Draft Thanet Local Plan to 2031 Preferred Options – Proposed Consultation Document


To:                               Extraordinary Cabinet – 11th December 2014


Main Portfolio Area:    Planning and Housing


By:                               Councillor Nicholson, Deputy Leader and Cabinet Member for Housing & Planning Services


Classification:              Unrestricted


Ward:                          All



Summary:                  The report sets out the Preferred Options for formulating the Draft Thanet Local Plan to 2031 which has been progressed in consultation with the Local Plan Cabinet Advisory Group. The report sets out the recommendation of the Local Plan Cabinet Advisory Group to approve the Draft Thanet Local Plan 2031 Preferred Options document for stakeholder and community consultation.


The report also includes the Project Plan to progress the Thanet Local Plan to 2031 for their consideration, as Annex 4.


For Decision



1.0       Introduction and Background


1.1       National planning policy stresses the central importance of an up to date Local Plan. It is the key strategic planning document for delivering sustainable development that reflects the vision and aspirations of local communities and providing the framework for guiding the determination of planning applications in order to manage development effectively.


1.2       Following changes to the planning system in recent years, including the introduction of the Localism Act 2010, the abolition of Regional Spatial Strategies (South East Plan 2009) and publication of the National Planning Policy Framework and associated National Planning Practice Guidance, the Council has been preparing a new Local Plan for the District to guide future growth, development and regeneration.


1.3       Between June and August 2013, the Council undertook Stage 1 public consultation on the Issues and Options for the new Plan for Thanet and engaged with the local communities and stakeholders on the current issues and how the future development needs of their area and the District should be met. There was a considerable response to this consultation and these responses have been fully considered in formulating the future growth, development and regeneration options to meet the strategic spatial objectives of the District.


1.4       Following the outcome of the Stage 1 consultation, the Draft Thanet Local Plan to 2031 Preferred Options has been formulated with the input from the Local Plan Cabinet Advisory Group. They finalised their deliberation at their meeting on 18th November 2014 and recommended that this Local Plan Preferred Options document should be submitted to the Cabinet for their consideration with a recommendation that it be published for public consultation.


1.5       The Draft Thanet Local Plan to 2031 Preferred Options has also been considered by the Council’s Overview and Scrutiny Panel at their meeting on 27th November 2014. The Report sets out the comments, observations and recommendation of this Panel for the consideration of the Cabinet.


1.6       The report also set outs the proposals for progressing the Draft Thanet Local Plan to 2031 Preferred Options to Stage 2 Public Consultation in accordance with the current Local Development Scheme.


2.0       Producing the new Local Plan


2.1       The new Thanet Local Plan to 2031 will be the Council’s single and overarching strategic spatial planning policy document, which will cover the whole of the District for a period up to 2031.


2.2       The Plan will set out policies and proposals that will be used to guide decisions and investment on sustainable economic growth, development and regeneration over the period to 2031. It will also set out how and where the homes, jobs, community facilities, shops and infrastructure will be delivered and the type of places and environments we want to create. It will also identify land to be protected from development, such as open spaces and environmentally sensitive areas.


2.3       The Plan will form the statutory planning framework for determining planning applications and replace the current ‘saved[1]’ policies from the Thanet Local Plan 2006.


2.4       The Local Plan should be prepared in compliance with the guidance set out in the National Planning Policy Framework (NPPF). The core principle of the NPPF is:


“to proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs.”


2.5       The NPPF also states that:


·           planning authorities should set out a clear economic vision and strategy for their areas which positively and proactively encourages sustainable growth, identify strategic sites to meet anticipated needs over the plan period, support existing business sectors and plan for new and emerging sectors,

·           policies should be flexible to accommodate needs not anticipated and to allow rapid responses to changes in the economy,

·           clusters or networks of knowledge driven and creative high technology industries should be planned for in priority areas for economic regeneration, 

·           infrastructure provision and environmental enhancement should be identified, and

·           flexible working practices such as the integration of residential and commercial uses within the same unit should be facilitated.”


2.6       National policy requires the Plan to be ‘sound’. This means:


·           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 is consistent with achieving sustainable development;

·           Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

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

·           Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.


2.7       The Local Plan must be based upon adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Evidence gathering is an on-going process.


            Justification for the Preferred Options


2.8       The Draft Thanet Local Plan to 2031 Preferred Options document has been prepared following identification and consideration of options, which were subject to the Issues and Options Consultation in 2013. Annex 2 sets out the options that have been considered and identifies the preferred options with an explanation as to why they have been selected and why the alternatives have been rejected.


2.9       As well as ensuring that the proposed Preferred Options Draft Local Plan comply with the National Planning Policy Framework, the consideration and selection of options have been informed by:

·           Sustainability Appraisal

·           Responses received to the Issues and options consultation

·           Duty to co-operate


            Sustainability Appraisal


2.10     The Planning and Compulsory Purchase Act 2004 requires the Council, in preparing the Local Plan, to carry out an appraisal of the sustainability of the proposals and prepare a report of the findings of the appraisal. The purpose of Sustainability Appraisal (SA) is to promote sustainable development through the better integration of sustainability considerations into preparation and adoption of plans. In response to a European Directive (the SEA directive) national regulations also require that certain planning documents are subject to Strategic Environmental Assessment (SEA) to provide for a high level of protection of the environment and contribute to the integration of environmental considerations into the preparation and adoption of plans. The requirements for the SEA are incorporated into the SA process.


2.11     The Interim Sustainability Appraisal assessment (Background Document) has been used to inform the way forward on future options, policies and allocation of sites to meet the housing, employment, shopping, community, social, leisure and infrastructure needs of the District. The draft Environmental Report has been prepared alongside the Local Plan and is a background document supporting the proposed consultation.


            Issues and Options Consultation Responses


2.12     The key issues that were raised in the response to the Issues and Options Consultation have, where possible, been taken into account in deciding on the preferred options and in preparing the Draft Local Plan. A summary of the key issues and the response to them is collated in the Document at Annex 3.


            Duty to Co-operate


2.13     Under the Localism Act 2011, the Council, in preparing the Local Plan must ‘co-operate’ with a number of bodies to ensure that cross boundary strategic issues are dealt with appropriately. These bodies include other councils, the county council and other bodies, including, for example, the Environment Agency and Natural England.


3.0       The proposed Preferred Options for consultation


3.1       The proposed consultation with stakeholders and communities will be on the Draft Thanet Local Plan to 2031 Preferred Options document, which has been prepared in consultation with the Local Plan Cabinet Advisory Group. The Draft Thanet Local Plan to 2031 Preferred Options document is included as Annex 1.


3.2       The following section provides a summary of the key issues and explains how they have been addressed.


            Strategic Priorities and Objectives


3.3       The strategic priorities and objectives set out in this plan are seeking to achieve the Council's vision and deliver sustainable development for the District and these are to:


·           create additional employment and training opportunities, to strengthen and diversify the local economy and improve local earning power and employability,


·           facilitate the continued regeneration of the coastal town centres, developing their individual niche roles, whilst also consolidating the role and function of Westwood as Thanet’s primary retail centre, ensuring retail expenditure is retained in the district,


·           provide homes that are accessible and suited to the needs and aspirations of a settled and balanced community,


·           safeguard local distinctiveness and promote awareness, protection, enhancement and responsible enjoyment of Thanet's environment, including the coast, countryside, rich seaside heritage, historic environment, diverse townscapes and landscape, biodiversity and water environment, and


·           deliver the infrastructure required to support existing communities and new development, including an efficient and effective transport system.


3.4       Under the various sections of the Draft Thanet Local Plan these strategic priorities and objectives have been central to formulating policy options to delivering sustainable economic development in the District.


Economy and Town Centres


3.5       The economic approach is to show how the District's economy should grow, develop and create new jobs and prosperity over the plan period. This approach is based upon a positive and optimistic level of growth and explains where the growth is expected to take place, and how the Local Plan is going to support this, alongside the Council's Economic Development and Regeneration Strategy.


3.6       The overall employment target proposed in the plan is to deliver a minimum of 5,000 jobs during the plan period to 2031 based on a projection that assumes high levels of growth in the tourism and green sectors. Population growth over the plan period associated with a short term migration trend projection would provide a labour supply for around 5,800 jobs. The overall aim is to reduce unemployment to 3%. Future job growth is expected to remain strong in town centres and tourism uses, as well as in public administration and education. As a popular retirement area, there will be a benefit to the economy particularly with the expected growth within the health and caring professions. Given the diverse economy of the District a flexible economic approach is needed in order to accommodate all employment generating uses and the proposed planning policies need to reflect this.


3.7       The economic growth will be supported, promoted and delivered by allocation and retention of employment land and premises that are fit for purpose across the District to allow flexibility of uses on employment land and to accommodate a wide range of compatible uses in the town centres. The Council also considers the need for flexibility with regard to uses related to tourism, leisure and holiday accommodation, education and skills facilities and retaining, promoting and regenerating the transport hubs and infrastructure. Flexible approach is also required to support growth in the green economy providing suitable and sufficient employment land.


3.8       The Draft Local Plan proposes that the airport and its surrounding area should be designated as an “opportunity area” for which the District Council will prepare an Area Action Plan Development Plan Document. The AAP will set out the development framework for the development and regeneration of the area.




3.9       The approach for housing in the District is “to provide good quality housing that is affordable, which meets people’s changing needs and aspirations and is located within pleasant, safe and sustainable communities.”


3.10     The main objectives of the Local Plan is to identifying sufficient and suitable land for expected population growth, deliver a range of homes to meet the local housing need which residents can afford, make better use of the existing housing stock across all tenures and improve housing conditions, enable vulnerable people access to good quality housing and to live independently and deliver housing in support of our regeneration and economic development objectives.


3.11     The housing provision over the 20 year period to 2031 is for 12,000 additional homes. This reflects the forecasts based on recent population and household trend, future population projections and the labour requirements to support the Council’s aspirations for economic and employment growth. In line with the forecasts the housing provision is attributed evenly over four 5 year periods.


3.12     Identification and allocation of housing land has been informed by assessment of the sustainability of individual sites through the Strategic Housing Land Availability Assessment alongside the strategy for the planned location of homes whose key principles are to:-

·           make best use of the sites in the built up areas of the coastal towns,

·           focus remaining provision at sites abutting existing urban areas, and

·           make modest provision at rural settlements to meet identified need for affordable homes and to provide locational choice at a scale compatible with their character and access to services and facilities.


3.13     The approach adopted in the preparation of the Local Plan is to focus future development in locations that are:

·           accessible

·           with exiting infrastructure and services, and

·           within or on the edge of existing urban areas.


3.14     The areas and sites being promoted provide the opportunity to deliver development at a scale that will serve both to facilitate a step change in delivering the type of homes required to meet need and secure the infrastructure required to support them. Such large and clustered sites have been identified as strategic housing allocations that will be of particular importance in delivering the Plan’s housing objectives. For this reason new greenfield sites are proposed in the following locations:


·           Westwood

·           Birchington

·           Westgate on Sea

·           Manston Green


Environment and Quality of Life


3.15     The Draft Local Plan seeks to protect the important countryside, open spaces, heritage and the built and natural environment around the district as these provide important landscapes and character that contribute to its sense of place, as well as making the district an attractive place that people want to come to. Much of the countryside is classified as ‘best and most versatile agricultural land’. The countryside also supports a variety of habitats and species, particularly a number of important species of farmland birds which have declined in numbers over the last few decades.


3.16     The Green Wedges are significant in shaping the character of the district which has historically wrapped around the built development along the coast. The Green Wedges provide a clear visual break when passing between the towns, giving a recognised structure and identity to the urban settlements. The Green Wedges are distinct from other types of open space as they provide a continuous link between the open countryside and land which penetrates into the urban areas.


3.17     There will therefore be strong resistance to new development in the countryside and green environment as the sites allocated in this plan meet the development needs of the district. The housing  sites put forward for future development that are classified as greenfield have been carefully assessed and whilst some have been allocated in the countryside, this has been very carefully considered against the sustainability criteria and is appropriate to meet the needs of sustainable development.


3.18     It is considered essential to protect the countryside through planning policy in view of its vulnerability to sporadic forms of development and all but essentially rural development will be located in the Thanet towns.


Transport and Infrastructure


3.19     The Key message for transport is that the system needs to be balanced in favour of sustainable transport modes, giving people real choice about how they travel. The aims of the Local Plan policies are for a balance of land uses is to encourage people to minimise journey length for employment, shopping, leisure, education and other activities. The level of economic growth proposed, and the strengthening of the local economy will also serve to reduce the need for local residents to commute to work outside the district.


3.20     Transport is a critical factor to the district’s aspirations for sustainable economic regeneration. Local people need to travel to work, school, shops and to access other services as part of their daily lives and goods need to be moved to support employment and economic growth. At present, the district does not suffer from significant levels of congestion, traffic noise, pollution and delays such as experienced in urban centres elsewhere in Kent. A high proportion of the population has no access to a car. However this has potential to change and some traffic congestion already occurs at certain junctions at peak times. The district has an attractive environment and is a pleasant place to live and work and this is also a potential asset in attracting investment.


3.21     The intention is to maintain that situation while attracting and accommodating appropriate development in support of regeneration. Accordingly, local plan policies and key actions will be to manage mobility by putting in place an efficient and effective, sustainable transport system.


3.22     The introduction of high speed trains connecting Thanet with the High Speed 1 (HS1) service has reduced journey times from Ramsgate to London by over 30 minutes. A surface access strategy and travel plan will be required alongside planned growth to promote sustainable travel, particularly by the workforce.


3.23     Kent County Council’s Transport Delivery Plan "Growth without Gridlock" identifies strategic transport projects to support Kent’s sustainable economic growth. It acknowledges the need and potential for coastal areas to derive greater benefit from the High Speed 1 rail service including through potential increases to line speeds for domestic link services, and a new railway Parkway Station is promoted for wider economic benefit to the district. The HS1 services need to be integrated with the wider public transport network and meet the needs of people who elect to access them by car.


4.0       Governance


            Local Plan Cabinet Advisory Group


4.1       Over the past few years, the Local Plan Cabinet Advisory Group (LPCAG), set up by Council has been working with the officers to progress the emerging Thanet Local Plan that will deliver the Council’s Vision, Objectives and Priorities for creating economic prosperous, healthy and inclusive communities whilst ensuring quality and safe environment. The LPCAG is a cross-party Members Group. It has reviewed the outcome of the stage 1 consultations, examined the options for future growth, development and regeneration in the District that will retain, scope to expand and attract new businesses and investment and create local employment opportunities; provide quality affordable home in sustainable locations whilst promoting and protecting the natural and historic environment.


4.2       At the formal meeting of LPCAG on 18 November, they consider the Draft Thanet Local Plan to 2031 Preferred Options document and resolved “to recommend to the Cabinet that the Draft Thanet Local Plan to 2031 Preferred Options Document is approved for a six week period of public consultation”.


Overview and Scrutiny Panel


4.3       The Thanet Local Plan to 2031 Preferred Options document was referred to the Overview and Scrutiny Panel for their meeting on 27 November to review and scrutinise the governance and management of the Draft Thanet Local Plan Preferred Options document and how the outcome of the Stage1 consultation on the “Issues and Options” has been incorporated in the development of the preferred options for future growth, development and regeneration of the District, the settlements and the wider communities. The panel also had the opportunity to consider the proposed programme of consultation on the Preferred Options Document and how the Council will engage with the local communities and stakeholders.


4.4       The Overview and Scrutiny Panel welcomed the opportunity to consider the Draft Thanet Local Plan to 2031 Preferred Options Document and noted the process that has been followed in preparing the Local Plan document, the engagement with Members, future project programme for progressing the Local Plan to adoption by the Council and the programme for community and stakeholder consultation on the Preferred Options. Number of comment/observations made included:


·           considering the important stage for engagement with the local communities, the period for consultation should be longer than six weeks to allow more time to review the document and to respond.


·           a summary of the consultation document to be provided for easy reference to the Preferred Options Document,


·           the Preferred Options document should include a Glossary of technical terms used,


·           clarification on the position of the District Council with the likely development pressures for housing whilst the Local Plan is being progressed, and


·           how the figure for future housing needs for the district has been calculated and its justification


5.0       Options


5.1       The LP CAG has agreed the Draft Thanet local Plan to 2031 Preferred Option and is submitting it for the consideration of the Cabinet.


5.2       There are two options for the Cabinet to consider:-


(i)     To approve the Draft Thanet Local Plan to 2031 Preferred Options Document for a six week period of public consultation.


(ii)    Not to agree the Draft Thanet Local Plan to 2031 Preferred Options Document for consultation.


6.0       Next Steps


6.1       Following the consideration and approval of the report by Cabinet, the Preferred Options Document should be progressed for six weeks public consultation.


6.2       On the conclusion of the six weeks public consultation, the LPCAG should be reconstituted to review all the representations received to the Preferred Options Document and to progress the Thanet Local Plan to the next stage by preparing the Draft Thanet Local Plan to 2031 Pre-submission Document for formal consideration of Cabinet for Regulation 18 Consultation.


7.0       Corporate Implications


7.1       Financial and VAT


7.1.1    It is envisaged that any costs associated with the consultation can be absorbed within the current budgeting procedures for preparation of the Local Plan and this report at this stage does not give rise to specific additional financial implications.


7.2       Legal


7.2.1    The Town and Country Planning (Local Planning) (England) Regulations 2012 set out the requirements of a local planning authority when preparing a Local Plan. The Regulations require local planning authorities to notify specific bodies and persons of the subject of a local plan which the local planning authority proposes to prepare and invite each of them to make representations to the local planning authority about what the local plan with that subject ought to contain.


7.2.2    The Environmental Assessment of Plans and Programmes Regulations 2004 set out the requirements in relation to the Sustainability Appraisal (SA), and requires that the SA considers all reasonable alternatives.


7.2.3    Legal advice has been sought in relation to the consultation process that should be carried out in order to meet the statutory requirements. It is important that the consultation process should inform the process of option selection i.e. that consultees have a genuine opportunity to influence the decision made. This requires consultation on all reasonable alternative options not just in relation to sites but also in terms of levels of development, how that development should be distributed and how it should ultimately be managed.


7.3       Corporate


7.3.1    The Local Plan will represent the Council’s overarching plan for shaping future development of the District over the period up to 2031. It contains a vision and sets out the issues and opportunities facing the district and takes account of the plans and resources of a wide range of agencies and organisations who will participate in its delivery.


7.3.2    The production of the Local Plan will help to deliver the majority of the Council’s priorities in the Corporate Plan. In particular the Local Plan will play a key role in supporting the growth of our economy and the number of people in work, planning for the right type and number of homes in the right place to create sustainable communities, working to improve parking and transportation and protecting and preserving our public open spaces.


7.4       Equity and Equalities


7.4.1    The Statement of Community Involvement (SCI) sets out the way in which all sectors of the community will be given the opportunity to become involved in the planning process. The SCI was subject to an Equalities Impact Assessment, and this consultation is proposed to take place in accordance with the SCI.


7.4.2    An Equalities Impact Assessment will be carried out for the next stage of the preparing the Draft Thanet Local Plan, when a draft plan is produced.


8.0       Recommendation(s)


8.1       It is recommended that:


I)     The Cabinet approve the Draft Thanet Local Plan to 2031 Preferred Options Document for a six week period of public consultation commencing the week beginning 5 January 2015,


ii)    The Cabinet delegate to Director Community Service in consultation with Cabinet Member for Planning and Housing to make any minor alteration to the approved Draft Thanet Local to 2031 Preferred Options Document that are considered necessary to ensure accuracy, reference and presentation for public consultation,


Iii)   The Cabinet set-up a Cabinet Advisory Group or Working Group to prepare the Area Action Plan Development Plan Document for the area of Manston Airport and its surrounding environ.


9.0       Decision Making Process


9.1       This is a non-key decision and exempt from call in by Overview and scrutiny Panel to ensure that the consultation on the Draft Thanet Local Plan to 2031 Preferred Options Document is not delayed.


Contact Officer:

Ismail Mohammed, Interim Strategic Planning Manager 01843 577141)

Reporting to:

Colin Fitt, Interim Head of Built Environment)


Annex List


Annex 1

Draft Thanet Local Plan to 2013 Preferred Options Document

Annex 2

Summary of Preferred Options

Annex 3

Summary of Representation to Issues and Option Consultation June/August 2013

Annex 4

Project Plan: Thanet Local Plan to 2031


Background Papers



Details of where to access copy

National Planning Policy Framework

DCLG website

Town and Country Planning (Local Planning) (England) Regulations 2012

DCLG website

Draft Environmental Assessment

Planning Policy Team, Council Offices

Local development Scheme

Planning Policy Team, Council Offices – TDC website

Statement of Community Involvement

Planning Policy Team, Council Offices – TDC website


Corporate Consultation Undertaken



Matt Sanham, Finance Manager (Service Support)


Suki Montague, Assistant Planning & Information Solicitor


[1] These are policies from the Thanet Local Plan 2006 that were saved by the Secretary of State’s direction (under paragraph 1(3) of Schedule 8 of the Planning and Compulsory Purchase Act 2004), and continue to be part of the Development Plan, until specifically replaced.