Local Plan Consultation

Public Consultation

The  final submission draft Policies and Places Local Plan was subject to another 6 week public consultation starting 5 Feb 2018 to 19th March . It will now be submitted to the Planning Inspector who will determine the “matters” (ie the important issues) which need to be examined in public. The 19th March was a strict deadline – unlike the planning application it will not be possible to submit a comment after this date.

The Examination in Public by the Planning Inspector is expected to take place in September 2018.

You can read the plan and  the comments :  http://shepway-consult.objective.co.uk/portal.

The plan allocates a number of development sites in Shepway as well as including a number of  planning policies which will be used to assess plan applications in the future so we would urge you to look at the whole Plan – not just the part affecting Princes Parade.

Here is the guidance we issued on how to make a comment:

Why is it Important to Take Part in the Consultation

Although the council has now submitted a planning application to itself for Princes Parade, it is important that we try to get Princes Parade deleted from the local plan because if it is still in there when the local plan is adopted any subsequent application will be granted planning permission almost automatically even if the current one is rejected.

We hope that the more people who object to the inclusion of Princes Parade as a development site, the more likely it is that the Planning Inspector will look closely at it. Remember it was the previous Planning Inspector who prevented it being developed in 2003.

If you have taken part in the previous consultations but don’t feel that your comments have been dealt with we recommend that you submit your points again as all representations at this stage will be seen by the Planning Inspector. (You can find your previous comments  in your account on the consultation portal .)

Note that this is a statutory consultation so your views do have to be considered. The public have an important role as a critical friend.

Using the Portal

Once you are in the consultation portal select “Places & Policies Local Plan Submission Draft” (blue open sign)

The click on “Read and comment on document” (in blue)

Select UA18 Princes Parade

Read through the section descriptions between 5.126 and 5.144 these give information on aspects of the development.Comments can be made in these sections as well as further down under the Main Policy UA18

You need to create an account and log in in order to make a comment.

You might find it easier to draft your comment in Word and then copy and paste it into the portal when you are happy with it.

You can’t change your comment once it has been submitted but you can submit multiple comments.

Soundness

Unlike the previous consultations your comments will have to relate to the “soundness” of the local plan .

DON’T BE PUT OFF IF THIS SEEMS TOO COMPLICATED – your comments are important and you can submit them even if you don’t understand “soundness”. If you are interested we have included more detail about Soundness below but all you need to remember is to tick “no” in a couple of the boxes ( eg  justified ,effective and consistent with national policy) and to start your comment with the words “Policy UA18 is NOT sound because…”

 

Which Boxes to Tick/Questions to Answer

 

(This section is probably easier to understand if you log into the portal first so you can see what it looks like.)

 

We recommend that you don’t try to submit a comment for each of the supporting paragraphs – just comment on policy UA18 itself.

As stated above you should tick no in some of the test of soundness boxes –  justified ,effective and consistent with national policy  – and start your comment with the words “Policy UA18 is NOT sound because…

You will then need to justify your comment – there is both a summary and a detailed box for this as well as a third box where you can suggest any modifications.

You don’t have to fill out all the boxes but as a minimum you must tick some of the “unsound” boxes and briefly state your reasons.

Your comments will be passed to the inspector but the planning officers may summarise them first. If you provide a good summary yourself it is more likely that your thoughts will be accurately passed to the Inspector.

The next question asks if your representation relates to a new site. The answer is no because Princes Parade was included in an earlier version. Then you have to state whether you wish to participate in the oral examination (Save Princes Parade will make sure we have representatives there) .

As always, it is imp ortant to use your own words and to justify your objections (ie in this case why you don’t think the policy is sound) with good planning reasons. You don’t have to use planning terms – you can respond using normal language.

 

Main Reasons Why Policy UA18 is not Sound

Looking at the Sustainability Appraisal  it is clear that when the council first started looking at Princes Parade with a view to allocating it as a development site, they identified 4 red flag/problem areas: flooding; harm to the historic environment; loss of biodiversity and loss of open space. When they  appraised policy UA18 three of those red flags became pink (presumably because they are claiming that clauses in the policy resolve those issues) but the flooding remains a red flag.
So we suggest that you base your submission on these 4 red flag areas.

You may also like to include the loss of visual amenity. This is suggested in the preamble to the policy but not mentioned in the policy itself. However, this was the main reason that the previous inspector said that development of the site was not appropriate and why it is currently protected by policies LR9 and TM8. (These will be replaced by policy UA18).

Note that unlike the planning application , policy UA18 makes no mention of the diversion of the road.

The council argue that the provision of the public benefits (mainly the leisure centre and the housing/affordable housing)  justify the risk of building in a flood zone as well as the harm that will be done to the setting of the canal. There are alternative sites for the leisure centre (Nickolls Quarry) and the housing so we don’t believe this argument stands up.

Evidence Base

You can find a lot of the supporting documents including the open space strategy and the heritage strategy here.
You might also like to read the Sustainability Appraisal.

If you have time to read these you will find some useful points to support your comments.

More Information about “Soundness”

To be sound the local plan must be

• Legally compliant – the plan must be included in the Local Development Scheme, informed by community engagement a set out in the Statement of Community Involvement and accompanied by a Sustainability Appraisal. You can probably ignore this for Princes Parade.

 • Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development . This is mainly about housing numbers . This is a complex argument which we will address in the formal SPP response.

 

 • Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.  Is the chosen strategy the best one compared to the alternatives? Is it clear how the Sustainability Appraisal has informed the Local Plan? Has it been prepared with the participation of the community and backed up by the evidence base?

 

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; Is the plan achievable?

•Consistent with National Policy – as set out in the National Planning Policy Framework.

There is also a category “complies with the duty to co operate” which you can probably ignore for the purposes of Princes Parade.

How Have Comments from the Previous Consultation been Taken into Account?

 

Princes Parade is still allocated as a development site in the draft plan (policy UA18) despite the high number of objections in the November 2016 consultation on the earlier draft from members of the public as well as Historic England and the Heritage Dept at Kent County Council.

You can read a summary of the previous comments and how the council have incorporated them into the wording of the policies in the current draft (or not) here.
The council seem to have largely ignored the comments about Princes Parade so we will need to restate them so that the Inspector can take them into account.
More Information on the Local Plan Process

If you you would like to find out more about the local plan process we recommend this guidance https://www.gov.uk/guidance/local-plans–2 as well as the excellent “Planning Explained”  leaflet from CPRE. We are at stage 5 on page 43. https://planninghelp.cpre.org.uk/resources/publications

Revised Core Strategy/Otterpool

You might be surprised that Otterpool has not been included in this Plan. This is because it is a strategic site which will be dealt with in the Revised Core Strategy.

The  original 2013 Core Strategy  is the document which sets out the overall strategy on which the PPLP has been based. This is now being revised to take into account a new higher housing need number and proposes Otterpool as a strategic development site as a means of meeting that new housing  target.

The Revised Core Strategy will be the subject of a separate public consultation in the near future.

The Local Plan has to be consistent with the Core Strategy and both documents have to be consistent with the National Planning Policy Framework – the NPPF.