Proposed Revisions to Draft Local Plan (Preferred Options)

Comment ID 14448865/1/8408180/-
Document Section 2. Sustainability Appraisal (no name) [View all comments on this section]
Respondent Angela Schembri - RPS Planning… [View all comments by this respondent]
Response Date 17 Mar 2017
Do you consider the document is Legally Compliant?
Do you consider the document is Sound?
On which grounds do you consider the document unsound? (if applicable)
  1. TDC has not given appropriate consideration to alternatives to delivering its housing need requirements before settling on a new settlement option (with reference to The New Settlement Mitigation Strategy, November 2016)


  1. RiverOak objects to proposals for a new settlement at Manston as it would result in the irrevocable loss of Manston Airport.
  1. It also represents a wholly unsustainable option that would require significant mitigation and infrastructure improvements to remedy the fact that it is located away from existing facilities and services. Concerns are also raised as to whether a new settlement on the site with the known and unknown mitigation would be a viable and therefore a realistic prospect.
  1. In any event, there is insufficient justification to demonstrate that a new settlement is the most appropriate strategy to deliver TDC’s housing needs especially as all other reasonable alternatives have not been properly considered. RiverOak’s reasons for this conclusion are expanded upon below:
  1. The response to the January 2015 consultation on the new Local Plan demonstrated considerable public concern for a new housing strategy based on a new settlement. The preference was for development of existing urban areas with limited settlement expansion. The 2013 Interim Sustainability Appraisal Report recorded that the new settlement option scored poorly based on an assessment against the performance criteria. The key negative effects were associated with the settlement being located away from existing facilities and services and that this could result in the greater reliance on private car use to access services.
  1. There are many queries that need to be raised in connection with the process that has been undertaken to conclude that a new settlement at Manston Airport should be promoted. The process is by no means sufficiently transparent and there is vital information that has not been presented by TDC as part of the consultation including the following:
  1. The New Settlement Mitigation Strategy (November 2016) states that the location of indicative sites for a new settlement has been based on sites submitted under the Strategic Housing and Land Availability Assessment process and ‘omission sites’ (alternative housing sites put forward as a result of the January 2015 consultation). These sites are shown on Figure 1 in the strateg The 320ha Manston Airport site (including the Northern Grass) was promoted by Stone Hill Park Ltd for mixed-use development including approximately 2,500 new homes as part of the January 2015 consultation and is therefore an omission site which has been considered.
  1. The December 2016 Sustainability Appraisal by Arup states in Section 5.2 (Housing and Employment Land Allocation) that a number of new sites had been promoted since the January 2015 consultation. The assessment of these sites has not taken place and TDC state that this will be included in the Environmental Report which will be prepared to support the Pre-Submission draft Local Plan that will be finalised during 2017. To promote a new settlement in advance of assessing the other omission sites is fundamentally incorrect. Furthermore, this very important information is missing from the current consultation which is misleading the publi
  1. Proper consideration of the other omission sites needs to be made before settling on the preferred housing strategy as these sites could involve fewer sustainability issues if they were to be taken forward and therefore perform better than the proposed new settlement option. Based on a review of the consultation responses, it would appear that there are a number of sites including large sites on the urban edges that have not been considered. Given that this is the preferred approach to new housing delivery as evidenced from the January 2015 Local Plan consultation, it is clear that TDC has not given appropriate consideration to expanding urban areas before settling on the proposed new settlement option at Manston Airport;


  1. The New Settlement Mitigation Strategy (November 2016) further states that the mitigation that could benefit a new settlement option has been identified from a literature review. The Strategy accepts that once a masterplan is devised for a new settlement, and more detail is known about the new settlement, more detailed specific measures can be included to mitigate and enhance any sustainability issues. The fact that there is a live planning application with TDC for the type of development envisaged by Revised Policy SP05 (application reference OL/TH/16/0550 by Stone Hill Park – the freehold owners of Manston Airport) means that TDC is much more informed than it otherwise would have been about the Manston Airport site option in terms of the likely environmental effects and the mitigation that will be required in the event that the settlement goes ahead. Significant objections have been received in connection with that application including from statutory consultees and significant matters remain unresolved. This questions the actual ability to deliver a new settlement on the site unless there is considerable mitigation which may render the scheme unviable. New settlements by their very nature require large infrastructure investment and there are long lead-in times associated with their delivery which questions the ability of this option to be realised during the plan period;
  1. Land comprising the Northern Grass at Manston Airport (Site NS4 in the New Settlement Mitigation Strategy, November 2016) is measured as being a Greenfield site in Table 3 of the Strategy which is an assessment of the new settlement options against the sustainability appraisal objectives. This is incorrect as it is land within the airport boundary which is already allocated in the adopted Local Plan and protected for employment use and is a brownfield site; and
  1. The sites considered for the new settlement options are not comparable. Site NS5 (Manston Airport) is the only brownfield site and is significantly larger than the other sites considered. Consequently, it would only ever score best on many of the sustainability appraisal options. The process that has been followed which has resulted in the preference for a new settlement option is too simplistic and the other indicative new settlement options not on land at Manston Airport (based on sites submitted under the SHLAA process and omission sites – see Figure 1 in the Thanet District Council New Settlement Mitigation Study Summary Report, November 2016) were never large enough in their own right to accommodate the volume of housing needed. Consequently, land at the airport simply because of its large size and the fact that it is brownfield land whereas all the other options are on Greenfield land, clearly meant that this option scored more highly in terms of meeting the Sustainability Appraisal objectives. It does not appear that TDC considered an option which allowed for the provision of new housing collectively across a number of the sites considered for the new settlement option. This is an omission.
  1. Furthermore, and no explanation is provided as to why, given the identified local demand for additional housing and the ‘reported’ difficulties in finding suitable new housing sites, it is surprising that TDC has not expressed any interest in promoting a new settlement at Manston Airport as part of the Government’s garden villages programme (villages of between 1,500 and 10,000 homes). Whilst the need for the additional 2,753 dwellings was not known until after GL Hearn prepared an Updated Assessment of Objectively Assessed Housing Need in January 2017 (which was after the Government’s deadline for expressions of interest on 31 July 2016), the Government has confirmed that it may run a further call for expressions of interest in 2017 for other places with proposals for new garden villages. RiverOak is not aware that TDC have expressed any interest in benefitting from this Government initiative despite a new settlement at Manston Airport being able to fulfil all the eligibility criteria to be considered for Government support (proposals must be for a new settlement of 1,500 – 10,000 homes; it must be a new discrete settlement, and not an extension of an existing town or village; and it must be led by local authorities to support wider housing and growth ambitions).


  1. The Government are especially encouraging expressions of interest which make effective use of previously developed land (brownfield land). If TDC were genuinely supportive of a new settlement at Manston Airport, then surely they would have applied to benefit from this initiative which is designed perfectly for the Council’s needs. However, it has not and this raises suspicions as to TDC’s genuine intentions for the Manston Airport site.
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?
Why do you feel it is necessary to participate at the oral part of the examination?
Officer's Response Not yet available.
Proposed Change