Local Plan to 2030 Regulation 19 - Publication June 2016

Local Plan to 2030 - Publication Draft

Strategic Development Requirements

The strategic approach to housing and employment delivery

3.15 This section of the Local Plan outlines the strategic approach to housing and employment delivery up to 2030 setting out the overall housing and employment requirements, the approach to the strategic distribution of development around the borough and how this development should be delivered and phased.

3.16 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.

3.17 Although the NPPF and PPG do not explicitly define what this means, there are a number of references, 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.

3.18 The role of this Local Plan is to provide a policy framework that considers all of these factors – effectively setting out what sustainable development is within the context of the borough. These considerations have been applied as a series of layers and been informed by the evidence base that supports the Plan.

The overall housing requirement

3.19 Strategic Housing Market Assessment (SHMA):   The NPPF sets out that a Strategic Housing Market Assessment (SHMA) is the primary vehicle by which local planning authorities should assess their housing needs.  This involves identifying 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. The Objectively Assessed Housing Need (OAN) derived from the SHMA provides the starting point for the derivation of the Plan’s housing target but the final target is based on a number of other considerations, outlined below.

3.20 In 2014, the Council commissioned specialist consultants to prepare an NPPF-compliant SHMA. This work was updated in 2015 to take account of new and more up to date demographic projection data. The SHMA identifies:

  • that Ashford has a relatively contained housing market area that largely reflects the borough boundary;
  • a total OAN of 13,813 dwellings between 2011-2030. This figure includes a small uplift to accommodate ‘market signals’ as recommended through the PPG;
  • of this total, 6,253 dwellings should be 'affordable[1] ' which equates to around 45% of the overall figure.

3.21 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 LPAs housing target in a Local Plan.

3.22 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. Whilst some key infrastructure has been delivered in recent times (e.g. the upgrade to M20 junctions 9 and Drovers roundabout), there remains critical constraints to strategic growth at both M20 Junction 10 and along the A28 corridor to the west of the town. There are clear proposals to bring forward schemes to alleviate these constraints (see Infrastructure chapter) but, in the short to medium term, there are limitations to the scale of development that can be safely accommodated on the strategic highway network which will influence the council’s strategy for development in this Plan.

3.23 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.

3.24 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.

3.25 Whilst infrastructure provision clearly remains a significant issue, this Local Plan – supported by the Infrastructure Delivery Plan and CIL charging schedule that has been produced in tandem – provides a policy framework that takes these constraints into account. In itself, these constraints do not mean that the OAN housing figure cannot be met over the Plan period but that there is a need to properly phase development and ensure the balance of development across the borough is controlled over the Plan period to take account of these constraints and the time necessary to resolve them. This is covered in more detail below.

3.26 Economic considerations: Another key consideration in the formation of the housing target in this Plan 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. This is described in more detail below but 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.

3.27 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 general move out of recession and 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 and that the housing target should be adjusted to reflect this conclusion. Consequently, a marginal uplift from the OAN based level of housing need is justified.

3.28 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.

3.29 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.

3.30 Future-proofing:- Advice received from the Council’s consultants suggests that demographic modelling of potential future in-migration flows to Ashford from London would equate to an average increase on the OAN figure in the SHMA by 55 dwellings per annum. This figure is not part of the OAN as some elements of in-migration from London are already accounted for within the ‘baseline’ 727 p.a. figure above. However, the current prediction by the Greater London Authority is 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 to be a sound and prudent aspiration for this Plan given Ashford’s HS1 links to the London. As this relates to a future return to this level of migration, the suggested uplift should relate to the plan period following the adoption of this Plan, i.e. from 2017 onwards.

3.31 Viability and deliverability: Although viability and deliverability is 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 boroughs and for varying forms of residential development, plus analysis of how different types of sites may be able to come forward for development.

3.32 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 generic policy approach which gives schemes the optimum opportunity to still come forward where viability is an accepted issue.

3.33 In reaching an appropriate housing target for the Plan, the viability evidence supporting the Plan is clear that seeking to meet the 45% 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 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 considered to be a realistic or deliverable scenario notwithstanding the significant environmental implications of this scale of growth over such a relatively short period of time. The policy for affordable housing, including starter homes, is set out in policy HOU1.

3.34 Sustainability appraisal: Within the context of the issues discussed above, the Sustainability Appraisal of the Plan has tested a number of different levels of housing growth to assist in the determination of a housing target. This evidence showed that the optimum range for a housing requirement figure that could be considered sustainable within the context of social, environmental and economic factors suggested a target based on meeting the borough’s overall OAN figure plus a small percentage uplift to allow for some flexibility in delivery rates across both allocated and committed sites identified within the Local Plan.

Conclusion

3.35 Based on the consideration of all of the above factors, an overall housing requirement of 14,680 dwellings is proposed to be delivered in the Borough between 2011 and 2030.

3.36 Table 1 sets out how this requirement is proposed to be met.

Table 1 - Meeting the Housing Requirement

Total Requirement (2011-2030)

14,680

Delivered since 2011

2,481

Residual Requirement (2016-2030)

12,200

Extant commitments (previously allocated sites)

2572[1]

Extant windfall commitments

445[2]

Town Centre policy area contribution

1,080

Chilmington Green

2,500

Future windfalls without planning permission

1000

Proposed allocations

5010

TOTAL 

12,600

 

3.37 [1] Source HIA 2014/15

3.38 [2] Total extant windfalls reduced by 25% to take account for non-delivery

3.39 Housing completions in the borough from April 2011 to March 2016 have totalled 2,481 dwellings leaving a net target of 12,200 additional dwellings to be completed within the Borough by April 2030.

3.40 There are 2572 dwellings expected to be delivered through extant permissions on previously allocated sites. In addition to this 445 dwellings are expected to be delivered from extant permissions on windfall sites (this takes into account a 25% reduction in total extant windfall permissions to account for potential non-delivery).

3.41 A contribution of 1,080 units are expected to be delivered through proposals coming forward on key brownfield sites within the town centre policy area.

3.42 As set out in the housing trajectory at Appendix 5 of this Plan, Chilmington Green is assumed to deliver 2,500 units across the plan period.

3.43 In addition, 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.

3.44 Completions data over the last 10 years show a strong and consistent rate of windfall housing delivery with an average of 144 dwellings completed each year. It is considered to be 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.

3.45 Based on these factors it is assumed that an additional 1000 units will be delivered between 2020 and 2030, at a annual rate of 100 dwellings per year, well below the historic trends for windfall completions even though this historic trend is likely to be exceeded.

3.46 This leaves a residual housing requirement figure of 4,602 dwellings to meet the overall housing target. Consequently, this Local Plan allocates sites for in the region of 5010 dwellings; 4,445 in Ashford urban area, and 566 in the villages.

3.47 Adopting this approach effectively provides for a buffer. This is considered to represent a sound planning approach as it gives the housing market some choice over the delivery of sites but also some contingency should some sites not come forward as planned.  

Distribution of Housing Development

3.48 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.

3.49 The abolition of regional planning and the introduction of the NPPF and PPG changes the higher level context somewhat. 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 context of the NPPF and its desire to deliver sustainable development.

3.50 The sustainability appraisal: 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 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 criteria or circumstances apply which make it so within the context of the NPPF;

3.51 With the above in mind – and taking into account a number of the considerations listed under the ‘housing requirement’ section above - the following distribution of housing development is proposed.

3.52 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 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.

3.53 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 M25 and London or to the coastal towns and 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.  

3.54 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, 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. 

3.55 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 seriously undermining the wider environmental objectives of this Plan.

3.56 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.

3.57 It is considered that a strategy that relies 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 masterplanning and the delivery of services that larger sites can achieve.

3.58 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.

3.59 Development in 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 previous 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 now has planning permission.

3.60 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. Piecemeal allocations would not be an appropriate response and therefore  major new development in Tenterden is limited to the completion of the masterplanned southern extension to the town which can fulfil the town’s development needs over the Plan period without adversely affecting the character of the town.

3.61 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.

3.62 The government’s policy for development in rural settlements has changed since the advent of the NPPF and its supporting Planning Practice Guidance. In para.55 of the NPPF, the ability of development in one village to support services in a nearby village is cited as an example of sustainable development in the rural areas and the practice guidance states that “all settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence”.

3.63 In line with this approach, the Local Plan proposes an allocation strategy that has been assessed against a broad range of issues, promoting optimum 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.

3.64 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.

3.65 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.

3.66 However, except for a handful of very minor site allocations dealing with gypsy and traveller accommodation and ‘exclusive’ homes, the council does not propose to allocate residential development sites in the wider countryside away from existing villages as such a location 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.

3.67 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 nation’s 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

3.68 The final strand relating to the promotion of sustainable development within the Borough is its phasing and delivery. These are crucial aspects to consider, particularly in the rural parts of the borough where it is more sensitive and too high a level of housing growth can quickly lead to unsustainable development that is inconsistent with the aims and objectives of the NPPF. In light of this, an identification of how housing development is envisaged to come forward over the Plan period is outlined in the housing trajectory which supports this Plan (see appendix 5) which has taken into account a number of important factors.

3.69 The spatial context and past completions: The proposed spatial distribution strategy for new housing in this Plan reflects the most sustainable model of housing delivery for the borough taking account of key social, economic and environmental considerations and following the outcomes of the Sustainability Appraisal process. This strategy is reflected in the site allocations identified in this Local Plan and it is expected that future windfall development will also follow these broad principles and in doing so be consistent with the policy framework of this Local Plan.

3.70 Underpinning this strategy needs to be a realistic and deliverable set of proposals that provide the best opportunity to meet the Plan’s housing targets in a sustainable way.

3.71 In the past, especially the period since 2008, market evidence points strongly to a continuing and healthy demand for new residential development in the rural parts of the borough. The Core Strategy target for housing delivery in the rural areas has, in effect, been met some 5 years early.

3.72 In contrast, allocated sites in and around Ashford have not come forward at the rates necessary to meet housing targets despite full and up to date Local Plan coverage over many years. There are several reasons that explain this ranging from the effects of the wider macro-economic downturn that affected the general housing market, to site-specific issues of infrastructure constraints or viability holding up the commencement and subsequent progress of sites. For the major brownfield sites close to Ashford town centre, market confidence has only just returned to levels where developers are starting to bring proposals for these sites forward. The viability evidence supporting this Plan bears this contrast out.

3.73 The Local Plan therefore needs to ensure its policy framework strikes the right balance between what are two potentially competing aspirations in the NPPF – the aspiration to “significantly boost the supply of housing “ and the aspiration to deliver ‘sustainable development’. In general, it is the less sustainable parts of the borough that are most attractive to the housing market and provide the best returns for landowners and developers.

3.74 The Planning & Compulsory Purchase Act 2004 (section 39 (2)) and the NPPF (paragraph 151) states that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. A strategy that focused the delivery of housing in the rural parts of the borough would fail to achieve this be likely to result in many sporadic developments which together would seriously undermine the character and environmental assets of the borough. Hence, a balance should be found with a strategy that seeks to deliver new housing principally in areas that are best served by infrastructure, jobs and services or which have the means to deliver them, and is aspirational but realistic in terms of viability and deliverability.

3.75 Meeting 5 year housing land supply: The NPPF (paragraph 47) requires local planning authorities to maintain at least a 5 year housing land supply against Local Plan targets. In recent years, except for 2015-16, housing completion rates in the borough have not kept pace with the annual requirement for new housing indicated by the SHMA or the proposed target in policy SP2 below.

3.76 The housing trajectory sets out a realistic timescale for the delivery of housing from committed sites and those allocated for development in this Plan, plus an assessment of windfall development on an annual basis. This takes account, in particular, of the timetable for the proposed M20 Junction 10a scheme indicated by Highways England, and the strategic constraint on the ability to fully develop out some sites until Junction 10a is in place.

3.77 The trajectory suggests that it will be unrealistic to expect completion rates over the next five years to be high enough to meet the annualised housing target for this Plan and also recover the accumulated shortfall against the OAN requirement since 2011. In order to achieve this, it would require a significantly greater scale of residential allocations across the rural part of the borough, which would greatly undermine the legitimacy of the strategic model for sustainable development in the borough which underpins the Plan.

3.78 Therefore, it is proposed that any accumulated shortfall in housing provision since 2011 is planned to be rectified over a period of longer than 5 years. The trajectory suggests that a more realistic and deliverable aim will be achieve this by 2023/24 thus enabling housing growth to be contained within the scope of the strategic principles of the Plan and to genuinely constitute sustainable development.

3.79 In order to achieve the Plan’s objectives for the distribution of housing development, policy SP2 identifies that a minimum proportion of new housing development in the borough should be located in Ashford or on allocated sites on its periphery, with the balance attributed to the rest of the borough. The council accepts that there should be limited flexibility of 10% around these proportions to aid housing delivery rates but in general it would be unacceptable for significant additional housing development in the rural areas to substitute for housing development in and around Ashford itself.

3.80 Should a significant deficit in housing delivery remain in place by April 2021, then this would be dealt with via an earlier formal review of this Local Plan so it can tackle the issue in a controlled and plan-led way – a fundamental principle of the NPPF. Annual monitoring will ensure that the housing strategy remains up to date and on target and supports the market in a way that continues to deliver sustainable development. 

Policy SP2 - The Strategic Approach to Housing Delivery

 

A total of 12,200 dwellings will be delivered in the Borough between 2016 and 2030 through a combination of committed schemes, proposed allocations and windfall developments.

The majority of new housing development will be focused at Ashford as the most sustainable location within the Borough based on its range of services and facilities, level of population and jobs, access to public transport hubs and the variety of social and community infrastructure available. With this in mind, land for a minimum of 10,125 dwellings in and around Ashford is identified, including land allocations for around 4,445 dwellings.

More limited development – at a scale that is consistent with their accessibility, infrastructure provision, level of services available, suitability of sites and environmental sensitivity – will take place on sites in the rest of the borough. With this in mind, land for the delivery of 1,030 dwellings is identified, including new land allocations for around 565 dwellings. 

Windfall housing development will be permitted where it is consistent with the spatial strategy outlined above and is consistent with policies HOU3, HOU4 and HOU5 of this Local Plan, in order to ensure that sustainable development is delivered. 

1. This need was calculated prior to the introduction of starter homes and therefore relates to traditional forms of affordable housing. [back]

The Economy and Employment Development

Current position

3.81 With the growth of the town over the last few decades, the Borough’s economy has grown, stimulated by critical drivers such as the introduction of International and domestic services on High Speed 1, transforming Ashford’s location and connectivity. Enhancements to key road infrastructure such as junctions 9 and 10 on the M20 have enables employment land to continue to come forward in developments such as Orbital Business Park and Eureka Business Park. With the growth in population within the town, expansion of the retail and leisure offer has also delivered new jobs to the area with the introduction and now planned expansion of the Designer Outlet Village, the extension to County Square, the development of the offer at Eureka Leisure Park, and the introduction of brands such as Waitrose and John Lewis.

3.82 Ashford has traditionally had a very high employment rate within the area with lots of residents in employment (80%+), but the challenge has been improving the low average earnings levels, and bringing more highly skilled employment to the area. Average gross weekly wages have increased in the last 5 years above the local and regional averages, with increases of 5.7% from £479.10 in 2009 to £506.30 in 2014 for residents in Ashford borough. This is a stronger growth rate than Kent at 4.5% and the wider South East region at 5.6%. This shows positive progress for this continued challenge in improving the local productivity and prosperity of the labour market.

The Key Drivers for Growth in the Borough

3.83 The aspiration is for Ashford Borough to play a key role in terms of economic development in Kent, and this is built around its strategic location, excellent transport links, competitive costs, and the quality of lifestyle for residents and employees.

3.84 Location - The key driver for employment growth within the Ashford Borough is the impact of the introduction of HS1 and the critical investment in transport infrastructure. Ashford’s business advantage is its location, as demonstrated through the results of the last Locate in Kent Perception Survey, which highlighted Ashford as Kent’s number 1 business location.

3.85 HS1 -The impact of a 38 minute journey time to London, Kings Cross / St Pancras will result in companies moving operations out of London to Ashford, but will also result in Kent companies locating to Ashford to take advantage of its central location within Kent and proximity to London.

3.86 International Links - Ashford is also the UK’s International town, with direct train services to France’s three largest cities, Paris, Lyon and Marseille, as well as to Brussels, Lille, Avignon and Disneyland Paris. With the tax and labour force advantages that the UK provides, Ashford continues to see the relocation of French companies into the area providing jobs and investment.

3.87 Highly Competitive – With commercial property costs up to 73% lower than central London, Ashford provides a real alternative for companies who want to do business within the capital, but without the continually rising costs.

3.88 The importance of Place Making – A key challenge over the next 15 years for Ashford will be the importance of developing the town into a memorable and sought-after location. Ashford already has many recognised benefits, but it’s town centre and external image make the attraction of investment a continual challenge.  The importance of quality place making through good design and streetscape will continue to be important in changing this image and attracting more employment and wealth to the area.

3.89 Broadband infrastructure – potential for strong broadband infrastructure available in parts of the Borough to attract investment, and support development of digital/ new media sectors will be critical in delivering greater productivity and prosperity within the local economy.

3.90 Rural Enterprise - Although the majority of employment growth will be centred around the Ashford Urban area, rural economy opportunities for development of rural enterprise, capitalising on quality of life and accessibility, and including the tourism economy, will ensure an enterprising and dynamic borough with a choice of employment locations and a choice in the price of accommodation.

Economic forecasting

3.91 The NPPF requires the Council to use evidence to define the full, objectively assessed needs for both business and housing in their areas and then seek to ensure that their Local Plans meet the needs identified.

3.92 In terms of business development the Council commissioned GL Hearn to carry out a Strategic Employment Options Report (SEOR) that developed a number of scenarios for economic growth in Ashford borough to 2030 that would be used to set a jobs target to be included within this Local Plan. There were 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. This work was prepared in 2012 when economic conditions in the UK were significantly worse than they are now.

3.93 At the time, GL Hearn were suggesting that the ‘downside risks’ jobs scenario had the greatest probability of playing out based primarily on the macro-economic risks to the wider global economy creating weaker prospects for growth over a longer period of time. This was predicted to result in job growth of 9,200 (16%) between 2011-30.

3.94 In general, the forecasts made in the SEOR enable a range of eventualities to be covered and, given the current predictions for economic growth in the UK from the OBR and other institutions, some of the more negative aspects of the forecasts need to be reconsidered in choosing an appropriate employment target for the Local Plan.

3.95 The other economic scenarios considered in the report were a ‘baseline’ trajectory based on previous performance of both the macro-economic factors and local factors and two ‘enhanced’ scenarios based on a significant uplift in local performance and productivity. Both of the ‘enhanced’ scenarios would rely on strong growth in the office-based sectors and to a lesser degree, the industrial sector. These remain aspirations for Ashford and steps towards the creation of the Commercial Quarter are now well under way. However, the creation of a strong and vibrant office market will take some time and the allocation of an over supply of land in the early years, especially outside of the town centre, may be counterproductive in building on the solid foundations of a station-based new office market. The 2012 report focused strongly on those aspects of the Ashford economy that have performed well and those where there is scope for improvement given the assets the borough has. This enables the council to focus land allocations towards the strongest sectors and put in place appropriate policies to protect existing active employment sites where possible.

3.96 As part of the GL Hearn commission there was an assessment of the current business sector strengths and the nationally forecast changes to employment by sector through to 2030. The sectors where the forecasts for the next 10 years show growth in jobs in Ashford include business services, professional services, computing services, hotels and catering, construction, retailing and education and health. Sectors that are likely to see lower employment growth due to macro-economic impacts or sectoral changes such as the automation of processes are manufacturing and public administration

3.97 It would seem prudent to set an employment target that is aspirational but also realistic in terms of its delivery over the next few years. The ‘downside risks’ scenario from the 2012 report now appears to be too pessimistic in terms of the macro-economic position in particular and a more appropriate response for the Local Plan would now be a jobs target based on the ‘baseline’ scenario of 12,600 new jobs over the Plan period.

3.98 The SEOR then derived a forecast of future employment land requirements based on the anticipated performance of the economy. Based on a jobs target of 12,600 jobs there is a requirement for 70.9 hectares of land for B class uses over the period form 2010 – 2030.

3.99 Since the GL Hearn forecasts for the 20 year period 2010 to 2030, and a target of 12,600 jobs for the Borough, survey figures have been published providing an updated position to 2014.1,500 jobs have been created within the Ashford Borough between 2010-2014, during a difficult national and global economic period.  This 3% growth during this period is above the 2.4% average growth for Kent, but below the 3.3% growth within the South East and 5.2% national growth. This  leaves a job target of 11,100 between 2014 - 2030.

3.100 An additional GL Hearn commission in 2016 to undertake an Employment Land Review: Site Assessment provides an up-dated employment land requirement for 2015-2030 of 66 hectares based on the baseline scenario from the 2012 SEOR report

Spatial Approach

3.101 As the main town within the borough and with the strategic transport links, it is proposed that growth in employment again is concentrated within and around Ashford town, and that due to its sustainable location, infrastructure and with its role as the heart of the town, that development is concentrated within the town centre on brownfield sites as the principal priority for the Local Plan.

3.102 The other primary locations for business demand for sites within the area are those with excellent access to the motorway network to support their operational needs. Industrial and Distribution companies have a specific need for good access to motorway junctions, to minimise the time for supplies to be delivered to and from the site.  This also limits the impact on other areas of the town through additional traffic and congestion.  For businesses requiring office space, as well as the locations in town centres, some companies will require a location that enables car bound access to clients across the County.

3.103 The challenge, spatially, and in the number of development sites within the Local Plan, will be to ensure that there is a choice of locations across the borough to support different business needs, and to support competition and choice within the market place. Both choice and the delivery of speculative employment space will stimulate relocations into the area.  The allocation of sites needs to provide some flexibility for the market to adapt to changes in the economy, whilst providing a structure within which the aspirations of the plan can be achieved.

3.104 There are 4 key strategic sites for employment in Ashford – the Commercial Quarter,  Waterbrook, Sevington and  Eureka Park – but other employment areas also provide a range of alternatives options for business development.

3.105 The Commercial Quarter – This is the new main business sector of the town intended to stimulate investment opportunities in new large scale office space based around a high quality environment with a location close to the domestic and international railway stations. The site is proposed for up to 55,000 square metres of new office floorspace

3.106 Eureka Park - This large office based business park close to junction 9 provides a key strategic location with easy access to the motorway network and the rest of Kent. Previous planning permissions for B1 floorspace have delivered a number of phases of development. This is a substantial greenfield site with excellent connectivity to the M20 at junction 9 and the potential remains for primarily office development with the area being seen as different to the offer in the Commercial Quarter with lower density development in a landscaped setting. There is also the opportunity in this location to support more flexibility to deliver a smaller secondary element of other employment uses such as light industrial around the cleaner pharmaceutical, medical and health sectors, as well as space for uses such as private hospitals. The role of Eureka Park is also proposed to evolve with the introduction of higher quality residential development on an extended site to sit alongside the employment development

3.107 Sevington – this site was identified in the Core Strategy and subsequently the Urban Sites and Infrastructure DPD as a strategic employment site to provide for a range of employment types and uses but with the opportunity to cater for some of the larger scale employment uses that are less suited to higher density, mixed use environments.

3.108 Outline planning permission has been given (subject to a s.106) for a development of this sort at Sevington. Approximately 157,000 sq m of floorpsace is proposed in total.  Within this figure there is flexibility for up to 140,000 sq m Class B8 (storage and distribution) use; up to 23,500 sq m of B1a/B1c Business (of which a maximum of 20,000 sq m of B1a); up to 15,000 sq m of B2 (general industry); up to 250 sq m of A1 (retail shops) and 5,500 sq m to accommodate the relocation of Kent Wool Growers from the town centre.

3.109 A masterplan has been produced showing how the quantum of development can be accommodated on the site whilst limiting the impact on the setting of Sevington church and the wider area.   The masterplan includes substantial strategic planting to help reduce the impact of the large buildings proposed – this will be complemented by the planting proposed as part of the junction 10A scheme.  This planting will obviously need to mature to deliver the full benefits – long term arrangements will be needed to make sure these areas are managed and protected, including the potential use of group Tree Preservation Orders.

3.110 It is likely that the phased development of this site will take some years to be completed. The planning permission given sets thresholds beyond which development cannot proceed before improved highways access arrangements are in place. 

3.111 Waterbrook – this site is identified for mixed use development but to date only limited development has taken place on the site which currently accommodates the Ashford Truck stop and lies adjacent to the aggregates recycling facility and railhead. The adjacent Orbital Business park is nearing completion and there will be a requirement for similar types of provision with smaller industrial, distribution, office and other sui generis uses within the area to fulfil requirements that do not fit comfortably within the primary roles of Commercial Quarter, Eureka Park or Sevington.

Rural employment 

3.112 Rural Ashford accounts for around a quarter of all jobs in the Borough, a proportion that has remained largely constant over the last 10 years or so. In the rural area workforce jobs have increased by around 14% between 2003 and 2012 – in absolute terms this represents an increase of approximately 1600 jobs.

3.113 In employment terms, rural Ashford’s largest sectors in 2012 were business and retail, largely echoing the pattern of employment across the Borough as a whole. The social care, construction and wholesale sectors also accounted for significant shares of employment. The tourism sector also makes a significant contribution to the rural economy.

3.114 It is clear that the rural area plays an important part in the economic prospects of the borough and this will continue into the future.

Overall requirements

3.115 The Council has concluded that in broad terms there is sufficient land allocated already within existing adopted Plans to meet the overall land requirements to 2030  and that these should be rolled forward as allocations in this Local Plan. The range and type of site has been identified as an issue and there are new allocations identified at Leacon Road/Victoria Way and additional commercial land identified to be brought forward at the Waterbrook site.

3.116 In the rural area, a new allocation is specifically proposed at Tenterden at the Pickhill Indusctrial Estate but there has been a limited selection of other possible sites submitted for consideration. There is currently substantial small scale employment provision in the rural area and hence the approach is to support appropriate, small scale expansion of existing sites, subject to necessary planning policy criteria(see policy EMP3).

 

Policy SP3 - Strategic Approach to Economic Development

Job growth and economic prosperity will be supported in order to enable the achievement of a sustainable economy with the intention to deliver 66 hectares of new employment land and a total of 11,100 jobs in the Borough between 2014 - 30. This will be achieved by the following measures:-

  1. The promotion and development of the employment locations identified within this Local Plan;
  2. The appropriate retention of the existing industrial/commercial/business land, premises and estates;
  3. The maximisation of town centre employment opportunities in accordance with the strategic approach to the town centre set out in this Local Plan;
  4. Taking a positive approach that reflects a presumption in favour of sustainable economic development;
  5. Promoting appropriate rural employment opportunities in sustainable locations
  6.  Improving skills in the workforce

 

 

 

 

Retail and Commercial Leisure Development Needs

3.117 Retail and leisure development plays an important role in the economy of Ashford Borough, and it is expected that these sectors will continue to contribute to the local economy over the plan period. This type of development is particularly important in supporting and developing a vital and viable Ashford town centre.

3.118 National Planning Policy requires local planning authorities to plan to meet the needs of main town centre uses in full, adopting a ‘town centre’ first approach.

3.119 The Local Plan should allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development needed in town centres.

3.120 The Retail and Leisure Needs Assessment 2015 (RLNA), provides an up to date assessment of the quantitative and qualitative need for new retail (comparison and convenience goods) and commercial leisure floorspace in Ashford Borough, up to 2030.

3.121 Tables 2 and 3 below outline the quantitative need for comparison and convenience retail development.

Table 2 - Convenience Retail Need 2015 to 2030 for Ashford Borough

 

2020

2025

2030

Ashford Town Centre (m2 net)

106

200

289

Tenterden Town Centre (m2 net)

-455

-196

50

Local/Village Centres (m2 net)

119

225

324

Rest of the Borough (m2 net)

-2,085

-774

464

TOTAL BOROUGH (m2 net)

-2,315

-544

1,127

 

3.122 The evidence shows there is limited quantitative need for new convenience floorspace over the Plan period across the Borough. However, there is currently an imbalance of convenience retail expenditure to out of centre stores, particularly in the Ashford urban area, which is influenced by a lack of foodstore provision in Ashford Town Centre. The RLNA therefore considered a potential scenario where ‘claw back’ of expenditure was achieved from out of centre food stores. This increases the forecast need for Ashford Town Centre to 751m2 by 2025 and 1,084 m2 by 2030. Alternatively, this provides the potential to support a deep discount foodstore of up to 1,673 m2 by 2025 or 2,413 m2 by 2030.

Table 3 - Comparison Retail Need 2015 to 2030 for Ashford Borough [1]

 

2020

2025

2030

Ashford Town Centre (m2 net)

-714

4,017

9,170

Tenterden Town Centre (m2 net)

9

541

1,122

Local/Village Centres (m2 net)

93

259

440

Rest of the Borough (m2 net)

-3,107

771

5,032

TOTAL BOROUGH (m2 net)

-3,719

5,588

15,764

 

3.123 In the short term, there is limited quantitative need for comparison retail development, when taking into account the re-use of existing vacant prime retail floorspace.

3.124 With regard to commercial leisure development, the leisure needs assessment identified the potential to support new cinema screens in the Borough, new food and drink beverage outlets (A3 to A5), and new gym facilities.

Meeting the need for Retail and Leisure Development

3.125 In accordance with National Planning Policy it is important that new retail and leisure development is focused at Ashford Town Centre first, to help to maintain and strengthen its role in the network and hierarchy of centres. The ‘Rest of the Borough’ retail need identified above should therefore be planned for within Ashford Town Centre.

3.126 Since the RLNA was completed, planning permission has been granted for a six-screen cinema, hotel, restaurants and cafes, at Elwick Place, adjoining the primary shopping area. Permission has also been granted for an extension to the Designer Outlet, which provides additional comparison floorspace and restaurants and café uses.

3.127 These committed developments provide for the need for comparison retail up to at least 2025, and cinema, restaurant and café development, for the whole plan period, in Ashford Town Centre. Given the uncertainty regarding retail forecasts beyond this time, it is not considered appropriate to allocate additional sites to accommodate the remaining need for the last few years of the plan period. In any event, there are sites within the Ashford Town Centre Policy Area, as set out in Policy SP5 which provide opportunities for development.

3.128 With regard to the provision of convenience retail need, in order to maintain flexibility, it is not considered appropriate to allocate a specific site. The need is only required if it is possible to re-distribute the market share to improve Ashford’s convenience provision, therefore the delivery of such a proposal will be very much market driven. It is considered that a flexible approach should therefore be maintained to enable this proposal to come forward within the Town Centre Policy area, as set out in Policy SP5 . Proposals will be required to demonstrate that they accord with Policy EMP9 (Sequential and Impact Assessments) and proposals for convenience provision out of town will be strongly resisted through that policy. 

 

Policy SP4 - Delivery of Retail and Leisure Needs

The need for retail and leisure development for Ashford Town will be met within the Ashford Town Centre Policy Area as defined in Policy SP5; through the delivery of existing commitments, development proposals in the pipeline, and site redevelopment opportunities.

The need for retail development in Tenterden and the local/village centres will be met through small scale development and changes of use within and adjoining the existing centres.

 

3.129 [1] Based upon constant market share and taking into account re-use of vacant prime retail floorspace in Ashford Town Centre