Head of Planning and Development
Maidstone Borough Council
Maidstone House King Street Maidstone Kent ME15 6JQ
Dear Mr Jarman
North Loose Residents Asssociation
MBC Local Pan Review – Regulation 18b – Response
The North Loose Residents Assocation (NLRA) welcomes the opportunity to respond to the Draft Local Plan Review Regulation 18b consultation and the allocations and policies within it.
It is clear that Maidstone Borough Council (MBC) has planned and assessed this Review thoroughly and that lessons have been learned from previous earlier experiences. Engagement with local parishes and other bodies and understanding of their comments, has been considered at an early stage.
The NLRA has benefitted from thorough consultation with our local Ward councillors and presentations from officers to enable us to gain a good understanding of the rationale for the development of the Plan Review process and about site allocations. This enabled us to make our informal views known.
Whilst we understand the need for a continued level of development, this has to be carefully managed so that is truly sustainable. Therefore, in the current policy climate, we strongly support the rightly greater emphasis in this Review on Sustainability, the Natural Environment and Climate Change.
We also support the MBC decision to accelerate the programme for this Review to ensure that decision making remains local and not controlled centrally. This is particularly so in the current circumstances where demand for development growth is now so heavily and
uncertain as a result of the Covid-19 pandemic and all its economic impacts, the continuing uncertainty around Brexit, the rapidly changing patterns for employment and demand for transport and the new levelling up agenda. It is not acceptable for development to be planned as far ahead as 2037 that is based on planning policy and targets set just prior to these effects. These effects must be researched and assessed and future policy shaped to respond positively not as a reaction to those previously set and now probably significantly outdated and overtaken by events.
Spatial Vision and Objectives
Para 4.5 – the NLRA agrees with the strong emphasis on safeguarding and maintaining the borough’s landscapes, but only having ‘regard to’ landscapes of local value and heritage designations is not a strong enough policy response for such important designations. We believe the wording here should be strengthened to give the policy greater weight in these areas.
Para 4.10 – Significant enhancement of the public realm and natural environment has been shown to have been so necessary during the pandemic for the wellbeing of the population. Maidstone riverside presents a unique jewel and opportunity to achieve this for an area of the borough where substantial development is proposed; and has already recently taken place.
Para 4.14 – ‘Provision for an increasingly ageing population’ is important, but this provision must be of housing stock they want to live in and locations where they want to be. Consultation with these groups is imperative to getting the right development mix in the right place. Here in South Ward the design requirements and demand for bungalows is strong amongst this age group, which is why it forms a part of our Neighbourhood Plan. The NLRA would like this demand to be recognised in the strategic objectives and policy.
Para 4.15 – The NLRA fully endorses the vision ‘to retain and enhance the character of the existing blue and green infrastructure’. Both in response to our comments on para 4.10 and the very important role these play in delivering green space, enhancement of biodiversity, leisure opportunities and climate mitigation benefits, right into the heart of the urban and suburban area. We will return to this point later in our response.
The NLRA has previously acknowledged that some development is necessary; we also firmly believe this development must be shared fairly across the whole borough based on sustainability and the geographical spread of demand.
Para 5.22 – We agree that Maidstone town centre cannot accommodate all the planned growth, but we do not agree that ‘edge of urban area’ is the ‘most sustainable location’. The South and South-east of the urban area has already experienced significant levels of
growth in the early years of the Local Plan. Especially in transport, local services and natural environmental terms further development in these areas is not sustainable
Already the very real danger of coalescence between south Maidstone and the inner rural villages exists. This must be prevented at all costs. Continued development of these areas risks good access to green spaces being further pushed away from residents in the town centre and the suburbs.
Green corridors in this area must be protected and with development very limited and then only permitted in these areas where it brings significant opportunities for enhancement and improved access to them.
SP11(B) – This policy should include the Wheatsheaf Parade on the A229. The NLRA would ask that this is added.
SP12 – Significant development has already occurred in south Maidstone and the villages to the south. This has brought a large volume of extra traffic onto the A229. Yet more development is planned by this Review – Marden 237 (extra properties), Staplehurst 837, Coxheath 295 and Boughton Monchelsea 92. Provision of transport infrastructure has so far failed to match the development delivered.
Before further development is permitted and delivered key infrastructure schemes must be completed on the A229 and A274. These include Linton Crossroads, Wallis Avenue/ Willington Street/Sutton Road, Wheatsheaf and Armstrong Road Junctions, all being top priority improvements. Bus improvements need to incorporate off carriageway lay-bys or half lay-bys to keep traffic moving.
SP13 (b) and SP14– The NLRA fully supports the policies on Open Space Development and The Environment; and the objectives in paras 7.119 and 7.124 in particular. Priority must be given to on-site provision if this at all possible. The Blue Green strategy of creating links and chains to help wildlife move into the urban and suburban areas is a very important biodiversity enhancement and for the promotion of wellbeing. Where this supports fragmented areas of Ancient Woodland, like here in south Maidstone, this is particularly beneficial.
The partnerships proposed in para 7.126 must also include local communities.
SP15 – Whilst ageeing with the Design approach, more attention should be given to design of individual developments to ensure we really do provide top quality housing sites. These developments must be able to blend in better with existing areas, with plenty of space and roads wide enough to allow parking on both sides of the road and still have clearance for vehicles between. Greater attention by planners should be given to Neighbourhood plans and local Character Assessments.
Detailed Site Allocation Policies
Policy LPRSA270 – Land South West of Police HQ, South of Maidstone – This site is partially within our Neighbourhood Plan area and importantly within the Blue and Green Corridor between the Loose Road (A229) and Sutton Road (A274). It is also within the Greensand Ridge Local Landscape of Value area.
This green corridor provides a crucial unbroken corridor between the open countryside and the Air Quality Management Area of the A229 at the Wheatsheaf roundabout. It is also an environmental buffer zone between the urban developments.
In principle we can support a level of development on this site provided the following conditions can be met;-
1. That the density and size of the development is one which reflects the edge of urban area and its transition into open countryside.
2. That the Green corridor can be significantly enhanced as a result of this development and that an open space corridor of a minimum of 50 metres, running alongside footpath KM99 is provided. Preferably splaying out to the south as it reaches footpath KM98. This requirement would support policy SP14.
3. That the open space created be transferred into the ownership and management of a local group protecting the environment, to prevent any future development pressures.
4. That traffic generated from the site would exit towards the A274 Sutton Road only.
5. That any possibility of traffic from the site percolating to Boughton Lane or through Boughton Monchelsea be removed through the closure of a section of Pested Bars Road/Cliff Hill Road to all traffic.
6. That the footpath network linking the site to the local area be enhanced and improved.
In addition to these policy requirements we would also ask;-
7. That the NLRA be considered as the organisation to design and manage the open space created in the 50 metre strip adjacent to KM 99 and north of KM 98 and be consulted on the remainder of the open space.
8. That dedicated CIL or Section 106 contributions be secured to deliver conditions 2 and 6.
9. That the site design should ensure any children’s’ play area and SUDS settlement pond should not form part of the open space strip and be addition
Policy LPRSA235 – Land at Boughton Lane, South of Maidstone Urban Extension – This site lies on the boundary of the NLRA Neighbourhood Plan area and will have impacts on this
area. This site was removed from the allocations in the Local Plan, following the Examination by the Inspector, due to the significant impact of congestion on Boughton Lane.
The NLRA can only accept the inclusion of this site in the Review provided the following conditions are met;-
1. That the density and size of the development is kept at a very low level, one which reflects the edge of urban area and its transition into open countryside and that minimises any congestion impacts on Boughton Lane . Only a small scale development is acceptable on this site.
2. That the vehicular access and egress be near or alongside footpath KM55 at a location which provides good sight lines onto Boughton Lane. The access/egress must not be at the north end of the site at or near a dangerous corner.
3. That the open space created be transferred into the ownership and management of a local group, to prevent any future development pressures.
4. That the footpath network linking the site to the local area be enhanced and improved.
In addition to these policy requirements we would also ask;-
5. That the NLRA be consulted about the design of the site and public open space.
6. That dedicated CIL or Section 106 contributions be secured to deliver conditions 2 and 4.
Finally, may we thank you for the opportunity to contribute to this consultation and hope that our views will be taken into consideration during the further development of the Local Plan Review document.
Sean Carter, Chair
North Loose Residents Association firstname.lastname@example.org 21st December 2020
Correspondence address –
c/o David Southgate