Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/1817
Document Section Local Plan to 2030 - Publication Draft STRATEGIC POLICIES Strategic Development Requirements Employment delivery View all on this section
Respondent Friends Life, AXA Real Estate… View all by this respondent
Agent Montagu Evans LLP (James Huish)
Response Date 10 Aug 2016
Do you consider this part of the document is Sound? Yes
On which grounds do you consider the document unsound? (if applicable)
Do you consider the Document is Legally Compliant? Yes
Comment

Policy SP3 outlines that 66 hectares of new employment land will be delivered and 11,100 new jobs will be achieved in the borough between 2014 and 2030, including through the maximisation of town centre opportunities and promoting rural employment opportunities.

We agree with paragraph 3.84 which identifies the critical investment in transport infrastructure as they key driver for employment growth within the borough and contributing to Ashford being the number one place for business location within Kent. A key component of this transport infrastructure is the delivery of J10a on the M20. Through the Sevington West planning permission my clients have worked closely with Highways England and ABC to assist delivery of this scheme and will be a major contributor to its funding through the scheme.

Highways England are shortly to submit their Development Consent Order which we continue to support and it is understood that the current programme shows that J10a will be open in 2019.

Paragraph 3.102 notes that a primary location for business demand are those with excellent access to the

motorway network to support operational needs. It recognises the requirement of distribution companies having specific need for good access to junctions and that it limits the impact on other areas of the town in terms of traffic and congestion. Delivery of J10a will provide such excellent access to the motorway network that Sevington West will benefit from. The land at Sevington East is similarly well located to take advantage of this access without undue disruption on wider areas.

We also welcome the recognition of ‘Sevington’ (in Para. 3.104) as being as one of the four key strategic sites for employment in Ashford. Paragraphs 3.107 to 3.110 goes onto discuss Sevington in more detail. Importantly para 3.107 confirms that Sevington West was allocated in the current 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.” (our emphasis)

Paras 3.108 and 3.109 go onto recognise the grant of planning permission and some of the core principles that sit behind this. 3.110 then provides some commentary on delivery of the development and refers specifically to triggers for development thresholds. It is important to note that these triggers are in place only to control the amount of development pre delivery of J10a. As noted above HE are progressing the DCO for J10a and it is currently expected that it will be open in 2019. There will at that time be no constraints on delivery of the permitted development on the site.

Furthermore, it will deliver capacity for significant amounts of other development which could include land at Sevington East. Sevington East benefits from the same attributes as Sevington West and is specifically well located to deliver larger scale employment uses that are less well suited to other locations. We therefore object to Plan failing to allocate Sevington East. This omission is flawed for the reasons set our below.

 

Section 4 – Site Policies

It is noted that at para 3.115 it is confirmed that with the current Development Plan allocations there is sufficient

land allocated to meet employment needs to 2030. It also notes that these existing allocations should be rolled

forward as allocations into the new Local Plan. Section 4 is where such allocations are addressed.

Despite noting that all existing allocations should be rolled forward it is noted that Sevington West is not included

within this section. This could be understandable now that there is a planning permission in place and this

position is presented elsewhere in the draft Plan (see Paras 3.107 to 3.110). However, it is noted that each of

the other four key strategic sites identified at para 3.104 maintain a site specific allocation in the draft Local

Plan. Presumably this is because there remains land on which planning permission has yet to be granted. We

do feel however that an ongoing allocation on Sevington West would be useful to inform future planning on this

site consistent with current policy U17.

Turning to Sevington East it is acknowledged that the current allocations are sufficient to meet employment

needs to 2030. Notwithstanding this the draft Plan does propose two new employment sites namely Leacon

Road/Victoria Way and some additional land at Waterbrook. The reason given for these additional allocations

is down to the range and type of sites and the employment opportunities afforded within the existing allocations.

It is clear from looking at these sites, and in particular Leacon Road that, there is an identified need for

commercial B1-B8 uses.

It is considered that Sevington East would be a more suitable location for the delivery of such commercial space,

particularly B8 space given the acknowledged locational advantages of the general Sevington location. Indeed

and as already noted it was accepted within the Core Strategy that Sevington East offers “the potential extent

of an employment area further eastwards” and that this was an issue for consideration for the next Local Plan

review. We consider the decision not to allocate Sevington East is flawed and that it should be allocated to meet

identified employment needs that arise over the Plan period over and above the current allocations. Given the

current planning permission for Sevington West it is inevitable that Sevington East would only follow after

implementation of that consent and as such would be towards the end of the Plan period. This could be

controlled through an allocation and/or the grant of planning permission. The same cannot be said of Leacon

Road which as a freestanding site could be brought forward in the shorter term following the grant of planning

permission. This is not therefore meeting the longer term needs.

[Steve – I would like to add in a couple of paragraphs on market conditions to show that demand already exceeds

the quantum of development that we have consent for. I want to get over that there is strong occupier demand

for industrial and warehouse space and there is a need for additional space in Ashford, Kent and the South East

of England Can you assist and Sevington East is best placed to meet this following on from Sevington West]

Turning now to the specifics of Sevington East. Previously this site was put forward in 2013, as part of the ‘call

for sites’ for assessment within the Strategic Housing and Employment Land Availability Assessment (SHELAA).

The submission highlighted that the site would be suitable and appropriately located for an expansion to the

employment area now approved on the adjacent site (at the time of submission, Sevington West was an

allocated employment area within the development plan).

We understand that Sevington East was then subsequently assessed for its potential as an employment site

allocation within the SHELAA (site ref. WE15), which forms part of the evidence base for the Local Plan. It

concludes:

“This site was identified in the Core Strategy and Urban sites and Infrastructure DPD as having potential

for allocation to extend the [U19] Sevington site. The site has some constraints with the archaeological

areas and its close proximity to the residential properties to the east and the village of Mersham. This

site is not suitable for extension at present due to Junction 10a implications and impact on surrounding

setting and villages. Assessed as part of ELR.”

The Employment Land Review (ELR) (April 2016) recognises the Sevington West site as a ‘site of strategic

significance’ in meeting demand for B8 warehouse/distribution floorspace. It notes that it will be a key

employment site in Ashford when the M20 Junction 10a scheme is delivered. It also recognises the importance

of its location, adjacent to the motorway where there will be strong demand for these uses.

In total, the ELR identifies 67 hectares of potential supply of land for industrial and warehousing floorspace.

Whilst this represents an ‘over-supply’ in terms of the assessed need, we note that paragraph 4.14 states that

“much of available land is constrained by access (either in planning or market terms) in the short-term.

As already noted above the new J10a junction is required to unlock the full potential of land at Sevington and

that the planning permission deals with this. However, the current programme for J10a has this work being

completed by 2019. This broadly aligns with the development programme for Sevington East. It is not therefore

a legitimate constraint for Sevington East as concluded in the SHELAA.

This then leaves only perceived concerns over the “impact on surrounding setting and villages.” As we know

from Sevington West similar concerns were raised. However, through a carefully considered design approach

including extensive landscape an acceptable solution was reached for what is arguably a more sensitive site

given its close proximity to St Mary’s Church (Grade 1 Listed) and other listed buildings at Court Lodge Farm.

The officers report concluded the following on this issue:

“In conclusion, I am satisfied that the applicant has demonstrated how the design and external

appearance of the proposed buildings could be acceptably accommodated at the site in a manner that

would both meet market requirements and help reduce their visual and landscape impact

notwithstanding the fact that Policy U19 envisages buildings of considerable footprint and scale and so

inevitably would change the character of this entrance to the town by road and rail.”

It can therefore reasonably be concluded that a design solution could be arrived at for Sevington East that would

ensure no unacceptable impacts on the character and appearance of the surrounding area and local villages.

Likewise it can reasonably be concluded that based on to the recent application and surveys undertaken for the

Sevington West application, technical solutions and appropriate mitigation measures can be found for all other

matters including drainage and ecology issues.

In conclusion therefore in the event that there is a requirement for new allocations for employment development

towards the end of the Plan period Sevington East is a more appropriate location then the two draft allocations.

To address this Sevington East should be allocated in the next iteration of the Plan.

 

 

 

What changes do you suggest to make the document legally compliant or sound?
Do you consider it necessary to participate at the oral part of the examination? No
Does your representation relate to an omission site (a site that has not been included). For example a site for Housing, Employment, Travellers, or Local Green Spaces. Yes
Please supply details of the omission site. Sevington East see attached
Attachments