Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2369
Document Section Local Plan to 2030 - Publication Draft SITE POLICIES Ashford Urban Area Land North-East of Willesborough Road, Kennington Content [View all comments on this section]
Respondent Natural England (Nigel Jennings) [View all comments by this respondent]
Response Date 16 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 Consistent with national policy
Do you consider the Document is Legally Compliant? Yes


Many of the site allocations are stated to be on agricultural land, but only one allocation mentions the land classification - Land North-East of Willesborough Road, Kennington which is approximately 60% grade 1. It would avoid confusion if all sites using agricultural land mention the land classification and whether they impact Best and Most Versatile (BMV) land.

Land to the North East of Willesborough Road, Kennington

60% of this allocation is categorised as grade 1 BMV agricultural land. Soil is a finite resource that fulfils many important functions and services (ecosystem services) for society, it is therefore important that the soil resources are protected and used sustainably. The Natural Environment White Paper (NEWP) 'The Natural Choice: securing the value of nature' (Defra, June 2011), emphasises the importance of natural resource protection, including the conservation and sustainable management of soils.

The conservation and sustainable management of soils is also reflected in the National Planning Policy Framework (NPPF), particularly in paragraphs 109 and 112. When planning authorities are considering land use change, the permanency of the impact on soils is an important consideration. Particular care over planned changes to the most potentially productive soil is needed, for the ecosystem services it supports including its role in agriculture and food production. Plan policies should therefore take account of the impact on land and soil resources and the wide range of vital functions (ecosystem services) they provide in line with paragraph 17 of the NPPF.

The Plan does not provide a clear rationale why the importance of the development outweighs the weight that should be given to BMV.


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. No
Please supply details of the omission site.