Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2164
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION F - IMPLEMENTATION Introduction View all on this section
Respondent Shadoxhurst Parish Council (Da… View all by this respondent
Response Date 12 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 Positively Prepared
  • Not Justified
  • Not Effective
Do you consider the Document is Legally Compliant? No

The attached document outlines our concerns in Part 1, Section 4 that our Parishioners have found it extremely difficult to comment on the Plan. Thus we consider that question 4 is flawed as we do not have professional legal or planning knowledge. Part l also looks at the policies which we consider are UNSOUND.

Part two of the attached document places objections to two sites in Kingsnorth Parish, S3 Court Lodge (page 50) and S4 Land north of Steeds Lane and Magpie Hall Road (page 55) which we consider to be UNSOUND

Part three of the attached document raises objections to the Infrastructure Delivery Plan and considers it UNSOUND

Part 3 Infrastructure Delivery Plan

3. Infrastructure in Local Plan

3.1 References:

 ABC Introduction to IDP

 Annex 2 Infrastructure Delivery Schedule

 ABC Statement of Community Involvement

NPPF paras 157 / 162 / 177

3.2 Overview

The Ashford Borough Draft Local Plan for 2030 and its associated Evidence Base documents include several elements which address "Infrastructure" needs.

The "Infrastructure Delivery Plan" includes a generalised Introductory Document together with "Annex 2 Delivery Plan". Whilst the key elements of Infrastructure are identified, the borough-wide needs and actions are given variable attention and in several key aspects not addressed at any practical level.

Extract from "Introduction to IDP: Background & Context".

"The NPPF (paras 157 & 162 & 167) requires the Local Plan to include strategic policies and to plan positively for the delivery of infrastructure, including for transport, telecommunications, ……

The NPPF goes on to say that adequate, up-to-date and relevant evidence must be used to assess the quality and capacity of such infrastructure and its ability to meet future forecast demands……to ensure that the Local Plan is ‘deliverable’ (para 173)".

This Critique addresses two specific areas of Infrastructure (within the NPPF definition); namely Transport (in particular the Existing & Planned Road network) and Telecommunications.

For the overall Local Plan to be viable, the associated Infrastructure, and its integration, must be defined to a level sufficient to permit complete understanding.

In particular, an overall Roads Infrastructure, capable of meeting the needs of the Construction Programme, needs to be put in-place before the Construction commences, in phases as appropriate. Both the construction phase and long-term Roads capability needs to recognise the impact on the broader community impacted by short-term and permanent traffic loadings / movements.

Equally the Telecommunications Plan needs to recognise the limitations of existing fixed & mobile networks and jointly work with providers to develop the necessary capabilities forward for Ashford 2030. This is not identified, nothing appears to be anticipated.

3.3 Transport

The only "Traffic Impact Assessment" included with the Plan addresses solely sites to the north of Town, i.e. Kennington East & Eureka.

Villages in the southern hinterland of the Borough, notably Shadoxhurst, Kingsnorth, Bethersden, Woodchurch and Hamstreet will be impacted not only by their own designated developments but by the parallel major Chilmington programme. Any work to construct Junction 10A and all the road infrastructure work at Chilmington, Sevington, Court Lodge, Kingsnorth, etc will also have a major impact on travel to and from, and indeed through, South Ashford as drivers try and avoid bottlenecks.

The IDP Annex 2 makes reference solely to A28 Widening and Pound Lane Link Road (together with the detailed study for the latter) but no clear detail on timing. Other roads created within the larger developments, and feeding to-&-from the other locales, equally warrant specific attention.

Ashford Borough Council should develop

a hierarchy & priority with respect to the development the Ashford road network.

a transparent vision of which road schemes need to be in place before others and before certain levels of development are begun.

Chilmington will have major impact on the South Ashford villages, not only on the day-to-day normal movement of local traffic, much of which will need to seek alternative routes to avoid development works but also the movement of construction related traffic movement and parking. This relates to all sizes of goods vehicle, but clearly HGVs have the greatest impact. It is imperative that specific impact assessments are undertaken and published addressing the key routes around the southern quadrant and its key component roads, including but not limited to:

A28 Ashford to Tenterden, whole route

 Magpie Hall Lane & Stubbs Cross junctions (designated as a Chilmington access route)

 Criol Lane (designated as a Chilmington access route)

 Bethersden Road

Tally Ho Road – Woodchurch Road through Shadoxhurst

Ashford Road & Hamstreet Road from Kingsnorth to Hamstreet

Many of the smaller routes are already seeing an increasing usage by "construction HGVs" taking short-cuts on roads which are totally unsuitable and increasing damage to road surfaces is occurring. There is an urgent need to classify, sign and effectively regulate specific rural roads to prohibit construction vehicles becoming a serious problem. Whilst we see the south Ashford rural roads as important to us, we respect that there will be displacement of this traffic and may cause problems elsewhere. There is thus a need to establish a mechanism for this, in conjunction with KCC Highways, before construction gets underway, so that all rural and town edge communities can be consulted and be able to have appropriate protection in place at the appropriate time.

3.4 Telecommunications

ABC’s "Statement of Community Involvement" includes a listing of specific consultation bodies. British Telecom, as primary supplier of terrestrial telecommunications infrastructure, notably Broadband, is not a listed consultee, either here or in the Draft Local Plan. The Local Plan specifies requirements for telecoms infrastructure without any study of whether this is available or deliverable, by fixed or mobile means.

"Intro to IDP, Appendix 1: Infrastructure bodies & service providers active within the Borough" makes no reference to Telecomms providers.

Annex 2 Infrastructure Delivery Schedule" makes no reference to Telecomms.

EMP6 addresses requirements for FTTP within individual new developments, no reference to the supply to these or requirements for existing users.

Ashford Borough, and notably much of its hinterland, does not benefit from a widespread telecoms infrastructure that reflects 2016 standards.

Many of the village BT exchanges are at or over capacity and fibre optic connections to existing users are sporadic. For many users, Broadband access is minimal or non-existent. Whilst the Plan claims that exchanges are "fibre enabled", there is little progress to connect users.

Equally, mobile coverage often doesn’t match that of many 3rd world countries, with some village areas having minimal to zero signal.

Communications Infrastructure is not specifically addressed as a component of the Plan and as such cross-references are limited.

The draft Plan & EMP6 states "promotion of FTTP to all new developments wherever practical"; seemingly a get-out clause. There is no apparent provision for S106 or other CIL contribution to the fixed & mobile capabilities, notably broadband and landline capabilities, for either new or existing users.

Annex 2 doesn’t address Telecommunications; it is totally ignored!

There is no evidence of the active participation of BT &/or any other Telecoms providers in the Draft Plan. Whilst infrastructure providers are responsible for meeting their statutory obligations and responding to growth through their own funding sources, planning for infrastructure provision necessitates a reactive participation in the Councils plans for development; this APPEARS TO BE TOTALLY ABSENT. In this regard the Draft Local Plan is fundamentally flawed and UNSOUND.


What changes do you suggest to make the document legally compliant or sound? We are not legally knowledgeable or proficient to be able to comment about legal compliance without seeking legal advice. The attached document looks at the soundness and questions if they can be made 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. No
Please supply details of the omission site.