Open letter to MBC Planning Committee about Woodcut Farm capitulation.

The Maidstone Borough Council Planning Committee is due to meet on Thursday 27th April at 6pm in the Town Hall to consider the MBC Planning Officers’ proposals that no money should be spent on fighting any appeal by Roxhill PLC who wish to develop a 550,000 square foot warehousing and distribution complex at Wood Cut Farm at Junction 8 of the M20 which lies within the Parish of Hollingbourne. Hollingbourne Parish Council will be represented at the Meeting.

Proposed developments on the site and elsewhere at Junction 8 have been successfully opposed over the last 25 years by Maidstone Borough Council, Kent County Council, local MP’s, Parish Councils, Leeds Castle, CPRE, Natural England, and tens of thousands of local residents. Millions of pounds of public money have already been spent fighting various schemes at Public Inquiries there remains strong opposition to development in an area which adjoins the North Downs AONB. Other concerns include traffic, the water supply, and the fact that there are already under utilised developments in the area.  It is also at the gateway to Leeds Castle which is the largest local employer with some 600,000 visitors a year who boost the local economy.

Dr Rebecca Driver, a planning consultant, who has been advising Headcorn Parish Council, has issued this open letter to Councillor John Perry who is the Chairman of Maidstone Planning Committee:-

Dear Councillor Perry

I am writing to you in connection with Agenda Item 16 of the Planning Committee Meeting for April 27th, the land at Woodcut Farm, in order to request that:

  •  you reject the proposal from Maidstone’s Planning Department that you should not defend at Appeal your earlier decision to reject this planning application; and
  • further that you should request that the Council should think again about the decision to support development at Woodcut Farm through the Local Plan.

I am making these requests because the reasoning underpinning the officer’s recommendation is premature, and new analysis calls into question the sustainability of development at Woodcut Farm.

In particular, the officer’s recommendation takes no account of the fact that the Local Plan Inspector has undertaken an additional consultation on employment issues and that the Inspector’s response to the findings of this consultation are not yet known. This consultation, which was on the evidence presented by Maidstone Borough Council in ED118, took place after the Inspector had issued his Interim Findings, meaning those findings cannot be relied upon as evidence that Policy EMP1(5) on Woodcut Farm will remain intact once the Local Plan examination has been concluded. The consultation on ED118 is significant, because some of the evidence presented was not available to the Local Plan Inspector at the time he issued his interim findings, and could well lead to a reversal of of his views on the soundness of Policy EMP1(5) on Woodcut Farm.

In particular, in the response to the consultation on ED118 that I helped prepare for Headcorn Parish Council (which is attached for your convenience), I analysed the results of Maidstone Borough Council’s Site Assessment Exercise. (These findings also formed part of my response to the Appeal for the Woodcut Farm site.) As you can see from Table 1 of the response, which compares the results for the Woodcut Farm site to employment sites that were rejected for inclusion in the Local Plan, there are at least nine potential employment sites, with a combined yield of almost five times the yield of Woodcut Farm, that performed significantly better in the Site Assessment Exercise than Woodcut Farm. Indeed, all the rejected sites had fewer red flags than the Woodcut Farm site. Similarly only 35.5% of the answers associated with the Woodcut Farm site were marked as green, while in contrast for all but one of the other sites (where 43.8% of responses were green) over 50% of answers yielded a green flag.

This analysis not only supports your decision to reject this application, it also calls into question why a site with such poor environmental credentials was preferred in the Local Plan to the available alternatives. The Local Plan Inspector will need to take these findings extremely seriously, because of their implications for the robustness of the Sustainability Appraisal that supposedly underpins Maidstone’s Local Plan. This means he could change his response to the Woodcut Farm allocation, so any decision not to defend your decision to reject this application would be premature.

This type of analysis is taken seriously by Inspectors. It is noteworthy that similar analysis that was presented in the Appeal hearing APP/U2235/W/16/3151144, Land north of Lenham Road, Headcorn, lead to the Inspector to conclude that:

  • “The LPA has seen fit to allocate, despite their relatively low sustainability credentials, a number of sites in Headcorn” (para 35 of the Inspector’s report).
  • the proposed development “would not therefore be sustainable development as defined by the NPPF” (para 41 of the Inspector’s report).

Therefore the Inspector dismissed the Appeal, supporting Maidstone’s Planning Committee’s decision to reject the application. In this case in reaching its decision to reject the application, the Planning Committee had also rejected the Officer’s advice that the proposal was sustainable, because of Headcorn’s RSC status.

I recognize that defending this Appeal is associated with a financial risk for Maidstone Council. However, the time to review whether to defend this decision is when the Local Plan Inspector has issued his Final Findings – findings that will be informed by the new analysis available to him. As such I trust that you will reject this premature proposal and stick to your Committee’s original decision, which was to block development on this site in principle. I also urge you to request that the Council looks again at its approach to site allocations through the Local Plan process, in order to ensure that the available evidence comparing the sustainability of different options is more effectively taken into account.

Please do not hesitate to contact me, if you have any questions on the evidence I have shared with you. I will also be contacting your fellow committee members about my concerns.

Yours sincerely

Dr Rebecca Driver