Local Plan to 2030 - Main Modifications September 2018

Main Modifications to Ashford Local Plan

Policy SP2 - Strategic Approach to housing delivery (MM3)

Amend the relevant paragraphs of the supporting text to read:

3.17 Market signals 3.17.1 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. Lower quartile affordability ratios have recently increased in the Borough and the Council is also conscious of the need to plan for the continuing net out-migration from London to the Borough based on the excellent connectivity by road and rail to Ashford. As a consequence, the OAN includes a market signals uplift of 13% above the demographic projection data. This equates to an OAN of 15,675 16,872 dwellings being identified between 2011 and 2030, equating to 825 888 dwellings per annum.

3.20 Future proofing 3.20.1 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.

3.20.2 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.

3.20.3 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.

3.25 Housing Windfalls 3.25.4 Based on these factors it is assumed that an additional 950 1000 units will be delivered from unidentified windfall sites between 2021 2022 and 2030, at an annual rate of 100 125 dwellings per year, well below the historic trends for windfall completions. This is in addition to the 749 996 dwellings on housing windfalls sites that currently have planning permission at 1st April 2018, of which only 75% of those not yet commenced are counted against meeting the overall Plan’s housing target.

3.26 The Housing Target 3.26.1 Based on the factors above, an overall Housing Target for the Borough reflecting the OAN of 16,120 16,872 dwellings to be delivered between 2011 and 2030 has been established. Factoring in completions since 2011, this figure is reduced to 12,943 13,118 between 2017 2018 and 2030. The overall breakdown of this figure can be viewed under Table 1 below.

Replace Table 1 – Overall Housing Profile with the following:

Objectively assessed need


Delivered since 2011


Residual requirement (2018-30)


Extant commitments (previously allocated sites with permission)


Extant windfalls*


Chilmington Green


Future unidentified windfalls


Local Plan Allocations


Neighbourhood Plan Areas




Contingency buffer


*Those not started have been reduced by 25% to account for potential non-delivery with the exception of Tilden Gill, Tenterden

Delete section 3.29:

3.29 The Strategic Road Corridors

3.29.1 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.

3.29.2 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.

3.29.3 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.

3.29.4 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.

Amend sections 3.31, 3.34, 3.35 and 3.37 as follows:

3.31 Development at villages

3.31.3 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 a greater scale of 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, whilst accepting that smaller scale development can potentially be accommodated in smaller villages subject to local factors.

3.31.4 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.

3.34 The borough’s profile

3.34.1 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.

3.34.2 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 5,159 4,872 dwellings in and around Ashford and 1,590 1,017 dwellings in the rural parts of the borough. In addition, Neighbourhood Plan areas proposed rural allocations of 216.

3.35 The urban housing market

3.35.4 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 as Junction 10a is in place (due to be completed in mid 2020 opened to traffic in Autumn 2019).

3.35.5 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 to steadily increase over the next few years following the completion of Junction 10a and the emergence of flatted schemes in the town centre as investor confidence grows 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 developers’ and house-builders’ known assumptions and intentions.

3.37 Rectifying the housing shortfall since 2011

3.37.1 As of April 2017 2018, the borough has a housing delivery shortfall of around 1,770 2,462 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 OAN updated SHMA.

3.37.2 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.

3.37.3 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.

3.37.4 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 much more new housing 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.

3.37.7 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. Consequently, and having regard to the need to complete Junction 10a before major developments can be occupied, the Plan is based on a strategy that would rectify the existing shortfall (at 1st April 2018) over the course of the next 7 years (i.e. 2018-25) at an average rate of 352 dwellings per annum and this should be reflected in the calculation of five-year housing land supply over this period. 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.

Amend Policy SP2 - The Strategic Approach to Housing Delivery as follows:

A total housing target of 12,950 13,118 net additional dwellings applies for the Borough between 2017 2018 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 5,159 4,872 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 1,590 1,017 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.

For the purposes of calculating 5 year housing land supply, the shortfall in housing delivery between 2011 and 2018 shall be rectified over a 7 year period to 2025 at an average of 352 dwellings per annum. Over this period, this figure should be added to the annualised OAN requirement to provide an annual housing target of 1240 dwellings plus any relevant buffer. From 2025 onwards, the housing requirement should then reflect the annualised OAN requirement plus any relevant buffer.