Delivery, and replace with the following text and new policy:

Strategic Development Requirements

The starting point for the approach is the National Planning Policy Framework (NPPF) and the guidance contained within the national Planning Policy Guidance (PPG). At its core, the NPPF sets out that there is a presumption in favour of sustainable development.

Although paragraph 14 of the NPPF defines what this means in overall terms, there are a number of references throughout the NPPF and PPG, which taken together are relevant to how this ambition is achieved. These include social, economic and environmental factors; access to infrastructure and services (or the ability to suitably provide such provision); ensuring that development can be delivered and is viable and ensuring that development is phased in an appropriate way.

The role of this Local Plan is to provide a policy framework that reflects all of these factors – effectively setting out what sustainable development is within the context of the borough. This includes specifically planning to meet the objectively assessed housing needs of the borough with flexibility. These considerations have been applied as a series of layers and have been informed by the evidence base that supports the Plan.

Objectively Assessed Housing Need

The NPPF and the supporting PPG set out that local planning authorities are required to identify their own objectively assessed housing need (OAN). It stipulates that a Strategic Housing Market Assessment (SHMA) should be the primary vehicle by which to determine the OAN figure.

In 2014, the Council commissioned consultants who prepared an NPPF compliant SHMA. This work was updated in 2015 and more recently in 2017 to take account of new and more up to date demographic projection data – an approach that is consistent with PPG.

The SHMA identifies the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period to meet household and population projections, taking into account migration and demographic changes and addressing the need for all types of housing, including affordable housing. It identifies that:

    • Ashford has a relatively contained housing market area that largely reflects the borough boundary,
    • a total of 14,934 dwellings are needed between 2011-2030 to cater for the 2014 sub-national population projections,
    • around 45% - 50% should be affordable housing.

Market signals

The National Planning Practice Guidance sets out that upward adjustments should be made to housing need figures where affordability is an issue – as is the case in Ashford. There is no nationally identified standard as to what this uplift figure should be. The 2017 SHMA takes this into account and suggests that a 5% uplift is appropriate for Ashford based on an assessment of market signals, affordability, past delivery rates and likely future delivery rates. This equates to an OAN of 15,675 dwellings being identified between 2011 and 2030, equating to 825 dwellings per annum.

Economic considerations

Another key consideration in the formation of the OAN is the relationship between housing and job creation. In 2012, the Council commissioned economic forecasting work to establish the likely growth in job numbers over the Plan period and the sectors most likely to experience expansion of employment opportunities in the local area. The forecasting reflected both macro-economic factors and more localised issues. It identified four potential economic scenarios for the borough, ranging from a ‘downside risks’ scenario at the lower end to an ‘enhanced performance’ scenario at the top end.

The initial assessment that a ‘downside risks’ scenario was most likely (reflecting a reduced rate of job growth in the borough over the Plan period) has since been reassessed by the Council based on the national economic recovery towards modest but sustained economic growth. As a consequence, a job creation rate based on a ‘baseline’ trajectory (i.e. a continuation of job creation in the borough at rates that are largely pre-recession) was considered to be the most robust and realistic scenario. The 2017 SHMA OAN figure reflects a housing target beyond that needed to fulfil this economic ambition.

Finalising a Housing Target for the Local Plan

The NPPF and supporting PPG establishes that a range of factors need to be taken into account to determine the eventual housing target for the area, to be identified through a Local Plan. The text below explains how the housing target for this Local Plan has been established.

Future proofing

The SHMA outcomes set out above already take account of some future in-migration flows to Ashford from London. However, advice received from the Council’s consultants suggests that demographic modelling for additional migration flows from the capital, of 34 dwellings per annum, could also be applied from 2017.

This reflects the current prediction by the Greater London Authority that out-migration from London will return to pre-recessionary levels soon and therefore districts with accessible links to London such as Ashford should plan for this rebalancing back to what were ‘normal circumstances’. This is considered a sound aspiration for this Plan given Ashford’s HS1 links to London.

These additional dwellings do not form part of the OAN figure. They are also not seeking to meet any unmet need from London. However, the Council considers that it is a sound planning approach to add these additional 442 dwellings to the overall housing target for the Local Plan.

Duty to Co-operate

 As mentioned elsewhere, the Council has fully engaged neighbouring Districts in the preparation of this Plan, recognising the proposed housing development strategies in the emerging Local Plans in those districts. In particular, the proposed Plans in Canterbury and Maidstone Districts, where there are very minor geographical housing market overlaps with Ashford borough, are intending to meet, at least, their respective OAN housing requirements. At the time of publishing this Local Plan, no other District has an outstanding request to this Council to assist meeting any unmet housing need in their area.

Therefore, there is no need for the housing target in this Plan to be adjusted to reflect an unmet housing need from either within the Housing Market Area or beyond.

Viability and deliverability

Although viability and deliverability are linked to aspects of social, environmental, economic and other relevant considerations (such as infrastructure provision), the NPPF makes it very clear that these are significant considerations in their own right. This includes a reasonable assessment of market conditions – both at a macro-scale and of the local housing market, including land and sales values in different parts of the borough and for varying forms of residential development, plus analysis of how different types of sites may be able to come forward for development.

The policies and strategic site allocations within this Local Plan have been assessed within the context of whole plan viability to ensure that they do not place an undue burden on developers and therefore can realistically be delivered. Flexibility is also applied within the policy framework through a policy approach which gives schemes the optimum opportunity to still come forward where viability can be independently verified as a constraint to development occurring.

In reaching an appropriate housing target for the Plan, the viability evidence supporting the Plan is clear that seeking to meet the proportion of the OAN figure that the SHMA indicates is ‘affordable housing need’ would not be viable as a policy requirement and would render residential development in the borough undeliverable.

In order to fully meet the affordable housing requirements identified in the SHMA through site allocations would necessitate an increase in the housing target of over 6,000 dwellings. In turn, this would require housing delivery hugely in excess of any annual level of housing completions the market has ever achieved in the borough. This is not a realistic or deliverable scenario, notwithstanding the significant environmental implications of this scale of growth over such a relatively short period of time.

Constraints and Context

The PPG sets out that an understanding of the strategic constraints and context of an area is relevant to the setting of an individual LPA’s housing target in a Local Plan.

Ashford’s previous role as a regional Growth Area in the now revoked South East Plan was predicated on extensive improvement of the town’s infrastructure, most notably in strategic highway capacity. Key infrastructure has been delivered in recent times (e.g. the upgrade to M20 junction 9 and Drovers roundabout). However, there remain critical constraints to strategic growth in the short term at both M20 Junction 10 and along the A28 corridor to the west of the town that directly impacts upon the scale of development that can be safely accommodated on the strategic highway network.

There are clear proposals to bring forward schemes to alleviate these constraints (see Infrastructure chapter) but the ability to bring forward some developments in Ashford in the short term is affected. Therefore, in the short to medium term, there are limitations to the scale and rate of development that can be delivered in and around Ashford – the Borough’s principal town and most sustainable location. This clearly influences the Council’s strategy for development in this Plan in terms of the phasing of housing delivery – this is covered in more detail below.

Crucially, these constraints do not mean that the overall housing target established for this Local Plan cannot be met over the Plan period, merely that there is a need to properly phase development over the early years of the Plan (see section below).

In environmental terms, the Borough enjoys a wide range of environmental ‘assets’ that contribute greatly to its overall character and attractiveness. Two Areas of Outstanding Natural Beauty are complemented by large areas of unspoilt countryside which, although without a formal landscape designation, are rightly valued in their own right. Watercourses across the Borough provide examples of rich areas for biodiversity whilst also providing natural areas for flooding along their lengths.

Natural environmental assets are complemented by the quality of the built environment with a number of attractive settlements, hamlets and farmsteads contributing to the overall character of the area. In addition, 43 Conservation Areas, over 3,000 Listed Buildings and numerous other heritage assets help to create the Borough’s rich character.

All of these environmental factors have been taken into account when determining the housing target and strategy for growth in this Local Plan.

Identifying a housing buffer

In preparing this Local Plan, the Council has liaised with landowners, developers and house-builders on a number of key sites within the Borough to ascertain their intentions on likely housing delivery rates on those sites. This is reflected in the housing trajectory Appendix 5 which supports this Local Plan.

However, these intentions relate to current market conditions and these can fluctuate over the plan period. Given this, the Local Plan identifies a supply of housing land that is additional to that needed to deliver the housing target set out below. Identifying a ‘buffer’ provides choice and competition for the market across the whole plan period, whilst remaining within the wider umbrella of sustainable development as a whole.

The housing buffer helps to provide greater certainty that the overall housing target can be delivered. It does not relate to meeting any wider unmet need, nor should it be considered part of the Council’s OAN figure. It sits outside of this figure and as such should not be used as the figure on which to base any future 5 year housing land supply calculations.

Housing Windfalls

Paragraph 48 of the NPPF allows unidentified windfall sites to be taken into account based on the Strategic Housing and Employment Land Availability Assessment (SHELAA), historic windfall delivery rates and future expected trends.

With regards to the SHELAA, over 700 sites were assessed following a ‘call for sites’ exercise in 2014, with over 200 sites progressing to the final stage of assessment.

Completions data over the last 10 years show a strong and consistent rate of windfall housing delivery with an average of 175 167 dwellings completed each year. It is highly likely that this consistent rate of delivery will continue and indeed may well be exceeded. There are a number of reasons for this:

  • the various extensions to permitted development rights via the prior approval process to allow conversions on various property types to residential use;
  • the NPPF’s presumption in favour of sustainable development; and
  • the Local Plan’s proposed windfall development policy which is more permissive than the equivalent policy in previous Local Plans.

Based on these factors it is assumed that an additional 900 units will be delivered from windfall sites between 2021 and 2030, at an annual rate of 100 dwellings per year, well below the historic trends for windfall completions. This is in addition to the 680 housing windfalls that currently have planning permission.

Within the context of the issues discussed above, the Sustainability Appraisal of the Plan has tested different levels of housing growth to assist in the determination of a housing target. This evidence shows that the full housing need of the Borough can be met through a housing target (plus a reasonable buffer) figure that is at an overall level that can still be considered sustainable within the context of social, environmental and economic factors.

The Housing Target

Based on the factors above, an overall Housing Target for the Borough of 16,120  dwellings to be delivered between 2011 and 2030 has been established. Factoring in completions since 2011, this figure is reduced to 12,943 between 2017 and 2030. The overall breakdown of this figure can be viewed under table 1 below:

Table 1 – The overall housing profile 

Objectively Assessed Need

15,675

Future Proofing

442

The Housing Target (2011-2030)

16,120

Delivered since 2011

3,177

Residual Requirement

12,943

Extant commitments (sites with permission - previously allocated sites)

2,870

Extant windfalls*

649

Chilmington  Green

2,500

Future Windfalls

900

Proposed Allocations**

7,110

TOTAL

14,029

Contingency buffer

1,086

*Those not started have been reduced by 25% to account for potential non-delivery

**Including assumed contribution from Neighbourhood Plans. 

Distribution of Housing Development

Historically, larger scale residential development in the Borough has been targeted towards the town of Ashford. All recent iterations of previous Local Plans, County Structure Plans and the South East Regional Plan gave clear and distinctive spatial guidance that focused growth towards Ashford and its immediate surroundings whilst applying a policy of limited growth to Tenterden and the main villages in the borough.

In some instances, such as the Core Strategy 2008, there have been separate and distinctive housing growth targets for Ashford and the 'rest of borough' respectively. This recognised both Ashford town's role as an economic hub in the wider south east region and the Borough, as well as the need to protect the more sensitive nature of the rural area.

The abolition of regional planning and the introduction of the NPPF and PPG changes the higher level context fundamentally. There is no longer a higher level plan that pre-determines the amount of development each part of the Borough should deliver. However, it is clear that, in principle, the strategic spatial objectives of the previous approach are sound in planning terms and represent a policy approach that clearly resonates with the NPPF and its desire to deliver sustainable development.

Various growth model scenarios have been tested through the sustainability appraisal. This evidence shows that:-

  • an appropriate balance of housing distribution is needed. Focusing most development towards Ashford and its periphery with proportionate development elsewhere provides the maximum benefits in terms of the social, environmental and economic factors;
  • moving away from the broad distribution strategy identified below can quickly lead to unsustainable development, imbalanced communities and harm to the environment;
  • the countryside is not a sustainable location for large scale development, unless certain exceptional criteria or circumstances apply which make it so within the context of the NPPF (e.g. garden cities or villages).

With the above in mind – and taking into account a number of the considerations listed in the section above relating to overall housing numbers - the following distribution of housing development is proposed.

Development at Ashford

As the Borough's principal settlement, Ashford represents the most sustainable location within the Borough and therefore where most development should be located. Ashford is home to about half of the Borough’s population and where a large proportion of local jobs are located and plans for future economic growth concentrated. There are a wide and full range of local services available within the town centre and the various neighbourhoods that make up the wider urban area and the town caters for its own residents’ needs and those living in a wider rural hinterland. The town has expanded very significantly in recent years and plays an important role in the sub-regional economy of East Kent.

Ashford has always been a well-connected town in Kent with rail connections in 5 directions but since 2009, its prime location on the HS1 rail link to London St Pancras has resulted in a step-change in reducing journey times to the capital via the major new growth locations at Ebbsfleet and Stratford. The town straddles the M20 motorway with two junctions providing quick access to the national motorway network and London or to the coastal towns, and also to the Continent via Dover and the Channel Tunnel. The Eurostar rail service provides direct international rail connections from Ashford International station to Paris, Brussels and other Continental destinations. Connectivity within the town via the regular bus services and extensive pedestrian and cycleway network is also a major attribute for new development to benefit from and contribute towards.

Aside from a limited number of development opportunities in the Town Centre (policy SP5 of this Plan), the existing urban area of Ashford provides relatively few opportunities for development on a significant scale. The major available brownfield sites in the town have been identified for redevelopment in the existing development plans, and many have planning permission or are under construction. Existing green open spaces within the urban area play important recreational and environmental roles in those neighbourhoods and so would not be suitable for allocation unless there were exceptional and specific local circumstances. Therefore, the existing urban area cannot play a major role (town centre apart) in accommodating new development outside those existing sites and allocations which may be brought forward.

The principal opportunities for new growth lie on the edge of the existing built up area of Ashford through carefully managed and planned growth. Here, although a number of well established environmental constraints exist in the form of the Kent Downs AONB and the floodplains of the Great and East Stour rivers, there are locations adjoining the town that could accommodate new development without undermining the wider environmental objectives of this Plan.

As such, a realistic scale of development on the periphery of Ashford has been identified through the allocation of a number of sites which have the ability to be well integrated with the existing town and / or committed schemes. This approach has been influenced by a number of important factors, including the implementation of the Chilmington development across the Plan period, the availability of additional motorway junction capacity that is due to be created by the construction of the proposed M20 Junction 10a and the need to ensure a consistent supply of available housing sites to cater for different elements of the market.

It is considered that a strategy that relied too heavily on a small number of very large sites, such as Chilmington Green, to achieve the Borough’s development targets would not be sufficiently flexible and instead a more balanced approach that seeks to distribute new development across more locations is preferred. This distribution also takes account of the presence of existing strategic infrastructure and services and the ability to deliver new facilities as part of new sites that can come forward in the short to medium term. Similarly, a strategy that focuses on a larger number of small sites around Ashford would fail to deliver the critical mass and a comprehensive approach to master planning and the delivery of services that larger sites can achieve.

The Strategic Road Corridors

The NPPF is clear in its desire to promote housing development which has good access to services and facilities, does not require significant infrastructure to deliver it and can be delivered early.

With this in mind, the Local Plan – following an assessment of the main road corridors which enter Ashford and the ability to maximise the use of the public transport services to Ashford this presents - identifies a few appropriately scaled housing sites near to Ashford along the A20. These sites have excellent access to the main local road network and are sites that do not adversely impact on the local landscape in a way that outweighs the benefits. Suitably scaled and designed housing development here would be consistent with the prevailing character of the built form along this part of the A20.

As part of the evolution of the Plan, the Council have confirmation from the landowners that these sites can come forward in the early years of the plan, on account of them being relatively unconstrained and by virtue of requiring little in the way of new infrastructure provision.

Providing potential development sites along this corridor introduces an additional offer to the market in terms of the types of land being promoted for development within the Borough, complementing the sites in the Town Centre, those within and adjoining the urban area and the sites on the periphery of rural settlements. Providing this variety is seen as a way of giving choice to house builders and broadening the scope of housing opportunities in the Borough.

Development at Tenterden

Although only about one-tenth the size of Ashford, Tenterden is the second largest settlement in the borough and its only other town. It plays a main rural service centre role for much of the south-western part of the borough. It is an attractive, historic town which is relatively well served by shops and services and is an important tourist destination which contributes greatly to the rural economy of the Borough.

Development at Tenterden is constrained by the High Weald AONB which surrounds it on three sides and a high quality, well-preserved Conservation Area in its heart that gives Tenterden its distinctive character. Traditionally, Tenterden has been the focus of relatively small-scale ‘organic’ growth which has been usually more on a village-type scale than the scale of allocations at Ashford. However, the Core Strategy identified increased levels of development for Tenterden and the Tenterden & Rural Sites DPD allocated a significant development area to the south of the town centre (TENT1) for which the first phase is under construction.

The high quality of Tenterden’s landscape setting and its intrinsic historic character are factors that suggest that new development in the town should be limited, phased and very carefully planned. Therefore, no more major new development is planned in Tenterden itself, apart from the completion of the master planned southern extension to the town and the permitted extension to housing at Tilden Gill Road on the Shrubcote estate. Combined, these can fulfil the town’s development needs over the Plan period without adversely affecting the character of the town.

Development at villages

The Borough is home to a wide range of smaller rural settlements which play a key part in establishing its overall character. Many lie in attractive and /or designated landscape settings and contain areas of historic value. Some fulfil a local service centre role and have a range of key local facilities such as a primary school or a post office or shop that helps to meet everyday needs.

The government’s policy for development in rural settlements has changed since the advent of the NPPF and its supporting Planning Practice Guidance. Now, the ability of development in one village to support services in a nearby village could be considered sustainable.

In line with this approach, the Local Plan proposes an allocation strategy that has been assessed against a broad range of issues, promoting suitable sites that can provide a range of housing opportunities across the Borough. This approach gives considerable weight to more ‘local’ factors and takes account of recent rates of development in different villages whilst encouraging the small-scale evolution of some smaller settlements which might otherwise stagnate. Overall, the strategy seeks to direct new development towards the most sustainable villages where services are more extensive and well established and public transport connectivity is greatest, consistent with the thrust of the NPPF.

In making Local Plan development allocations, the Council is also cognisant of several emerging Neighbourhood Plans being promoted by Parish Councils. The Council has worked closely with these parishes to ensure that their plans are consistent with the proposed strategy for development set out in this Local Plan and has encouraged them to include an appropriate scale of local development allocations in their respective Plans. The current scale of these allocations is included in the Housing Trajectory at Appendix 5.

Development in the wider countryside

One of the NPPF’s core planning principles is to recognise the intrinsic character and beauty of the countryside, although it is clear that this should not be interpreted as applying a blanket restriction on new development. Isolated new homes should be resisted, unless proposals meet the particular exception tests set out in the NPPF, but there may be scope for the potential re-use of suitable brownfield sites and there is a need to consider potential economic or tourist related development that will benefit the wider rural economy of the borough. In fact, the attractiveness of the Borough’s countryside is an important aspect of the economic potential of the Borough, especially of the rural economy, and a significant income generator for the Borough as well as providing a fundamental part of the character that makes Ashford a pleasant place to live and work.

Therefore, except for a handful of very minor site allocations dealing with gypsy and traveller accommodation and the desire to deliver some ‘exclusive’ homes within the Borough, the Council does not propose to allocate residential development sites in the wider countryside away from existing villages as such locations will be usually be more environmentally sensitive and less sustainable in respect of access to services and reasonable road or rail access. Instead, development in the countryside should be controlled through appropriate topic-related policies which are set out elsewhere in this Plan.

There are two Areas of Outstanding Natural Beauty (AONBs) in the Borough – the Kent Downs and High Weald. These are statutory designations of national importance where the conservation of the natural beauty of the landscape and countryside is the primary objective. The Council has a statutory duty to protect the character of the AONBs and major developments will not be permitted in AONBs unless there are exceptional circumstances where a need is proven, no other sites or alternative provision are available and any detrimental impact on the landscape and environment can be moderated. Also, development located outside an AONB but which would have a significant adverse effect on the setting of the AONB will also be resisted.

Phasing and Delivery

The final strand relating to the promotion of sustainable development within the Borough is its phasing and delivery.

The NPPF is clear in its desire to ‘significantly boost’ housing supply, within the context of meeting Objectively Assessed Housing needs, alongside setting out a requirement for authorities to maintain at least a 5 year housing land supply.

The NPPF is clear in its overall desire to deliver development that is sustainable and sets out that the economic, social and environmental planning roles need to work together in order to achieve this ambition. The Planning and Compulsory Purchase Act 2004 (section 39 (2)) also states that Local Plans must be drawn up with the objective of contributing to the achievement of sustainable development.

The phasing and delivery strategy for this Local Plan is explored below and has been informed by various layers of evidence. It should be read in conjunction with the distribution strategy above and the housing trajectory that supports this Plan, see Appendix 5?*

The Borough’s profile

Ashford Borough contains two distinct areas that exhibit clear and differing characteristics in planning terms. Ashford is clearly the most sustainable location within the Borough and therefore the most suitable location at which to deliver the majority of new housing growth. In comparison, the Borough’s rural area is much more sensitive and too much housing growth would quickly lead to an unsustainable model of housing development overall.

These characteristics are clearly evidenced in the accompanying Sustainability Appraisal to this Plan and are reflected in the Plan’s distribution strategy which identifies new housing land allocations to deliver around 5,865 dwellings in and around Ashford and 1,245 dwellings in the rural parts of the Borough.

Any significant divergence from this broad approach, i.e. transferring major housing growth from Ashford to the rural parts of the Borough should be avoided. Doing so would result to an unsustainable model of development by:  

  • being poorly served by sustainable modes of transport, leading to significantly more trips being made by private car,
  • not making best use of infrastructure that has been delivered or is about to be delivered at Ashford, including HS1 and strategic road improvements,
  • being more removed from the local jobs market which is focused at Ashford,
  • being located near to services and facilities that may only meet local needs, as opposed the range of key services and facilities at Ashford,
  • running contrary to the roles and character of different areas by shifting the focus away from where growth and change has previously been planned – and where substantial infrastructure investment has been targeted - to providing a step change of housing levels in the rural area, areas which have incrementally and organically grown steadily over time,
  • damaging the intrinsic beauty and character of the countryside,
  • damaging the nature and character of the rural settlements with a scale and pace of housing that is not proportionate,
  • undermining the sound planning aspirations for Ashford and the benefits to be delivered through increased housing growth in a way that provides sufficient critical mass to deliver new strategic facilities for the town, including two strategic parks and the wider services and facilities present which benefit the wider borough.

The urban housing market

Accepting that Ashford and its periphery is the most sustainable location on which to target significant levels of housing growth in the Borough, the realistic ability of the market to deliver this growth must be considered.

Recently, housing completion rates in and around Ashford have not come forward as originally envisaged, despite full and up to date Local Plan coverage over many years. This is mainly due to the wider macro-economic downturn that affected the general housing market from 2008 and restrictions on the capacity of the strategic road network, in particular until Junction 10a is in place. Other factors, including site-specific issues, viability concerns and market confidence in the Town Centre due to lower land values were also relevant.

However, many of these issues have, or are now being, overcome. Market confidence is returning and - as of May 2017 - many key brownfield sites in the town centre have planning permission and some are under construction. Others are in advanced discussions with the council. Also, the major urban extension at Chilmington Green is now under construction.

It is clear that the recent constraining factors to housing delivery at Ashford are beginning to subside. However, it is accepted that housing completion rates may not increase rapidly as it will take time for the market to continue to improve. A number of key sites are also still constrained until such time Junction 10a is in place (due to be completed in mid 2019).

The phasing strategy in this Local Plan is cognisant of this position in that it predicts a lower level of housing delivery rates in and around Ashford in the early years of the Plan (pre Junction 10a) with a steady increase around in the early 2020s. This is considered to be a realistic and deliverable scenario and is consistent with developer’s and house-builder’s known assumptions and intentions.

Basing a strategy on an immediate major step change in the delivery of housing in the early years of the plan, far in excess of what has been delivered, on average, annually in the past, would be inappropriate and unrealistic. There is little doubt that the urban area will be able to achieve the increase in housing numbers that is required, but it will take time to fulfil this ambition and therefore needs to be given every opportunity to succeed.

The rural housing market

The rural housing market in the Borough has been and continues to be strong. Market evidence points strongly towards a healthy demand for new residential development in the rural parts of the Borough as supported by market viability evidence that underpins this Plan. The 2008 housing delivery target for the rural area, as set out in the Core Strategy, has been delivered, in effect, some 5 years early.

The phasing strategy in this Local Plan recognises this position in that it reasonably assumes the majority of rural housing allocations will be delivered in the early years of the Plan, mostly within the first 5 years. There are no significant infrastructure constraints to restrict these new dwellings from coming forward and none are of such a scale that individually - or cumulatively – would warrant a settlement specific phasing approach to mitigate their impact.

Frontloading a number of rural housing allocations in this way also helps ensure that the annualised housing supply numbers for the wider Borough in the early years of the plan are maintained at a reasonable level prior to the resolution of the market and infrastructure constraints on delivery in the short term at Ashford.

Rectifying the housing shortfall since 2011

As of April 2017, the Borough has a housing delivery shortfall of around 1,770 dwellings which demonstrates that, except for 2015/16, housing completion rates in the Borough have not kept pace with the annual requirement for new housing indicated by the updated SHMA.

However, the Local Plan provides the opportunity to address this position and determine a robust and sustainable approach to rectify this shortfall - one which reflects local circumstances and character.

As referred to above, it is questionable how realistic it is to rely on the Ashford urban housing market to achieve a short term step change in housing delivery needed to meet the housing shortfall in the early years of the Plan. It is also doubtful that the industry will be able to deliver such an increase in housing completions in such a short space of time. This would require securing a local workforce, building materials and immediate financing arrangements at a time when the local market is still recovering and remains in competition with other areas in the south east.

The only alternative option therefore would be to require the rural area to rectify the housing shortfall, entirely on its own. Such an approach would lead to over 2,000 additional new dwellings in the rural area, significantly more than has been planned through this Local Plan and evidenced as being sustainable through the sustainability appraisal.

Paragraphs X and X (within the Borough’s Profile section above) of this Plan demonstrate why such an approach is not appropriate or sustainable. The Strategic Housing and Employment Land Availability Assessment (SHELAA) shows that there is very little scope to deliver new housing growth within the confines of rural settlements. Therefore, significant amounts – way above what is already being allocated – of greenfield land would need to be released in a way that would fundamentally harm the countryside and the attractive character of the rural area.

As the Plan identifies more land for residential development than is needed to meet the Plan’s overall housing target, and adopts a pragmatic and realistic approach to housing delivery in Ashford, there is no justification for allocating significantly more land in the less sustainable locations which would seriously affect the Borough’s character. The housing trajectory (Appendix 5) of this Plan indicates that major sites in Ashford are likely to come forward in the early part of the 2020s as strategic infrastructure constraints are resolved and the local housing market broadens in response to the connectivity of the town via HS1 and the M20. This should mean the current shortfall in delivery since 2011 has been fully rectified by the mid 2020s, well before the end of the Plan period without the need to resort to further unsustainable short-term releases of land in the Borough’s villages and countryside.

However, to achieve this outcome it is necessary for the strategy to assume that the shortfall is technically addressed over the whole of the remainder of the Plan period – commonly referred to as the ‘Liverpool’ approach - in order for the Council to be able to demonstrate a deliverable 5 year housing land supply in the short term. This approach ensures the integrity of the Council’s strategy for addressing the shortfall in a sustainable way can be properly maintained and that unrealistic annualised levels of housing completions are not required from the start of the Plan, merely as a means of meeting an existing shortfall that can be better and more sustainably phased and located elsewhere in the Borough over the Plan period.

Dealing with any future housing shortfall

The scale of allocations proposed in this Plan should ensure that there will be no significant housing shortfall in the future. However, in the event of a housing shortfall being identified in the future, the following considerations will be applied.

Although this Local Plan does not propose separate policy based housing targets for different parts of the Borough, unlike in some previous Plans, it is clear that there are very different policy priorities for Ashford and its periphery which focuses on managing and sustaining growth, in comparison to the rural area which focuses on managing small scale change in a way that protects the Borough’s attractive rural character. This is reflected in the overall scale of new dwellings proposed for each planning area (see policy SP2 below).

These respective priorities should be used as a guide by the developer and decision maker as to the way in which the Local Plan approach should be applied; namely that there should not be significant substitutions of housing numbers away from Ashford and its periphery to the rural parts of the Borough.

It is not the case that each planning area should maintain its own five-year housing supply, as this will continue to be calculated on a Borough basis. However, if a Borough housing shortfall in supply occurs as a result of significant non-delivery within Ashford and its periphery, the variances in policy emphasis between the two planning areas will need to be weighed according, alongside the need to improve housing land supply and meet housing needs.

Housing numbers across the Borough will be monitored annually. If a significant housing shortfall against the Local Plan target becomes apparent, and housing trends suggest that this will not be a short term issue, the Council will seek to implement the review of the Local Plan earlier than expected (currently expected to be adopted in 2025) as a means of ensuring that a plan-led solution can be delivered to rectify the situation.

Policy SP2 – The Strategic Approach to Housing Delivery

A total housing target of 12,950 net additional dwellings applies for the Borough between 2017 and 2030. In order to achieve this target, additional housing sites are proposed to provide choice and competition in the market up to 2030.

The housing target will be met through a combination of committed schemes, site allocations and suitable windfall proposals.  

The majority of new housing development will be at Ashford and its periphery, as the most sustainable location within the Borough based on its range of services and facilities, access to places of employment, access to public transport hubs and the variety of social and community infrastructure available. With this in mind, in addition to existing commitments, new land allocations to deliver 5,865 dwellings are proposed.

Development in the rural areas will be of a scale that is consistent with the relevant settlement’s accessibility, infrastructure provision, level of services available, suitability of sites and environmental sensitivity. With this in mind, in addition to existing commitments, new land allocations to deliver 1,245 dwellings are proposed.

Windfall housing development will be permitted where it is consistent with the spatial strategy outlined above and is consistent with other policies of this Local Plan, in order to ensure that sustainable development is delivered.