Comments on the Maidstone Borough Council Local Plan need to be in by 30th September.

Comments on the Maidstone Local Plan need to be sent to Maidstone Borough Council by 30th September and more details can be found on the briefing documents in Christopher’s Village Shop or at https://www.hollingbournepc.kentparishes.gov.uk/mbc-launch-public-consultation-on-the-local-plan/

The matter is likely to be considered at the next Hollingbourne Parish Council meeting Monday 9th September at 7.30pm in the Cardwell Pavilion. Key aspects of the plan are increased housing without sufficient investment in infrastructure with no apparent consideration of the effects of Brexit on the local area.

Pictured below is Parish Clerk delivering the five copies of the plan for Hollingbourne provided by MBC for the 900 residents to Christopher’s Village Shop.

Vicki Smith handing over the five copies of the Local Plan review document for the 900 residents of Hollingbourne to Tania Shillingford in Christopher’s Village Shop.

Robert Sinclair from Leeds who has been active in opposing development around Junction 8 of the M20 in Hollingbourne has circulated the following very detailed draft comments locally. Please Read More for further information. These comments will in due course by considered Mr William Cornall, the MBC Director of Regeneration and Space.

TQ1

Good growth is only achievable from a sound economic base. To achieve that status there needs to some adjustments such as reduce housing development until the infrastructure etc to support it, is present. The market might assist the imbalance between infrastructure/housing because growth is currently weak. Does the question imply that there will be growth? MBC assumes that there will always be growth, and historically this factor gets them out of trouble. There will be a nasty shock if there is no growth, growth in the wrong places or negative growth. There is no forward planning if the growth assumption disappears!!

MBC assumes that there will always be growth, and historically, this factor gets them out of trouble. There will be a nasty shock if there is no growth, growth in the wrong places and negative growth. Where is the plan B?

Does the question imply that there will be growth? There will be a nasty shock if there is no growth, growth in the wrong places or negative growth.

There is no forward planning if the growth assumption disappears!!

OQ2 What could the Local Plan Review do to help make our town and village centres fit for the future?

Appreciate that the market needs to be understood. It is the market that will finance improvements that will make “towns and village centres”. Match housing demand, and development whilst ensuring there is proper infrastructure provision. Market demand for retail uses needs to be carefully considered. This use will diminish, so have a plan B to reduce the impact of void accommodation.

OQ3 How can the Local Plan Review ensure community facilities and services are brought forward in the right place and at the right time to support communities?

Listen to the communities and engage with them. Schools, medical, station car parking, protection of retail uses, pubs, post office and banks.

OQ4 What overall benefits would you want to see as a result of growth?

If there is going to be any growth, then to retain it, MBC needs to focus on those matters that will curtail growth and make Maidstone an unattractive location – such as – Congested roads, overcrowded schools, better transport, (train & car parking), protection of the countryside, safe environment, medical facilities, water, air quality, poor planning.

Accordingly, it is the items referred to above that need to be addressed if there is growth to provide the benefits to the community.

MBC needs to get involved with those organisations which are outside their remit and be seen to connect with them, on behalf of the Community examples are: Roads / KCC, Crime /Police, Water – Southern Water/ South East Water/ Air quality/ Climate Control/ Broadband / Mobile 5G. Restore trust in MBC.

Without growth MBC will struggle to address the organisation(s) that can make a difference for MBC and encourage growth.

OQ5 What infrastructure and services, including community services and facilities, do you think are the most important for a successful new development?

EV – power points, understand and plan for more than one car parking space per household. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/818810/electric-vehicle-charging-in-residential-and-non-residential-buildings.pdf

Safe and secure play areas. Installation of broadband connections via cable for phones and TV. There is a risk that if more people use streaming services like Netflix that existing broadband will slow down !! Future proofing needs to be considered now.

Plan for 5G connections.

OQ6 How can the Local Plan Review help support a thriving local economy, including the rural economy?

There needs to be digital connectivity. MBC needs to actively promote this matter. MBC needs to be seen taking the initiative and putting pressure on operators. Free Wi-Fi through Maidstone would help retailers etc. Investigate 5G. MBC needs to take the lead and make it happen. There needs to be much more support for the tourist industry. Maidstone should be marketing itself promoting its future prospects as opposed to just reminiscing about the past.

OQ7 How can the Local Plan Review ensure we have an environmentally attractive and sustainable borough that takes a pro-active approach to climate change?

The keys issues that will make MBC “environmentally attractive” are clean streets, reduced noise, reduce vehicle fumes, parks, footpaths, air quality, land quality, waste. Consideration must be given to the effect on people and communities in terms of a wide range of issues including public health, planning, transport, energy and climate. MBC must be seen to understand these matters and give serious consideration to these issues when considering planning applications.

Encourage the use of “green materials”.

OQ8 Are there any other themes, issues and choices that you believe we should address as part of this Local Plan Review?

The consultation process should not simply to provide an endorsement of the MBC plan produced by officers. It is supposed to encourage a joint approach between the Community and the Local Authority and should be seen as a way to improve the low level of trust that currently exists.

Obviously, “Politics” will interfere, but it is clear irrespective of politics, that we all want what is best for the Community. It is how we get there that has to be addressed. The ultimate goal is to produce a Plan that is fully endorsed and understood by all Councillors and therefore representing the endorsement by the local community who voted for them. The current plan was adopted by the majority of the members that voted. All members must vote, and their vote should be fully published – named vote.

As a general comment, the questions that are being put by MBC to the community appear to be designed to obtain answers that the Council want to hear so that the “advice” that has been formulated by officers can be said to based on the views of the community. MBC has form for seeking support from the public based on their “unbiased” questions. The junction 8 survey was brought into disrepute. Some of the questions feel that they have a bias, and this will lead to the wrong conclusions because of the wording. As a general point, again, revealed by the style and content of the questions there appears to be a lack of knowledge in relation to market forces and the current state of of the economy and the impact of BREXIT.

It appears that MBC wants to carry on without reviewing whether they failed to fully brief the inspector. In other words, there is an impression that the Local Plan is set in stone and really does not need any tweaks to improve it? It is up to the officers managing this process to clearly show that they are listening to the community.

TQ1 What do you think should be the end date for the Local Plan Review? Why?

The local plan review should be until 2037. On the assumption that there is a regular 5 year review this period can be seen as moveable. To predict any longer would be very risky. Very few companies looking for certainty and reliability budget for more than 5 years. 20 Years is reasonable when considering capital projects, but the reviews need to rigorous and expect changes will have to make.

TQ2 Have we identified the correct cross boundary issues? Please give reasons for your answer.

The major cross-boundary issues are: employment/journey to work/roads/trains/schools/housing/retail impact/Brexit.

MBC in their submissions to the inspector gave the impression that jobs for residents should only take place within the MBC area. They did not acknowledge that there were industrial locations outside the MBC boundary which could and would provide job opportunities for Maidstone residents. The fact is that there are.

London provides a huge amount of jobs for residents of MBC.
The future impact from the London Resort at Swanscombe Peninsula – 9,000 jobs (6,500 full time) plus 2,300 jobs (1,800 jobs full time) Hotels etc needs to be assessed particularly having regard to the MBC tourist industry.

The journey to work issue needs further consideration and acceptance that the only way to reduce the impact of this travelling is to support and encourage working from home. But this needs proper connectivity.

The M20 whilst potentially an asset for the MBC is now seen as a reason not to work/live in the Maidstone area. This motorway is currently under repair to convert it to a “smart motorway” and is suffering from Brexit barriers etc that reduce speed and increase accidents. Long term, its value should increase.

Now is the time to consider some “expensive” road improvements that will impact on the area. The 6.8 billion Lower Thames Crossing will push more traffic into the area. As a consequence consideration should now be given to a new junction 8A.

With regard to trains, the future of the Southeastern franchise is in doubt. There need to be discussions with the Department for Transport. At the risk of being too controversial an earlier decision by MBC needs to be reviewed. The opportunity for a parkway station for HS1 by junction 8 should be reconsidered. The existing links into London are very unreliable, overcrowded, and infrequent.
Adjoining local authorities that have land protection issues may seek to transfer the housing requirements to an adjoining authority. MBC needs to consider the protection of the countryside. MBC should take active measures to ensure MBC does not become the dumping ground for those local authorities that have taken action to enhance their landscape assets.

Retail impact issues need to be considered. Not all competition will come from adjoining boroughs. There may be instances such as the Ashford Designer Outlet which might be seen as a threat to Maidstone. The reality is that its 100,000 sq ft extension to the 185,000 sqft will attract customers within a 45-minute catchment. Some of this traffic will be looking for tourist features and could be drawn to the MBC area.

MBC appears to be very defensive and wants to control the destiny of the community. The reality is that life has changed and there needs to be an appreciation that the greatest benefit can be derived by co-operation with adjoining authorities. MBC is too small to do everything.

TQ3 How do you think the council can achieve a consistent annual rate of housebuilding throughout the Local Plan Review period?

The council will have little influence on achieving a consistent annual rate of house building. It is the market that will determine the rate of housebuilding. All that MBC can do is to ensure that the planning process is certain, efficient and does ensure that the necessary infrastructure is in place to support existing needs and does future proof additional housebuilding.

The Council could provide additional housing and borrow at preferential rates of interest cash to finance new build housing.

TQ4 Have we identified all the possible types of housing sites?

MBC has called for sites and this is a way to identify sites. This is a very outdated approach.

The Council has local knowledge and could look at existing locations that will not be highlighted by the call for sites initiative.

The Council should use its skill and experience to look at the market and to “fast forward” to see how current uses will develop. Twenty years ago the trend was offices, and out of town retail. The Council sought to protect in town retail. This approach is very negative.

All it does is stifle initiatives that are outside the control of MBC. MBC needs to obtain external professional advice looking at retail, industrial and carefully consider sustainable locations. The facts are that the emphasis needs to be brought back into the centre of Maidstone and focus on reusing and introducing new uses that will improve life for the community.

So in simple terms, the biggest driver for new residential development will be the change of use from retail to residential. In and out of town sites should be considered. The biggest change that is needed is more flexibility in the use classes order. MBC needs to look at redevelopment/ regeneration. There will be huge changes in the built environment and these needs to be considered and embraced. MBC needs to stop GDO changes of use from offices to residential without having a planning input. There needs to be an article 4 directive to address this change of use and put a stop to this form of residential development.

MBC must ensure that there are proper housing standards maintained. The risk is that this form of residential conversion will become tomorrows slums. This acceptance of substandard accommodation will lead to social problems that MBC can do without!!

TQ5 What approaches could we use to identify more small sites suitable for allocation in the Local Plan Review?

Small sites will come out from redevelopment and regeneration opportunities.

TQ6 What approaches could we use to increase the number of new homes being built on brownfield sites and to make brownfield development more viable and attractive to developers?

MBC needs to understand the market. Brownfield sites will arise when a site is viable to develop. Some retail sites will reduce in value, because of demand, and this value may be below residential values. When that occurs residential development will be viable. The issue is that it is the land with the highest residual value that will be developed. If land is contaminated or too expensive to develop, a brownfield site will not be of interest because the residual value is too low. MBC could “pump prime” and reduce the costs of development by cleaning up a brownfield site. There is an inherent risk for MBC is providing this initiative. This is where politics comes in!!

TQ7 What factors should we take into account when considering minimum density standards elsewhere in the borough, beyond the town centre?

The basic principle is that land should not be wasted and land for development needs to be developed into a sustainable community. There is a need for play/community areas that are designed to increase the sense of community. The space standards for good housing need to be imposed and there needs to be considered matters relating to safety and security. Too often planning is more concerned with access for the refuse vehicle. Public transport will determine the need for cars. Poor public transport results in the need for cars. In areas where cycling is potentially safe or not too difficult (not too hilly) this use should have a designated area for cycle storage etc. There is a need to ensure that the density can support a digital network to ensure connectivity.

TQ8 Have we identified all the possible types of employment sites?

The question is slightly loaded. What is the purpose of identifying all the possible types of employment sites? Is it to ensure that there is sufficient land within the MBC boundary to provide work for those living the MBC area? This question fails to acknowledge the reality of the fact that some residents of the MBC travel outside the MBC area to work and some work from home.

At the local plan Inquiry, the impression was given and the inspector accepted the evidence that there was a shortage of industrial land in the MBC area. The inspector might have reached a very different conclusion about the need for Woodcut Farm if he had appreciated that 5,118 sq m of potential accommodation at Eclipse Park had been omitted to be included in the total of available land. This conclusion might have been reinforced if the fact that Newnham Park Bearsted had also been excluded because it was supposed to be for Medical Purposes

The key point is that the plan should consider not just the amount of available land – the quantitative need but also the qualitative need.

Accordingly, it is correct to look at sites outside the MBC boundary such as :

• Aylesford Paper Mill
• Sevington
• London Medway Commercial Park
• London Resort –(535-acre theme park)

The consultation process should have highlighted these locations and the message that MBC has sufficient land to satisfy local need would have been made.

In addition there, other non-specific sites in London where current residents work and some future residents will work.

TQ9 What approaches could we use to identify sites in and at the edge of the town centre for future shopping and leisure needs?

The market should decide. The use of the artificial sequential test will not bring retail and leisure business back to the centre of Maidstone that MBC is seeking to protect. The fact is that the market has changed. Traditional retail is struggling, and the net result will be more closures. To protect retailing, there needs to be excitement and lack of aggravation. Stores need to adjust and there is a requirement for ease of access and parking etc. The rates cost has had a huge impact on the viability of retail when fighting the internet offer.

MBC is now receiving direct experience in trying to develop the site it purchased (Former Royal Mail Sorting office). In theory, this site could house a large retail operator. It could have housed most of the new M&S store at the “edge of the town”. If planning (for M&S) had been refused because the sequential test result, they would have gone elsewhere. Next, failed the test, but promised to keep a store in town? The conclusion is artificial planning tools will not achieve new development.

If MBC wants to support and introduce more retailing then MBC should be actively promoting real activity in the centre, such as leisure uses and residential. What is required is positive planning. If retail operators do not want to come into the centre instead of opposing the use because it not in the existing area, the approach should be to encourage it. If they trade successfully, more people will be attracted to the Maidstone area, and this could deflect trade from places like Bluewater and Tunbridge Wells. (This is the approach that Ashford took). If the offer is attractive, the shoppers will come. The style of shopping probably has to change. Encouragement of more speciality shopping supported by free wi-fi would be positive.

The market has provided sites outside the town centre. However,the reality is that much of the out of town stock is over rented and is set to struggle. These sites may offer a location for alternate uses such as schools, housing and leisure uses. The more interference by the MBC in the market will cause uncertainty and disinvestment. MBC needs to be simply more supportive of reusing assets that are past their sell-by dates.

“Out-of-town retail has consistently outperformed its high street counterpart in recent years, with both opportunistic retailers and customers trading town centres for retail park shopping. Rental analysis of the retail park sector shows that the next five years could be testing for landlords as vacancy and lease terms work to suppress asset values. According to Radius Data Exchange, over 50% of retail park leases signed since 1990 expire or experience lease break between now and 2025. The outcome of this is that large swathes of out of town stock will be vacated or revalued. While it is unlikely that more occupiers will seek to evict themselves than remain, what we should instead expect is the sector to begin to revalue itself at the will of tenants. We know this from additional analysis into the current costs of renting, which show that many occupiers are paying over the market rent. RETAIL PARK LEASE COVENANTS SINCE 1990: OCCUPIER LEASE START AND EXPIRY DATES WITH LEASE BREAKS Cheaper rents, more space and free parking have offered welcome relief against a turbulent period on the UK’s high streets. However, with valuations heading south and new space still being built out despite the relentless increase of online spend and occupier consolidation; is the sector in danger of becoming overrented? Radius Data Exchange looks at the top headlines from the sector.” (EG research)

TQ10 Do you think there should be changes to the current settlement hierarchy? If yes, what evidence do you have for your answer?

There should be an expansion of the hierarchy, namely: 4. Smaller Villages such as Bearsted and Leeds. At present, there is a lack of focus on these locations and they only get attention when it features in the planning meetings. Some of these communities feel that MBC does not consider them properly. The fact is the sum of the villages makes up a significant part of the MBC area. Maybe not in numbers but it does in terms of space. It these areas that feel cut off and suffer poor infrastructure. These areas not large enough to be able to focus on the issues, and it is this point that needs to be addressed, and MBC should provide guidance.

TQ11 Which is your preferred option for the future pattern of growth (A, B. Bi or C) and why?

The preferred option for development for the future pattern of growth is A.

• Higher density of development – encourage additional floor space – upper space
• Better transport
• Alternative uses to fill voids
• Improve connectivity – wi-fi and provide broadband networks / 5G connectivity.
• Stop office conversions with planning controls to avoid future slums.
• Start by pump-priming and develop its Maidstone East Site. Show confidence.
• Change and improve the perception of Maidstone. Make it a great place to live.

The Maidstone focus will provide quick solutions to the needs of the MBC area. Concentrating on this area for the next five year will produce real benefits and show to the community the progress that MBC has made.

During this period MBC could look at locations that fall within category C. The basic principle would be “clean sheet approach” and start from scratch to produce a new settlement that will avoid overcrowding in existing settlements which ruin their character.

In simple terms the new settlement needs :
• Good design
• Good connectivity – roads/ motorways & trains
• Good mixture of housing, to rent and to buy, including affordable and retirement dwellings. Affordable house with preference to local people.
• Play areas
• Schools
• Medical
• Local shopping + post office
• Digital connectivity – 5G, broadband and cable
• Have regard to air quality and EV power points etc

In other words, a ten-year plan to reach say 5,000 house which will relieve stress in existing communities whilst at the same build up a real sense of community. The balance of the existing housing allocation to meet government requirement to be focused in Maidstone. During this development period, it will allow MBC to take stock and improve the existing local infrastructure with the firm objective of having the infrastructure ahead of additional development that requires it.

The dispersal approach leads to ribbon development that has to be filled in. Communities lose their identity and community spirit. Development south of Maidstone is an illustration of poor planning. Sutton Valence will be joined up with Maidstone linked by a poor road connection which results in poor connectivity, poor air quality, noise and congestion. Existing communities will vote with their feet and there will be dispersal away from the MBC area. This will translate into probably negative growth and poor community relations and a full-time job for the police.

TQ12 For your preferred option, what infrastructure would you want to see brought forward as a priority?

Roads and services linked to a planned master plan that would bring additional infrastructure need to match/anticipate the increase in the local population – Schools, doctors, and play areas etc.

TQ13 If your favoured option won’t achieve the number of new homes needed, at the rate they are needed, what combination of options do you think would be best?

This should not be a race for growth. By proper planning, the number of houses (residential units) will be achieved. The market needs to drive the objectives. The developers will not want to flood the market. This statement illustrates a defeatist approach and lack of confidence in the need for new housing.

It is the market that will determine the speed of development. The key feature has to be quality of development. The MBC role is simply to source a location that is sustainable and encourage it by supporting good development. This should not be a numbers game for MBC. MBC needs to be transparent in their negotiations with developers to obtain the planning gain associated with this opportunity. The CIL and s106 contributions need to pay for the infrastructure required to support new development. If the developers can see that their payments do make a difference and provide the real benefits to their customers, they will seek to make construction profits as opposed to additional land profits. It is a share of the land value/profit that needs to be obtained for the community to finance the infrastructure. It is very important that the existing owners understand the requirements in financial terms to develop the land. By managing their expectations, MBC will be able to deliver the funding for the infrastructure that is required.

TQ14 Have we identified the correct areas of focus for future masterplanning? What are the reasons for your answer?

MBC has set out the basic matters to be considered when “master planning”. The mistakes in the past that are directly attributable to bad planning must not be repeated. In the ’60s bad planning resulted in poor social conditions, and at that entails.

Well planned development will last and be looked after, retain its value and be sought after. Good design should not cost more.

MBC should be careful not to impose their own style on the developers. The result is likely to be a “Heinz 57” compromise that has the planners input because of the developer’s fear of a planning refusal. Planners have power without responsibility.

TQ15 Should the national space standards be incorporated into the Local Plan Review? What are the reasons for your answer?

New accommodation must comply with space standards. If they are not considered properly it will result in poor housing, which will have social implications.

National space standards probably were not be properly considered in respect of all the Office to residential use conversions, and this has produced sub-standard solutions. Hence the suggestion that there should have been involvement by the planners to secure good planning of the space. The number of conversions need to be considered and the impact that they will have on the stock of residential units. Some of these units will not have the proper national space standards. Therefore the value of some of these conversions which are produced to a price will detract from the objective that MBC needs to achieve, namely good housing.

TQ16 How can the Local Plan Review best plan for the different types of housing which will be needed?

The local Plan review needs to fully understand the market. There is no acknowledgement that the buy to let market is going to produce additional accommodation to buy. Landlords are not able to achieve a return that is required for the risk of ownership because the tax treatment (reduced interest offset / write off for repairs ) has changed. Fundamentally the value of the investment has diminished, and the threat of the planned withdrawal of “section 21” will probably finish this market.

So the rental market will diminish, and the owner-occupier market should increase. Has any work been carried out to assess how these “windfalls” will be accounted for in assessing the housing numbers?

It is likely that existing occupiers will have to move out, and this will increase the stress on the local market. It is also likely that the purchasers for these units will be removed from the market, depressing the demand for new housing?

There is an opportunity to attract the institutional investor in the Buy to Rent market. The weight of money available is huge, and the developers will address this market to offload existing stock and presell units.

The need for affordable housing will have to be addressed directly with institutional investors. The key to a successful outcome will be achieved if the management of these units is professional and has regard to the need to provide affordable accommodation.

Custom and self build housing will still be subject to the planning requirements. If house prices increase, then this form of housing is a way to secure accommodation. Self-build can produce higher-quality housing and should be encouraged.

The housing strategy has been devised to assist in reaching the Government’s housing targets. The risk is that these excessive targets will be reached at the risk of ruining the community. New housing would be acceptable in the right places and with the right amount of infrastructure.

MBC must resist office conversions without their input to ensure quality accommodation. Poor conversions will be tomorrow’s slums. There needs to be further consideration of an Article 4 direction to adjust the PDR rights associated with office to residential conversions.

The current resistance is a direct result of the communities perception that MBC wants more housing to obtain the benefit of the new Bonus Scheme, and that might be the real driver. The net result is that the drive times are getting longer because of traffic congestion. Schools are required. The queue at the medical centres to see a doctor have got longer. The dialogue between the MBC and the community needs to be increased. The recent publicity relating to secret meetings, and the performance or lack of it, in relation to the Leeds Langley bypass produces a feeling of mistrust. There is a feeling that MBC just goes through the motions and contributing to this consultation is a waste of our time and effort.

Whilst it is fully understood that Local Authorities have very tight responsibilities with regard to “funding” the community might be persuaded that MBC has a vested interest in providing the infrastructure necessary to support the new housing that they say is being imposed by Central Government.

Without going into detail I respectfully suggest that there needs to be a full review of the ways that MBC can be fully involved in developing residential accommodation. For instance utilising funding sources such as “The Public Works Loan Board (PWLB) is a statutory body that issues loans to local authorities, and other specified bodies, from the National Loans Fund, operating within a policy framework set by HM Treasury. This borrowing is mainly for capital projects.”

“PWLB also lends to major local authorities. Since 2004, major local authorities have been able to borrow without government consent, provided they are satisfied they can afford the borrowing costs. To this end, they are required by law to “have regard” to the Prudential Code, published by the Chartered Institute of Public Finance and Accountancy (CIPFA) and MHCLG. The PWLB requires assurance from the authority that it is borrowing within relevant legislation and its borrowing powers.

Under the current legislative and policy framework, the PWLB is a non-discretionary lender and it is not part of its arrangements to require information on the reasons for, or circumstances surrounding, loan applications or borrowing activity. The DMO’s responsibilities are for timely administration of the function within the set framework. Responsibility for local authority spending and borrowing decisions lies with the locally-elected members of the council, who are democratically accountable to their electorates.

Moneys are, as provided by Act of Parliament, drawn from the National Loans Fund and rates of interest are determined by HM Treasury.

Loans to local authorities are automatically secured by statute on the revenues of the authority rather than by reference to specific revenues, assets or collateral.” (Extract from UK Debt Management Office”.)

This a matter that should be directed at “professionals” who have the experience in progressing Property Finance utilising Institutional Investment without the pitfalls that have been apparent with PFI projects. There is a current appetite for Buy To Let investments as mentioned above and with MBC pump-priming, this could be very beneficial to the community and politically acceptable.
Whilst the local plan is focused on planning issues there has to be a realisation that the plan may require assistance from MBC to make it happen.

TQ17 How can the Local Plan Review best plan for the accommodation needs of Gypsy & Travellers and Travelling Showpeople?

The local plan has a statutory duty to address this issue.

TQ18 How can the Local Plan Review help ensure that local economic growth benefits everyone?

In my opinion, there is a real problem with the Maidstone Economic Development strategy. It fails to acknowledge the market place. Without a better market understanding, all the great aspirations will fail to materialise.

Maidstone town centre is going to suffer badly from the current trend to shop away from the High Street.

According to new figures from the British Retail Consortium and Springboard survey (Aug 2019),:

• Footfall last month was also the weakest it has been in July for seven years after an overall decline of 1.9%.

• Shopping centre footfall was the hardest hit, with a 3.1% year-on-year decline in footfall in July.

• High street footfall fell by 2.7% for the same period, while retail park footfall grew by 1.2%.

The local plan must come up with a strategy to reduce the impact of what could be a devastating problem.

There has to be an acceptance that MBC needs to acknowledge the problems. Once that point is understood, the major problem is outside their control, but it can seek to regenerate the area.

Be more flexible in respect of alternative uses. Encourage proper residential opportunities and increase site densities.

The failure to develop the former Royal Mail sorting office site must be seen as a failure. Maidstone needs a confidence boost. This project could have influenced the market positively. It is a real concern that the published plans fail to fully appreciate the fact that this site is potentially a “gateway” site and should focus on the fact that it could be a proper transport interchange where buses, cars and trains connect. Spending £80,000 on architects and potentially another £1.5m to convert what was effectively a bus lane into the MBC bus/coach station will convey the wrong impression about Maidstone. These projects should not be allowed to become the epitaph for Maidstone.

Life needs to be encouraged back into the centre. Being at the top of week street it could make a huge difference to pedestrian flows. These schemes need to instil confidence.

To suggest that MBC can “improve the infrastructure” is perhaps overstating the facts. Just look at roads. MBC holds itself out as being able to influence this matter. MBC consults with KCC, and if they indicate that there is no problem, planning is given. If MBC wants to be really influencing this matter, then they need to engage with KCC and make sure that their consultation response is going to firstly ensure that the direct impact from the new development has been carefully considered. How will it impact on the existing community and if it does, what proposals are they suggesting should be made to ensure that traffic congestion, safety, air quality and noise are all addressed? Secondly, if mitigation works are required, to ensure that the infrastructure does take account of this matter. MBC also needs to be seen to be co-operating with KCC in making sure that the infrastructure contributions be they CIL, S 106 or S 278 are correctly directed to pay for roads, schools, and medical.

Apparently, MBC is going to obtain evidence “about the realistic demand for new office space”. At the local plan Inquiry, there was a clear indication that there was, and this was conveyed to the Inspector who interpreted, it is suggested, this advice incorrectly.

Again, the lack of market intelligence is appearing. There are different types of offices. There are requirements that make a location suitable for office development. All these matters have to be considered.

MBC needs to be more open and accept that uses at locations will vary, and this possible change of use should be considered in assessing available land for development. It is correct to have a flexible approach.

The MBC Economic Development strategy needs to consider in addition to the retail disruption, that it must as part of its duty to consult analyse where people currently work. The results will reveal that there is a huge amount of cross border traffic and that this will continue with the developments at :

• Aylesford Paper Mill
• Sevington
• London Medway Commercial Park
• London Resort –(535-acre theme park)

As part of the MBC research, there needs to be a discussion with the train operator (Currently Southeastern) and TFL plus the Mayor of London. There is a huge number of MBC residents commuting into London and beyond on a daily basis. Again, this point needs to be considered against the background as to how work patterns and methods have changed.

The conclusion that will be reached is that MBC does not have to be concerned that there is not enough land for commercial development.

It has been mentioned in other sections that MBC has made a huge mistake in basically supporting office conversions. The legacy will be substandard residential space. It appears that numbers were more important for MBC.

Any additional commentary at this stage would serve no useful purpose.

MBC needs to urgently obtain outside Independent advice and for the brief to be provided to the “professionals” not to be restrictive in the hope that the advice supports the MBC approach. This matter needs a serious wide-ranging review based on evidence and experience. The firm reporting must be truly independent and be able to withstand scrutiny.

This is the most important part of the Local Plan, and MBC needs to get it right for the benefit of the community.

TQ19 How can the Local Plan Review help sustain our town and local centres?

At the risk of repeating my comments for TQ19 and other questions, it is the market that will sustain the town and local centres.

In simple terms:

• Make Maidstone (and local centres) a more exciting place to live & There needs to be more activity, and this can only be sustainable if there is real demand to be there.

• Why will people come – There needs to be a critical mass for the uses that will be sustainable in the future :

• To Live – Allow more change of use – i.e. increase good residential accommodation/leisure uses. (increase site density).

• Shopping – This must be made more exciting.

• Accessibility – Public transport, private cars, more EV charge points, free Wi-Fi within the bid area

The BID initiative is a good exercise, but my concern is that it does put an additional burden on retailers. If it can make a difference that would be good. This does need careful monitored to prove its value.

TQ20 How can the Local Plan Review best plan for the new infrastructure that will be needed to support growth?

Infrastructure is probably the most important aspect of the local plan which interestingly and correctly the Technical Documents states “ The council can’t do this alone”. So fundamentally, there needs to be a real commitment to focus on those matters that are identified. It is very concerning that the Infrastructure Delivery Plan (Feb 2016) described as “The IDP is a “living document” and will be kept under regular review as new or updated evidence is made available. The Council will continue to engage with infrastructure providers to ensure that the IDP provides a robust and up-to-date evidence document to support the examination of the Local Plan and the development of the Draft CIL Charging Schedule.”

It would have been useful to have included in the technical document a simple update so that progress can be assessed by the community. (Authority Monitoring Report – last update July 2016) It is important to clearly understand where the objectives have been implemented and have a clear report setting out, with a timeline, future implementation dates and a note of additional Infrastructure improvements that MBC want to process, again with possible implementation dates. In other words, an updated Infrastructure Delivery Plan which sets out the total current costs to implement the infrastructure proposals with a “guestimate” of the unknown costs so that the full extent of the MBC’s proposals can be understood is required. There also needs to be a commentary from the Chairperson of the relevant committee so that the community can see if MBC is on target and what needs to be done to achieve its objectives which are so important. This commentary should also provide an assessment of the contributions received or budgeted to be received from CIL / S106 contributions. Without out this information, it is not possible to review this matter fully.

The community, in general, were horrified to see the phoney war between KCC and MBC. The waste of public funds did not improve the perception of the two authorities.

There needs to real progress and for MBC to engage with the relevant authorities on behalf of the community and engage with them to produce positive results and to make a difference.

There needs to be transparency in respect of the various projects that are the focus of infrastructure funding to ensure that there is full accountability and a proper assessment of needs to identify funding shortfalls.

The clear mission statement is for MBC is plan for upgrading the infrastructure “need” ahead of the requirement so that it is always ahead of the “need”. At present, as set out in the technical document, there is much work required to be done. As mentioned above there needs to be an annual assessment to identify success and highlight where there are still deficiencies in procuring the necessary infrastructure. Responsibility needs to be directly assigned. At present, it appears to be members via a committee? Perhaps the officers should be given delegated power to move matters ahead and report to the relevant committee. This would provide management by exception and enable the key issues to be identified immediately and addressed.

The key partners that must be engaged with are :

• KCC
• Cable / broadband operators/ mobile phone companies/ 5G rollout
• South East Water & Southern Water
• Uk Power Networks and Southern Gas Network plus the National Grid
• The rail operators and network rail.
• The bus companies
• TFL
• Highways Agency
• Education Department at Department for Education
• NHS
• Institutional Investors
• The Police & Fire Department
• Sports Organisations
• Locate in Kent
• The Bid team
• Local business networking organisations
• Locate in Kent
• Leeds Castle
• Air quality experts
• Noise experts

These discussions need to be regular and very focused, particularly in identifying urgent infrastructure requirements and anticipating future needs. In anticipation of the next review, there should be a properly costed range of infrastructure needs which will be seen as Work in Progress. Failure in respect of the provision of infrastructure will result in MBC becoming a third rate location to live and invest.

TQ21 Have we identified all the types of transport measures? Which measures do you think we should prioritise?

Roads are probably the most immediate items of infrastructure that the community consider are substandard:

• Congestion
• Pot Holes
• Increased drive times
• The risk from wide HGVs etc
• Air quality
• Noise
• Lighting

The reality is that MBC does not control this matter. MBC is reliant on KCC, and therefore there needs to be a firm commitment from KCC to collaborate with MBC set out in the Local Plan.

When consulting with KCC in respect of a planning application, there needs to be proper consultation. “No objection” is not sufficient as it leaves the matter of how the new development will impact on the existing road network. Other questions must be addressed :

• Air quality
• Noise
• Safety
• Mediation measures
• Futureproof requirements
• Funding

TQ22 How can the Local Plan Review best integrate health and wellbeing into the planning of new development?

As part of this Issue , there must be a commitment as part of the local plan to ensure that sufficient utility infrastructure is provided to serve “existing” as well as the new development that is planned. There has to be a commitment that the existing community will have the additional infrastructure necessary to catch up with the current shortfall.

Health, Wellbeing (and schools) are matters that are outside the MBC’s control. The requirements will evolve from KCC, & health providers set out in the Technical Report.

There needs to be proper co-operation, and MBC needs to monitor the requirements based on their factual evidence of new development. These meetings need to be transparent, and reports need to be provided directly to the relevant Committee and for the Chairperson to ensure that the requirements are included with costs as part of the Infrastructure Delivery Plan (update). The conclusions will need to be matched against receipts from S106/CIL. There needs at this point in time to be a reconciliation/budgeting exercise to evaluate the potential shortfall in receipts and a recommendation as to how to rectify a deficit.

MBC must be seen to be pro-active to ensure that local infrastructure provision matches the need. If there is some catching up required, and this needs to be taken into account. If the infrastructure requirement is not provided, (on time and within budget), then MBC whilst not directly responsible must bear some of the responsibility. The phrase “ The council can’t do this alone” implies that MBC has the duty to look after the interests of the community and make it happen to work with the providers.

TQ23 How can the Local Plan Review best manage flood risk whilst still achieving the growth that is needed?

Flooding is a real risk in various parts of the Borough, as identified in the technical document. MBC has to rely on advice from the Water Companies and r the Environment Agency. There is a potential risk that Climate Change will affect the environment, and that flood alleviation proposals need to be very carefully assessed. By accepting that due diligence has been properly carried out by the site owner to obtain Planning Permission does provide a seal of approval from MBC that a site is safe from flooding. The potential risk can be expressed as an event every 50 /100 years. If a property that has been properly assessed by MBC, is flooded, there may be a risk that needs to be carefully considered by MBC as the MBC assessment could be relied upon.

TQ24 How can the Local Plan Review best plan for the protection and enhancement of the borough’s environmental assets whilst still achieving the growth that is needed?

The responsibility is that MBC must ensure that development does not impact the “borough’s environmental assets”. Decisions have been made that do not or will not take this consideration fully into account despite consultation comments. There is this need by MBC to anticipate possible growth having fully assessed the damage that will result. The fact is that once the assets are damaged, possibly forever, this cost needs to be weighed against any possible benefit.

TQ25 How can the Local Plan Review best plan for the conservation and enhancement of the borough’s heritage assets whilst still achieving the growth that is needed?

As suggested above, there needs to be a better assessment of potential damage that development will have on the conservation and enhancement of the boroughs heritage assets :

• Noise,
• Air Quality
• Impacts on views
• Traffic
• Congestion
• Damage to property by passing vehicles servicing the development
• Flooding
• Spoiling the unique character of a particular location
• Roads

The above issues need to be considered even when considering “the growth that is needed.”

The above issues can cause long term damage, which can reduce growth, which will be determined by the market perception of the damage that can be caused by development. The long term damage is more detrimental than the short term gain. Sometimes the damage and harm to the heritage assets can not be repaired.

TQ26 How can the Local Plan Review best plan for the protection and enhancement of the borough’s biodiversity whilst still achieving the growth that is needed?

This is a very important aspect. As with heritage assets, once they are gone, they are gone.

TQ27 How can the Local Plan best plan for an overall improvement in air quality in the Maidstone Air Quality Management Area, and manage air quality elsewhere, whilst still achieving the growth that is needed?

It is important that Air Quality issues are carefully considered at the planning stage. MBC should have their own experts to form their own opinion with regard to air quality issues resulting from development. MBC needs to utilise up to date monitoring devices which can be remotely read to assess air levels. These devices need to placed at strategic locations that will produce meaningful results. The locations need to selected by experts and their advice tested.

Various sensitive locations need special attention, such as schools that front main roads.

This matter should be regularly reviewed, and the readings need to be published at least monthly and the results published online with recommendations, and in the KM.

There needs to be an officer responsible for this matter and this officer should have at his disposal“experts” to review the results.

Planting hedges to protect schools etc needs to be considered.

This service needs to be properly funded with a specific budget to ensure that it is effective. Lives are at stake if necessary growth implications cannot take precedent. Air pollution in cities “as bad for you as smoking 20 cigarettes a day”.

It should be a basic planning requirement for all new developments to have fitted EV charging points and digital connectivity.

TQ28 How can the Local Plan Review best reduce the generation of carbon emissions and mitigate for the effects of climate change whilst still achieving the growth that is needed?

Possible local consequences of Climate Change:

• Flooding
• Drought / Water supplies

Easy Ways to reduce climate change:

• Make parking more accessible to avoid “circulating around the town to find a parking space
• Look at encouraging the use of trains
• Encourage better public transport

Planning should consider climate change when granting permission for new buildings:

• Buildings account for 30% of total greenhouse gas emissions in the UK
• Buildings use 32% of global energy
• Look for Green building Credentials – BREEAM rating
• Consider the MEES (minimum Energy Efficiency Standards) requirements for new developments.

TQ29 How can the Local Plan Review best provide for open space in new development?

The report Sports Facilities Strategy and a Playing Pitch Strategy could be a useful document. There is a need to have pitches and sports facilities.

There needs to be a clear policy regarding maintenance and control.

Walking needs to be encouraged in conjunction with the NHS and local medical centres to increase awareness of the footpath system in the MBC area.

There needs to be consultation from the Police to ensure that open spaces are in a location where they cannot cause a nuisance. If the open space requirement can be considered an added benefit to the marketing of the development, then more land will be made available. There needs to be a positive consideration in relation to the maintenance and security of the open space.

Loss of “playing fields” – Change of use should be resisted.

• The Gen2 report should be issued by MBC
• Should support the KM campaign to Protect Our Play.

TQ30 What community facilities do you consider are the most important to a successful new development?
• Sufficient car parking (inc for visitors)
• EV power points
• Digital Connectivity
Depending on the size of the development:

• Local retail
• Bus Stops
• Community Hall
• Community Playing fields
• Schools
• Footpaths
• Medical Centre
• CCTV linked to Police
• Free Wifi

TQ31 Have we identified the extent of potential changes to the adopted Local Plan correctly? What alternative or additional ones do you suggest and why?

There are omissions in the Local Plan that need to be considered:

1. A better understanding of the market forces and the effect of growth. There is a need for there to be a plan “B” if the growth that MBC anticipates fails to materialise.
o There needs to be prepared as part of the evidence required to produce the review, various pieces of work against which value judgements can be made. MBC needs to fully understand the current state of the market within the Borough.

o The reports prepared in April 2013 need to be fully updated “to provide evidence on the viability of development in Maidstone and delivery of policies and proposal in the emerging development plan.” The current review “will have a bearing on the cumulative viability of the plan”.

o “If the recommendations for policy change, including that of affordable housing, are taken forward in conjunction with work on the new sites and their infrastructure requirements a deliverable plan can be achieved. It is necessary, however, to properly identify within the council’s existing infrastructure delivery plan the infrastructure requirements for new development and their respective funding sources.”

o “Therefore it is recommended that this report is revised at an appropriate time in advance of any Examination to update assumptions and provide further testing if necessary.”

o Looking at the Planning Evidence for MBC Local plan 2011-2031 there is a concern that much of this work was out of date at the time of the Local Plan hearings. The Technical Report does not appear to set out the proposals for gathering up to date evidence. The real concern is that the Local Plan Review cannot be seen as being sound without property evidence.

2. The local plan should not be determined by the Central Government requirement for more housing. MBC needs to be able to support a case that is realistic and fit for purpose and one that can be supported by an infrastructure provision that addresses the current defects. The NPPF does accept that lower hosing targets are acceptable if there are constraints. There are constraints in the provision of infrastructure so the housing numbers need to be reduced to have regard to the constraints.
3. All development must be sustainable.

4. Acceptance that there is no shortfall in commercial land – to address the B1 and B8 requirements.

5. The fact that the implementation of various matters such as roads, schools, health are outside the direct responsibility there needs to be a clear understanding that MBC must make these matters work as if they were directly responsible. There needs to be a reporting mechanism that will focus on/ publicise these matters. The Infrastructure Delivery Plan needs to be online and updated monthly to clearly demonstrate progress and action since the previous update. This document needs to published in the MBC “magazine” that is delivered to all homes.

6. There needs to be seen positive consultations with adjoining authorities which benefit the communities. (This is a statutory Duty.) The reality is that MBC cannot do everything. Having a joint approach to various matters will be much more powerful when addressing the central government.

7. There needs to better communicate with the community. Secret meetings, Judicial Reviews, give the wrong impression and lead to a break down in trust. MBC will be judged by their response to this consultation, and there will need to be continued dialogue with the community to ensure that MBC is listening.

8. MBC needs to address Climate Change and consider the material aspects relating to developments by encouraging a green approach by looking such matters as EPCs, Use of Grey Water, and encouraging developers to consider the green aspects in their design, construction and use of materials.

9. Air quality issues require a more dynamic approach to monitoring. There need to be IoT connections to monitor automatically air quality and for there to be an action plan properly financed. This aspect needs to be properly considered when reporting to the planning committee to enable proper safeguards against poor air quality. There should be a review of recent approvals that might not have been fully considered and for advice to be given to landowners. Although this might be seen as a retrospective action, it is a life and death matter that does require attention.

10. More attention needs to be given to flooding issues. Failure to address them could leave MBC open to a class action for damages. There is a reliance that MBC has carried out its duty, for instance, with regard to foundation design. The same amount of care should be provided by MBC in relation to flooding issues, and this will require close cooperation with the Department for the Environment and Insurance Companies.

11. Maidstone does not have to be boring. The Local Plan lacks imagination and confidence. If MBC does understand the market and wants to encourage growth, which is a top priority, then they need to be innovative instead of acting in such a traditional manner. MBC needs to decide what they want to achieve and if they have to take some risks, so be it. MBC’s role in the Maidstone economy has to that of the facilitator, and to let the market do the work within certain rules. It is these “rules” that the Local Plan will provide.

12. In recent editions of the Kent Messenger, they have set out a “Vision” in respect of Maidstone. Their suggestions are along the right lines.

13. It is blue-sky thinking that will assist in making Maidstone a better place to live and work. MBC should consider having a competition to assist in fully engaging with the community to look for new ideas to make Maidstone a more interesting place. A place more people want to live, work and visit. Maidstone lacks the confidence to succeed. We need a can-do attitude and belief that MBC can be made a better place to live and work.

14. This approach will need some bold leadership to make it happen. Is Maidstone capable of making it happen?