Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/1819
Document Section Local Plan to 2030 - Publication Draft SITE POLICIES The Villages Biddenden - North Street Content View all on this section
Respondent Millwood Designer Homes Ltd (M… View all by this respondent
Agent Peter Court
Response Date 10 Aug 2016
Do you consider this part of the document is Sound? No
On which grounds do you consider the document unsound? (if applicable)
  • Not Effective
Do you consider the Document is Legally Compliant? Yes

These representations are submitted on behalf of Millwood Designer Homes, who control the proposed allocation at North Street, Biddenden. They very much welcome the fact that the Borough Council has identified their site for residential and related development in the draft local plan. Nevertheless, they wish to submit a number of comments about the proposals as set out in Policy S.27.

My clients have been working with the landowner and, indeed, yourselves for the past three years in order to consider how best the site could be developed and to promote it. Indeed, from the outset, their assessment of the site was that, due to its location and other attributes, it was just the sort of proposal that should be acceptable to the Borough Council, given its need to identify land for residential and other uses. It abuts the built up area of the village and enjoys good access to a range of village services and facilities. Furthermore, as it lies behind existing residential development it is well-screened from view. It is now very pleasing to see that, following an assessment of many sites, the Council has included the land at North Street in its draft local plan.

It is clear from the draft plan that the Council is going to come under pressure from other landowners and developers to allocate more land for residential development. The Council does not have a 5 year supply of land for housing and, furthermore has distinctly limited the amount of new residential development in its villages. The Council will certainly be challenged about the adequacy of its total housing provision, and its reliance on large brownfield and greenfield sites in and around the town of Ashford. In these circumstances, the Council should adopt a flexible approach to its proposals in Policy S27 regarding this particular site. My clients do have the ability to provide a good range of facilities, although it must be viable for them to do so. Economies of scale are important in this respect and it is essential for everyone to understand that if total housing provision is limited, then my clients cannot provide everything that local people may wish to see.

In particular, there is a need at this stage to comment specifically on parts a and d of the draft policy. The Council needs to be aware of the fact that an allocation of just 45 units would not be able to deliver a full community facility building for reasons of economic viability. Nevertheless, it would be sufficient to provide a satellite surgery facility to the community, which is a key objective of the Community-led Plan. This could be a multi-purpose building of around 250 sq.m to include B1 use and also facilities for parish meetings. If other representations to the Local Plan consultation support a full community facility building, and it is considered appropriate that a larger number of units on the site would be acceptable, then it is considered that my clients would need to provide 75 units or more to make it economically viable, but would be willing to provide that number of units.

The advantage of this site is that it has the capacity to provide a number of facilities in a single location. It is considered that this is far better than having several smaller sites in the village, all of which can provide a limited number of dwellings, but little in the way of additional community benefits. The Council is therefore requested to carefully consider this matter. Indeed, my clients would be pleased to discuss the development of this site in more detail with the Council.

Overall, therefore, my clients welcome the allocation of this land, but feel that a flexible approach is require to the specific elements proposed under Policy S27.

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? Yes
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. Not an omission but request to increase site number to 75