STRATEGIC PLANNING SUSTAINABILITY & TRANSPORTATION COMMITTEE				9th October 2018
Maidstone Local Plan Review: Broad Spatial Options
Final Decision-Maker		Strategic Planning, Sustainability & Transportation Committee
Lead Head of Service/Lead Director		Rob Jarman, Head of Planning & Development
Lead Officer and Report Author		Sarah Lee, Principal Planning Officer (Strategic Planning)
Classification		Public
Wards affected		All
Executive Summary
In July, Council agreed the Local Development Scheme for the Local Plan Review and is currently developing a new Strategic Plan, which will set out a key vision and series of objectives for the future of the borough. Following on from this, an important step in the preparation of the LPR, and in anticipation of the first ‘Issues & Options’ public consultation scheduled for July 2019, will be the identification of broad spatial options for how planned new development will be distributed in the borough.  Taking an objective, evidence based approach to the identification and ultimate selection of the spatial strategy will be important to the LPR’s soundness at Examination.  This report provides background on the influences on the identification of the broad spatial options and sets out the immediate next steps.
This report makes the following recommendations to this Committee:
1.   That officers be instructed to progress the identification of broad spatial options for the Local Plan Review.   2.   That a report outlining the Call for Sites information package be submitted the Strategic Planning, Sustainability and Transportation Committee for approval prior to publication.
Timetable
Meeting			Date
Strategic Planning, Sustainability & Transportation Committee			9th October 2018

Maidstone Local Plan Review: Broad Spatial Options

 

 

1.        INTRODUCTION AND BACKGROUND

 

Introduction

 

1.1     In July the Committee considered a report which signalled the start of the Local Plan Review (LPR) process. Council subsequently agreed the ‘Local Development Scheme’ (the LPR timetable) and also agreed specific amendments to the July SPST report to underline that the LPR should, amongst all the other things, maintain and enhance the natural and historic environment including air quality and that ‘conceptual masterplanning’ should precede a Call for Sites.

 

1.2     Since the July report, the Government has issued the revised National Planning Policy Framework (NPPF) with which the LPR will need to conform.

 

1.3     Further context for the LPR is provided by the Council’s Strategic Plan, which will set out a key vision and series of objectives for the future of the borough. A report on draft Strategic Plan themes is a separate item on this agenda and thereafter a finalised version of the Strategic Plan is due to be considered at Council on 12^th December.  These timings will enable the completed Strategic Plan to provide both a steer and starting point for the LPR.

 

1.4     The purpose of this report is to provide background on the influences on the identification of the broad spatial options for the LPR and to outline the next steps. A workshop was held on 3^rd September for Members to have an early and informal discussion about the factors which will influence the identification of the broad spatial options for the LPR.

 

New housing requirement

 

1.5     The LPR will include a new housing target.  Since the Housing White Paper in February 2017, the Government has been advocating the use of a standard method to calculate an authority’s housing requirement figure. This has now come to fruition in the revised NPPF which directs councils to use the standardised calculation[1] to derive the ‘local housing need’ figure.

 

1.6     The inputs to the standardised calculation are a) the average annual household increase over the forthcoming 10 year period using the latest Ministry of Housing, Communities and Local Government sub national household projections and b) a housing affordability factor for the borough generated by the Government based on the ratio between median workplace earnings and average house price.  Details of the formula calculation are available here;  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728247/How_is_a_minimum_annual_local_housing_need_figure_calculated_using_the_standard_method.pdf

 

1.7     The current working estimate for the ‘local housing need’ figure is 1,058 homes/year. This figure stems from the latest 2016-based sub-national household projections, issued by the Office of National Statistics on 20^th September.  These supersede the 2014-based projections which resulted in an annual requirement of some 1,200 homes for this borough using the formula.  This substantial downward change should be treated with caution; such reductions have been replicated elsewhere in the country and the Government has already signalled that it may adjust the formula to ensure its application results in a national requirement of 300,000 new homes/year.

 

1.8     In any event, this figure should not be regarded as the final figure. It will change through the duration of the LPR’s preparation because;

 

·         The 10 year period for calculating the average household growth element will roll forward 1 year each year

·         The affordability data is updated by the Government annually

·         Updated sub national household projections are released every 2 years – there will be at least one more release before the LPR is submitted for Examination

 

1.9     The formula calculation is currently capped and should not exceed a 40% increase in the housing requirement in an up to date Local Plan. This should mean that the borough’s figure should not exceed 1,236 homes/year[2]. The calculation excludes Duty to Co-operate approaches from neighbouring authorities which may be forthcoming and is expressed in the NPPF as a ‘minimum’ requirement.  To illustrate, the latest version of the emerging Sevenoaks Local Plan considered at the Committee’s September meeting shows a shortfall of at least 578 homes against the district’s objectively assessed need. Whilst the emerging London Plan aims to meet the capital’s housing needs within its own boundaries, this will require a virtual doubling in the average rate of completions to 65,000 new homes/year. It can be expected that some London boroughs will find their individual targets highly challenging to achieve.

 

1.10 Maidstone borough’s new figure will apply from part way through the Plan period.  We expect this to be from 2022 which is within 5 years of the MBLP’s adoption and coincides with the point the LPR will be adopted.  An additional 175 homes will be needed each year between 2022 and 2031 to ‘top up’ the MBLP’s 883 annual housing requirement to 1,058 and thereafter the full 1,058 requirement will be needed year on year to the end date of the LPR.

 

1.11 To illustrate, this could mean the LPR would be planning for 7,923 additional homes if the end date of the Plan is 2037.  This is the earliest end date possible, per the requirements of the National Planning Policy Framework and the 15 year time period is used in the majority of local authority’s Local Plans, including Maidstone’s adopted Local Plan. It is contingent on the current LPR timetable keeping on track. A longer plan period is more unusual given the additional evidence base requirements, but could be to 2042, and this would result in a requirement for 13,213 additional homes. These figures depend on the delivery of the 17,660 homes in the MBLP remaining on target.

 

1.12 The updated NPPF maintains the Government’s stance that needs should be met in full; that is the starting point.  This is articulated in the presumption in favour of sustainable development as follows;

 

“a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change; b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas”[3].

 

Broad Spatial Options – an introduction

 

1.13 A key question for the LPR is how the housing, and the other types of development needed, should be distributed in the borough i.e. what the spatial strategy should be.

 

1.14 The alternative ways that this could be achieved will be expressed in the early stages of the LPR preparation as broad spatial options.  It will be important for the Committee to consider the different, realistic ways that the required housing numbers can be achieved and, in due course, for the selection of the preferred option to be both transparent and objective and based on a reasoned understanding and consideration of the alternatives. This is affirmed in the Tests of Soundness which require the plan, amongst other things, to be;

 

“Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;”[4]

 

1.15 The Sustainability Appraisal (incorporating Strategic Environmental Assessment) has an important role in influencing and impacting on the content of the LPR, including on this option selection process.  It is integral to the local plan preparation process.  The SA is an evidence document prepared in an iterative way and in parallel with the evolution of the LPR and which will, amongst other things, provide an assessment of the overall and relative sustainability of the emerging options. The National Planning Policy Guidance on sustainability appraisal specifically confirms that;

 

“Reasonable alternatives should be identified and considered at an early stage in the plan making process, as the assessment of these should inform the local planning authority in choosing its preferred approach”[5]

 

1.16 In short, this means that distinct and realistic options will need to be identified for what the spatial distribution could be and then these will need to be assessed in a transparent and reasoned way, in particular through the SA process, so that this Committee (and ultimately Council) is armed with sufficient information to conclude on the best approach for the LPR. This is crucial to ensure that the process of selecting the preferred spatial strategy is, and is seen to be, objective. To do otherwise would be a risk to the soundness of the LPR. A recent Inspector’s letter to the North Essex authorities[6] underlines the importance of the SA process and the need for an open minded approach to decision-making.  The Inspector found that the SA failed to justify the authorities’ favoured spatial approach which centred on the delivery of three new garden communities.  The authorities could not demonstrate that the chosen spatial strategy was the most appropriate one when compared with the reasonable alternatives. The Inspector considered that, in this respect, the SA was likely to be in breach the relevant legal requirements.

 

1.17 The types of sites, in generic terms, which could feature in the future spatial options are briefly described in the following paragraphs.

 

1.18 Town centre – the town centre is a focus for facilities and services and is the best connected location in the borough by public transport. The current MBLP allocates five specific sites in the town centre[7] for residential or residential-led redevelopment. The town centre is also identified as a broad location for a further 940 homes.  The current Town Centre Opportunity Areas stream of work will help reveal further, future potential for residential development which could be a foundation for future, specific site allocations in the LPR. 

 

1.19 The Government sees town centres as key locations for more housing in addition to their function as hubs for commercial, shopping and community services. The revised NPPF now incorporates a specific section about making the best use of land which, amongst other things, expects Local Plans to achieve significantly higher densities in town centres;

 

“Plans should contain policies to optimise the use of land in their area and meet as much of the identified need for housing as possible. This will be tested robustly at examination, and should include the use of minimum density standards for city and town centres and other locations that are well served by public transport. These standards should seek a significant uplift in the average density of residential development within these areas, unless it can be shown that there are strong reasons why this would be inappropriate”[8]

 

1.20 A balance will need to be struck between achieving increased densities and creating good quality places to live; this is a point consistently made by town centre ward Members.  Some sites will be better suited to higher densities for example by increased storey heights or because they are particularly well served by public transport.

 

1.21 Rest of urban area – the MBLP allocates a number of sites[9] in the built up area of Maidstone outside the town centre, generally former institutional or commercial sites. In the mid-2000s, housing associations led a number of regeneration schemes to redevelop areas of social housing in the borough.  These initiatives sought to upgrade the housing stock and achieved a better balance of dwelling sizes however the net increase in the number of homes tended to be minimal (or even negative). The opportunity for further estate regeneration could be explored as part of the research for the LPR but a realistic view of delivery will need to be taken, especially in respect of the availability of funding to Registered Providers for such schemes.

 

1.22 Edge of Maidstone.  Further greenfield sites are allocated in the MBLP at the edge of the town, focused to the north-west and south east.

 

1.23 In and at the edge of the most sustainable villages – next in the settlement hierarchy are the 5 Rural Services Centres followed by the 5 Larger Villages. The MBLP directs a lower quantum of new housing to greenfield sites at the edge of these villages.    

 

1.24 Countryside sites – small residential sites in the countryside, away from the identified villages and removed from services and public transport connections generally score more poorly in sustainability terms. The countryside housing allocations in the MBLP are limited in number and predominantly on previously developed land. 

 

1.25 Garden Communities– the Government is alive to the role that new free-standing settlements and major extensions to existing towns and villages can have in providing new housing and has included a new section in the NPPF;

 

“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. Working with the support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way”[10].

 

1.26 Garden communities are large scale proposals.  The Government defines ‘garden villages’ as being of between 1,500 and 10,000 homes and ‘garden towns’ being 10,000+ homes[11]. Garden communities will be a longer term approach; proposals commenced in one plan period are likely to roll on into subsequent periods. Invicta Barracks is an example of a larger scale development which will deliver housing in more than one plan period with 800 out of a total of 1,300 homes programmed for post 2031.  A strategy which included new settlement/s would be better matched to a plan with a longer time horizon, say to 2042.

 

1.27 Cross cutting – brownfield sites and small sites - the NPPF includes a new requirement for Local Plans to identify sites for at least 10% of the housing requirement on small sites of 1ha or less[12].  This has the objective of diversifying participation in the house building market to help boost delivery.  The NPPF also includes the expectation that the best use will be made of brownfield sites[13].

 

1.28 The revised NPPF still allows for windfall sites (i.e. unidentified sites) to be included as part of future housing supply calculations provided there is convincing evidence that the sites will come forward at the rate proposed, usually obtained by looking at past trends. The revised NPPF defines a windfall site as one not identified in the development plan whereas previously the definition was limited to previously developed sites.  This change should mean that an increase to the annual windfall allowance can be justified.

 

1.29 With the exception of new garden communities, the MBLP includes all these types of sites to greater or lesser degree. The ‘dispersed’ spatial strategy of the MBLP directs the new housing at the most sustainable settlements in the borough with established services and facilities. This was a pragmatic approach which has proved highly deliverable, resulting in new homes being built in locations where the market (housebuilding firms) naturally gravitates, most notably greenfield sites at the edge of settlements.

 

1.30 The items in the list above are generalised types of sites and they are not discrete options in themselves. A discussion about how we will translate this list into possible spatial options is included under ‘next steps’.

 

 

Ensuring a continuous housing supply

 

1.31 The LPR will not simply have to plan for the total local housing need figure, it will also need to include a selection of sites which sustains housebuilding at the required rate year on year.  This is tested through the 5 year housing land supply position which measures the future supply pipeline and also the Housing Delivery Test which measures whether building targets have been achieved on the ground. For the council to maximise and maintain its control over future residential development decisions, both measures need to be met.

 

1.32 The implication of this is that the LPR must be realistic about the timing and rates of delivery from the different types of sites. Over-optimistic assumptions, or a focus on too limited a market in terms of type or location of sites, could mean that the LPR fails to plan for a sufficient, continuous housebuilding with the outcome that the 5 year supply could fall away and/or that delivery drops to the extent that the Council fails to meet the Housing Delivery Test

 

1.33 One illustration of this point is around the potential role of new free-standing settlement/s and/or major settlement extensions which, as noted earlier in the report, is now specifically recognised by the Government in the NPPF. Nathaniel Lichfield & Partners has researched the speed and rate of delivery of large scale housing developments on 70 sites of between 500 and 15,000 homes from across the country[14]. This found that for large sites it took on average 3.9 years from a site’s first promotion (for example, a submission to a Call for Sites) to the point a first planning application was submitted. Thereafter the period of planning approval to the first completion is in the order of 5.3 to 6.9 years. This points to an overall lead in time of approximately 10 years before these largest scale sites start to deliver new homes.  Further, the research found that the build out rate for developments of 2,000+ homes was on average 161 homes/year.  The highest rate a site achieved, 321 homes/year, was sustained for just a three year period.

 

1.34   The implication of this analysis is twofold. Firstly, any Local Plan which includes new settlements and/or major settlement extensions as part of its spatial strategy would rely on advanced masterplanning work to give a Local Plan Inspector assurance that the development and any essential infrastructure will actually be delivered at the time proposed. The level of detail required will depend on how early (or late) in the plan period the development is programmed. 

 

1.35   Secondly, the long lead in time for larger developments and projected build out rates point to the need for a mix of different sizes of sites to ensure supply is sustained at the required levels throughout the plan period. For example, a new settlement approach would be insufficient on its own.  In this scenario suitable sites elsewhere in the borough, potentially including sites in the town centre, in and at the edge of Maidstone and the villages, would also be needed to a) maintain housing supply whilst a new settlement comes on stream; and b) to bridge the gap each year between the number of completions that can be achieved in a new settlement and the borough requirement for some 1,058 new homes.

 

Overview of constraints in the borough

 

1.36 The suitability of different sites and locations for new housing will be influenced by, amongst other things, the presence of constraints, as well as opportunities. To illustrate, the NPPF places the highest level of importance on the following environmental designations[15];

·         Areas of Outstanding Natural Beauty

·         International nature conservation sites (Special Areas of Conservation)

·         Sites of Special Scientific Interest

·         Green Belt

·         Flood risk

·         Ancient woodland and veteran trees

·         Designated heritage assets (conservation areas, listed buildings, scheduled ancient monuments)

 

1.37 There will also be a wider range of environmental considerations which could factor into the selection of options (and ultimately individual sites).  These are not absolute constraints; they will need to be weighed along with other relevant considerations; for example

·         Locally valued landscapes

·         Local nature conservation sites

·         Highest quality agricultural land

·         Value of land for future minerals extraction

·         Air Quality Management Area

 

1.38 In all instances, the scale and significance of the impact of development on such factors will be part of the consideration as will whether impacts can be avoided or appropriately mitigated.

 

1.39 Environmental considerations are part of the picture.   The ‘next steps’ section touches on other high level factors which will influence the choices to be made in the plan.  Understanding the capacity of existing local infrastructure – highways being a prominent example - to withstand the increased growth demands (both the amount and location of development) will be a critical workstream for the LPR. In addition to identifying locations of spare capacity, additional work will be done with the responsible agencies where insufficient or constrained capacity is identified to determine whether capacity can be increased or other alternative solutions found so that the constraint is not demonstrably ‘over-riding’. Using the example of highways, this involves working with KCC colleagues to look at the capacity position on primary routes and junctions and how could be impacted and addressed by development. This solution-focused approach is inherent to the ‘positive planning’ against which the plan will be tested. 

 

1.40 It is worth underlining that, by setting out a positive strategy for where growth should go, taking account of constraints and overall sustainability, the LPR will also be directing the opposite i.e. the locations where development will be resisted.  It is only by doing the former that the Council can maximise its control over the areas it wishes to protect from inappropriate development.

 

        Next steps

 

1.41 The resolution from Council in July affirms Members’ commitment to direct, and take ownership of, the identification of spatial options from the outset. The broad spatial options will be an important part of the ‘Issues and Options’ Regulation 18 consultation scheduled for July 2019. This will be the first opportunity for widespread views to be sought on the scope and direction of the LPR and the key planning issues it will tackle.

 

1.42 However it is apparent that significant work will be required in the meantime. As noted previously, it is very unlikely that a continuation of the council’s current approach would secure the uplift in supply that is needed as a result of the Government’s new housing requirements.  Regardless of the future options and the eventual preferred option, it will be fundamental for the council to meet the Government’s tests for housing delivery, namely the 5 year supply and the Housing Delivery Test. Unless the council is able to demonstrate these, it risks reverting to a ‘planning by appeal’ scenario. Further work around the 5 year supply and Housing Delivery Test will be an essential component in the work on the evaluation of future spatial options in the LPR.

 

1.43 Furthermore, given the significant gap between current supply and future requirements, it will be important for the council to be clear with all parties, and in particular developers, how the existing spatial approach is delivering and also its limitations.  The MBLP has relied on a blending of approaches to deliver its housing target of 883 units/annum. Before we undertake a Call for Sites exercise, it is clear that further work will be necessary to analyse the components of the existing spatial approach - town centre sites, development in and at the edge of Maidstone town and lesser amounts at the villages plus windfall sites - and their respective contributions to housing delivery.

 

1.44 We will also be undertaking further work to understand how these and other approaches could play a role in the new spatial options. It is already apparent that further work is required to inform members, developers and the public as to the nature of the situation faced by the council and the ways in which this could be addressed in future before we undertake a Call for Sites exercise. As previously noted, work will need to be done to demonstrate what combination of sites can achieve the increased level of supply, taking account of the fact that individual sites can only deliver a certain number of homes each year.  Earlier in the report it is acknowledged that infrastructure planning alone will be a substantial workstream. 

 

1.45 Once work has progressed, a further report will be brought to this Committee focusing on the proposed approach to the Call for Sites exercise including the information package to be provided to the development industry as part of that exercise.

 

1.46 It is already considered that there will be an opportunity for the development industry to demonstrate that the sites which they put forward will contribute to the council’s delivery of housing and the various approaches that are apparent. The council will need to apply a consistent approach to the submitted sites and one of the most fundamental elements of the approach will be a demonstration that sites are deliverable. Prior to the Call for Sites exercise, officers will also draft guidance for those submitting sites which will encourage developers to demonstrate matters such as deliverability with their submissions.

 

1.47 In addition, in order to inform the Call for Sites exercise, officers will be undertaking work to set out the national and local constraints which will help inform the spatial approaches that are taken forward and this will also be presented to Members as part of the information package that will accompany the Call for Sites exercise itself. In addition, the package could signal some high level objectives the council wants to achieve through new development.  It could be appropriate for this to cross-relate to the content in the new Strategic Plan with respect to ‘good growth’.

 

1.48 Importantly this approach to the Call for Sites exercise would not commit the council to any particular future spatial approach. Its purpose would be to help generate an effective and informed response to the Call for Sites which in turn would be used by the Council to help refine the potential options through an objective process.

 

1.49 The Call for Sites is currently scheduled to commence in February 2019.

 

1.50 Greater understanding of the realism of the broad spatial options will come with knowledge about which specific sites/locations are available, suitable and deliverable when assessed against an objective evaluation framework and this finer grain information will result from further evidence gathering, most notably the Call for Sites and Strategic Housing Land Availability Assessment (SHLAA). The Council will consider all the categories of sites from earlier in the report (paragraphs 1.16-1.26) as it refines the spatial options, including the potentially new approach for this borough of new settlements or major settlement extensions, in line with paragraph 72 of the revised NPPF. 

 

1.51 The findings from the site assessments, the outcomes of the ‘issues and options’ consultation, the SA interim findings and other relevant evidence  will all help inform the refinement of the spatial options leading to the identification of a favoured option in the ‘preferred option’ Regulation 18 consultation document scheduled for February/March 2020. The justification for the selection of the preferred approach will need to be clearly recorded, including setting out the reasons why the alternative ‘reasonable options’ are not being pursued. This points towards a comparative assessment of the different options against criteria, perhaps in a matrix style format.  Important headline criteria include; 

 

·         Deliverability – the selected spatial strategy must result in the new homes and other development needed being built in the required numbers, at the time needed and at the rate needed.

·         National planning guidance and legislation – the Government’s direction over the planning process is considerable set out in the NPPF and NPPG as well as regulations and legislation. The strategy (and the detailed content of the LPR) will need to comply with this national framework

·         Overall sustainability – is the strategy the one that most successfully balances social, environmental and economic drivers in the round? The SA is a key document to compare the sustainability of the reasonable options.

·         Consultation and engagement – the LPR will go through the specific stages of public consultation and also engagement with key experts e.g. infrastructure providers, agencies like Historic England, Environment Agency, Highways England, KCC and adjoining authorities etc

·         Infrastructure implications – does the strategy make sufficient provision for the timely delivery of the infrastructure generated by the amount and location of development e.g. infrastructure for transportation, telecommunications, water supply, wastewater, flood risk, education, health, sports, open and green space etc? The detail will be set out in an updated Infrastructure Delivery Plan.

·         Viability - linked to both deliverability and infrastructure, the LPR and its policy requirements must be viable in overall terms, otherwise the planned development will not happen.

 

1.52 A further Members’ workshop will be held to cover some of these matters.

 

2.        AVAILABLE OPTIONS

 

 

2.1     Option 1 – that the Committee instructs officers to undertake the necessary preparatory work to establish broad spatial options for inclusion in the Reg 18 ‘issues and options’ consultation scheduled for July 2018.

 

2.2     Option 2 – that the Committee instructs officers not to undertake any preparatory work at this stage on the broad spatial options.

 

 

3.        PREFERRED OPTION AND REASONS FOR RECOMMENDATIONS

 

3.1     Council agreed the Local Development Scheme in July which sets out the timetable for the LPR.  The ‘Issues and Options’ consultation is scheduled for July 2019.  Whilst the content of such ‘informal’ stages of public consultation are not prescribed in regulation or guidance, it is an early opportunity to obtain wider views on initial aspects of the plan and a key element will how development could be distributed i.e. broad spatial options.  A meaningful consultation is likely to include some reference to spatial options. The SA process also requires options to be assessed. An instruction to delay progress with this work (Option 2) could impact on the achievement of the milestones in the LDS. Both this report and its predecessor in July have signalled the benefits to the council of continuing to have an up to date Local Plan in place. For this reason, Option 1 is recommended.

 

 

4.       RISK

4.1    The report underlines the requirement for the identification, refinement and selection of spatial options to be undertaken in an objective and transparent manner, informed by evidence, in particular (but not exclusively) the findings of the SA/SEA process which will be undertaken in an iterative way in parallel with the evolution of the LPR.  Deviating from these requirements is a risk to the soundness of the LPR.

 

4.2    More generally, the risks associated with the recommendation to progress the identification of broad spatial options, including the risks if the committee does not act as recommended, have been considered in line with the Council’s Risk Management Framework. The scenario which has been considered is ‘failure to progress the LPR to timetable’. That consideration has rated the risk to service delivery as ‘RED’, primarily as this would represent a failure (or delay) to the plan’s contribution to council priorities in respect of ‘a home for everyone’, ‘providing a range of employment opportunities and skills required across out borough’, ‘securing improvements to the transport infrastructure in our borough’, ‘regenerating the town centre’, ‘encouraging good health and wellbeing’ and ‘respecting the heritage and character of our borough’.

 

4.3    To mitigate this risk, officers are taking a programme management approach to advancing the LPR.  The LDS agreed by Council in July provides the overall timetable for the key stages of the LPR process.

 

4.4    This overall approach is considered sufficient to bring the impact and likelihood of the identified risks within acceptable levels.  We will continue to monitor these risks as per the Policy.

 

 

 

5.       CROSS-CUTTING ISSUES AND IMPLICATIONS

 

 

Issue	Implications	Sign-off
Impact on Corporate Priorities	The LPR, as the primary long term spatial plan for the borough, will contribute to the achievement of the council’s priorities in respect of ‘a home for everyone’, ‘providing a range of employment opportunities and skills required across out borough’, ‘securing improvements to the transport infrastructure in our borough’, ‘regenerating the town centre’, ‘encouraging good health and wellbeing’ and ‘respecting the heritage and character of our borough’	Rob Jarman, Head of Planning & Development
Risk Management	Please refer to Section 4 - Risk.	Rob Jarman, Head of Planning & Development
Financial	Funding has been set aside in the Medium Term Financial Strategy for the Local Plan Review.  The action recommended in this report does not require additional, specific funding. Financial monitoring will be an important component of the programme management arrangements for the LPR so that any divergences from the agreed budget can be anticipated, quantified and addressed.	Suzan Jones, Accountancy Assistant
Staffing	Staff resources are being actively managed.  There is a current advertised vacancy for an additional principal planning officer in the Strategic Planning team. The selective use of agency staff will be explored if permanent recruitment is not successful. Collation of the LPR evidence base will require the commissioning of external, specialist expertise to deliver specific tasks.	Rob Jarman, Head of Planning & Development
Legal	The Council is obliged to undertake the local plan review in line with the requirements of the Planning and Compulsory Purchase Act 2004 (as amended) and the procedures set out in the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended).   In particular a Strategic Environmental Assessment must be prepared and considered against all options being considered as part of the spatial strategy for the distribution of housing.  This includes the possibility of planning for new settlements together with other alternatives to enable the Council to lawfully identify a preferred option in accordance with the Environmental Assessment of Plans and Programmes Regulations 2004. More generally, legal advice will be sought as required throughout the Local Plan Review process.  A named officer in the Mid Kent Legal services team is the team’s key point of contact for all legal issues arising to ensure continuity and consistency of advice.	Cheryl Parks, Mid Kent Legal Services (Planning)
Privacy and Data Protection	The LPR process in its entirety will result in increased volume of data held by the Council, most notably the personal data of those who respond to the consultation stages on the Local Plan Review.   This data will be held and processed in accordance with the requirements of the GDPR.	Cheryl Parks, Mid Kent Legal Services (Planning)
Equalities	The recommendation does not propose a change in service therefore will not require an equalities impact assessment at this stage.   An Equalities Impact Assessment will be undertaken on the draft LPR itself when that stage is reached.	Equalities and Corporate Policy Officer
Crime and Disorder	No specific implications at this stage.	Rob Jarman, Head of Planning & Development
Procurement	No specific implications arising from the recommendation in this report.	Rob Jarman, Head of Planning & Development; & Section 151 Officer

 

6.        BACKGROUND PAPERS

 

Nil