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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8482

Received: 27/09/2021

Respondent: Richborough Estates

Agent: Fisher German LLP

Representation Summary:

Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.

In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.

The issue with the other options proposed is that they place significant emphasis on delivery in limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further pressure on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
Dispersed growth (or Village related as it is referred in the consultation material) should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. Any attempt to constrain dispersed growth is not supported.
Whilst it is recognised that the Adopted Plan makes some provision for dispersed growth, and growth in the sustainable rural settlements to the period 2030, if this pattern of development is not continued, it could result in 10-year + period where no growth occurs in such settlements. This could have a negative impact on the vitality and viability of these settlements.
A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts to online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.