Proposed Modifications to the Thanet Local Plan

Document Section Main Modifications Chapter 3 - Housing strategy MM/039 MM/039 [View all comments on this section]
Comment ID 155
Respondent Greenacre (Thanet) Ltd - Green… [View all comments by this respondent]
Agent Montagu Evans LLP - Montagu Ev…
Response Date 23 Jan 2020

Please find enclosed on behalf of our clients Greenacre (Thanet) Ltd representations to the Draft Local Plan Schedule of Main Modifications (December 2019) and Policies Map. The Main Modifications comprise a number of changes which are proposed to the previous ‘Pre-Submission Publication Regulation 19’ version of the Local Plan, in order to
make the Plan sound.

Greenacre (Thanet) Ltd are the option holders in respect of Land at Manston Court Road / Haine Road (Policy SP18). For completeness, approximately half of the allocation area has been subject to a planning application (reference OL/TH/18/0261) which was determined by the planning committee in February 2019, with a resolution to grant subject to a Section 106 agreement. The applicant is in the process of agreeing the Section 106 agreement in conjunction with Thanet District Council and Kent County Council.

We wish to confirm our support for the proposed allocation of the land at Manston Court Road / Haine Road. Main Modification reference MM/039 sets out the proposed alterations to Policy SP18

Local Plan alteration (Policy SP18)

The Main modifications at reference MM/039 seeks to provide a clear and consistent approach to strategic housing policies. We wish to confirm our support for the majority of the proposed changes to the wording of Policy SP18.

The proposed alteration to the allocation to increase the number of dwellings from 1200 to 1400 is supported. It is acknowledged that this increase reflects the change to the allocation boundary, and bring it into alignment with the planning application for ‘Phase 1’ of the allocation, which received a resolution to grant from the planning committee in February 2019 (subject to S106).

We wish to also confirm our support for the proposed increase to the approximate average density, which ensures there is a consistent approach to all strategic housing sites across the district.

The requirement for a masterplan to be produced is an appropriate approach, and we support the removal of the need to include a development brief. The proposed text in respect of master planning, open space, infrastructure delivery and phasing plans, and the requirement for a transport assessment are all acceptable and reasonable.

We would query the requirement at SP18 (2) for

2) Provision on site of a serviced site of no less than 8ha for a 6-form entry secondary school and its construction
in a location and in a form agreed with the County Council.

The policy as currently drafted infers that construction of the school is to be funded and/or even undertaken by the developer. Greenacre (Thanet) Ltd are in the process of agreeing a financial contribution towards the delivery of the secondary school as part of the Section 106 linked to Phase 1 of the masterplan. At this time the process for delivering the school remains unknown. The wording of the policy in our opinion is too restrictive and could unduly burden the delivery of housing on the remainder of the site allocation. In our opinion, the policy as worded is not justified and is therefore unsound as it would appear to provide no flexibility with regards to the delivery route of the secondary school.

Furthermore, the policy expressly states a minimum area of 8ha for the school. We have not been provided with any justification for this site area and suggest that in order to maintain flexibility that reference to a site area is removed.

In order to render the policy sound we recommend that it is amended as follows:

“provision on site of a serviced site for up to a 6-form entry secondary school in a location and form
to be agreed with the County Council”

In summary, we are supportive of the proposed alterations to Policy SP18 and the allocation boundary, as set out in the Main Modifications (December 2019). Further clarity is required particularly in respect of the secondary school provision and related financial contributions. We therefore recommend that the draft policy is amended as set out above in order to render the Plan sound.