On behalf of our client, Cogent Land LLP (CL), Iceni Projects is writing in response to Thanet District Council’s Man Modifications to the Local Plan. The submission relates to the land known as Manston Green located to the east and west of Haine Road, Ramsgate (the Site). In order to inform this submission, please also find enclosed a copy of the site location plan attached as appendix A1.

a. The site: By way of background, CL were granted outline planning permission on the Site, including details of the access, on 13th July 2016, for the erection of 785 dwellings, highways infrastructure works (including single carriageway link road), primary school, community hall and public open space on the land to the east and west of Haine Road (Manston Green) (LPA ref: OL/TH/14/0050).  Subsequent reserved matters for outstanding matters on layout, scale, appearance and landscaping for 220 units was granted permission on 18 October 2019 (LPA ref: R/TH/19/0499).

b. Main Modifications to the Pre-Submission Publication Local Plan: The Council are currently consulting on the Main Modifications to the Pre-Submission Publication Thanet Local Plan (July 2018), that was submitted for examination on 30 October 2018. Under Policy SP13 (Strategic Housing Sites) the Site (Ref: MM/034) known as Manston Green is currently allocated for up to 785 new dwellings and the Council have proposed several amendments to the policy in order to make the Plan sound. Whist we consider the majority of amendments to policy SP13 to be acceptable, we request that
greater clarity is needed on the following modification: 
All development proposals must be planned and implemented in a coordinated manner and accompanied by an infrastructure delivery and phasing plan. 

The Council stated that this has been added in order to apply a consistent approach to strategic housing policies. Although this is a requirement for all the allocated strategic sites, there is firstly no justification for its inclusion, and it’s unclear whether it is down to the applicant or the Local Planning Authority to provide this.

Policy SP01 – Implementation of the draft Local Plan states:

All new development will be expected to fully meet its infrastructure requirements, whether directly on site or by contribution to that provision elsewhere, and to comply with the provisions of the Infrastructure Delivery Plan, in terms of provision of physical and social infrastructure. This provision should be made within the phasing programme set out in the draft Local Plan and draft Infrastructure Delivery Plan. Any such requirements will be secured by means of conditions, legal agreements, Community Infrastructure Levy or other appropriate mechanisms.

This existing policy suggests that any development must comply with the Infrastructure Delivery Plan rather than applicants being required to submit one as part of any application. Notwithstanding this the Site benefits from outline planning permission, therefore the developer’s contributions have already been established through the Section 106 Agreement. Further to this, the provision of services on site such as the school are reliant on support from infrastructure providers. We therefore anticipate that this requirement could have implications for the delivery of the site, with subsequent effects on the Council’s housing delivery. With this considered, we request that the Council provides more clarity on the governance process for this requirement if it is to be taken forward and adopted as part of Policy SP13. Considering the site already benefits from an agreed S106 agreement, the Council should consider removing this from the Manston Green allocation to avoid hindering the delivery of much needed housing. 

c. Further Allocation: 

CL have been promoting the remaining area of developable land to the west of Haine Road, expressing that by allowing a slightly higher density and incorporating all developable land included within CL’s option agreement, outlined in red on the enclosed Site Location Plan (appendix A1), the Site could accommodate an additional circa 150 units above that which has already been consented under Outline Planning Permission OL/TH/14/0050.
Since the Reg 19 Local Plan consultation, CL have secured reserved matters approval for 220 units (Phase 1) (LPA ref: R/TH/19/0499), further up this area as a sustainable option for development.

Sustainability Appraisal Assessment (2019)
Following the Local Plan hearing sessions, the Council published an update in October 2019, including an addendum to the Sustainability Appraisal (SA) prepared by Arup, consisting of assessments for each individual Strategic Housing Site. The SA assesses the Site based on an uplift to the existing allocation from 785 units to 935 units. 
The appraisal summary states that the site is in close proximity to local retail, employment and service provision, as well as the nearby bus and rail transport links, which provide access to the rest of Thanet and the wider South East Region, highlighting the inherent sustainability of the site. In the context of the existing allocation and planning permissions, the Council should allocate the site for an additional 150 dwellings. This would ensure the most efficient use of the site, which is known for being suitable, achievable and deliverable for housing. The land should therefore be allocated for a total of c. 935 dwellings.

e. Conclusion: The Council should consider allocating all developable land included within CL’s option agreement, the land at Manston Green which could accommodate an additional 150 dwellings (total of 935 dwellings) as identified in the Sustainability Appraisal (October 2019), on a sustainable site that benefits from planning permission.