THE PROPOSED ALLOCATION OF BOTH SITES We set out below the justification for the allocation of both sites before providing specific commentary on each proposed allocation. Both sites are close to the village centre of Charing and the shops and services within it, including the primary school and railway station. Both are sustainable locations for new development. It is evident that both sites are well contained and represent a logical and contained expansion of the village. Draft Policy HO

Policy HOU6 – Self and Custom Built Development Whilst we support the need for self and custom built homes, there is no evidence included in ABC's evidence base to set out how the threshold of 5% was reached. It is considered that with ABC setting such arbitrary figures, it could delay sites coming forward together with making developments unviable.

Policy HOU5 - Residential windfall development in the countryside We suggest the Policy is too restrictive as for a non-isolated site in the countryside to be permitted for development, it must pass 9 separate tests. We suggest that the following tests are in particularly very restrictive: a. the scheme is for 3 dwellings or less, b. the site is currently brownfield or has an agricultural building on site and that any building on site is no longer used and has been in situ for a number of

Policy HOU4 – Residential Development in the rural settlements Whilst Policy HOU4 suggests minor residential development and infilling of a scale that can be easily integrated into the existing settlements such as Charing is acceptable, we object to the reference of 'minor'. Should sites be sustainably located that are of a scale to the surrounding area, can be easily integrated into the existing settlement and are available, viable and suitable for development now, they should be brought f

Village Allocations The village of Charing has two proposed residential allocations (Policy S28 and Policy S29). Whilst we do not object to these allocations, we consider there are two other sustainable sites that should be allocated for residential development in Charing. Paragraph 55 of the NPPF makes it clear that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. We consider that the allocati

Ashford Site Allocations Whilst we understand why ABC has sought to direct much of the housing growth to Ashford, this results in a spatial development strategy that is over reliant on housing development on complex brownfield sites. This strategy is flawed because it will lead inevitably to a shortfall in housing supply. It is proposed that ABC should bring forward a more balanced spatial development strategy that promotes development in other sustainable locations, such as Charing.

Policy SP1 – Strategic Objectives It is suggested locations such as Charing that are acknowledged by ABC to be suitable for residential allocations (paragraph 4.296) should be the focus of housing development owing to their sustainability. It is not appropriate to impose an arbitrary control on the amount of development in these locations.

FULL OBJECTIVELY ASSESSED HOUSING NEED The NPPF requires at paragraph 47 that local authorities should: • 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, • Identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their requirements, and • Identify a supply of specific, developable sites or broad locations for

SUSTAINABILITY APPRAISAL Our Client has concerns about the way in which the different scenarios are assessed against the Sustainability Appraisal (SA) objectives, over reliance on an out of date Strategic Housing and Employment Land Availability Assessment (SHELA) and the fact that the scoring system considers only urban and not rural areas. If the SA does indeed rely on the SHELA, then a further call for sites should have been completed now.

DUTY TO CO-OPERATE Although the Local Plan asserts at paragraph 2.5 that the Duty to Cooperate has been applied, there is no evidence of this, and therefore our Client must register an objection to this and reserve the right to submit further representations once the Duty to Cooperate document is made available. This is important because it will indicate how ABC is responding to unmet housing needs across the market area.