SDC draft consultation Places & Policies Local Plan open for comments

So the draft consultation Places & Policies Local Plan local is now open for you to comment on (closes March 5th 2018). Shepway District Council’s (SDC) draft  Places and Policies Local Plan runs to 458 pages, so is a lengthy document. Now our advice would be for you to concentrate on your patch where you live if you wish to comment.  Send comments to planning dot policy@shepway dot gov dot uk or by post to the council offices.

Screenshot from 2018-02-13 16-23-58

Now some of you may have read in the local paper – The Folkestone & Hythe Express last week  (7th Feb 2018) that 2,000 homes are due to be built over 13 years. However, it would appear that when one scrutinises the detail of SDC’s draft Places and Policies Local Plan, it is not 2,000 homes, nor is it 2,500 homes as SDC states on their website here, but would appear to be closer to 6,165 homes to be built over the next 13 years. According to paragraph 4.12 on page 33, the Council have submitted that completions up to 16/17, were 3,191, homes under construction in 2017 were 629, those with permission in 2017 but not started were 3,728 and that the minimum target was 8,750 homes, although SDC’s total projected number of homes is 9,985. We arrived at our figure of 6,165, as we have started from column D, as these are home which have not been built yet.


So how have the paper arrived at 2,000 homes and SDC on their website at 2,500?

SDC website

As always the devil is in the detail.

The Local Plan will be examined by an independent inspector prior to being adopted and whose role it is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound.

If you wish to comment, your comments will have to relate to the “soundness” of the local plan para 182 of the National Planning Policy Framework. To be sound the local plan must be:

  • Positively prepared, the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

  • 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 Framework.

Aspects of those four requirements are further clarified throughout the rest of the NPPF. Of particular relevance are:

  • NPPF 14: “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change”;

  • NPPF 156: “Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver: ●● the homes and jobs needed in the area”,

  • NPPF 157: “Crucially, Local Plans should: ●● plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework;”

  • NPPF 158: “Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area;

  • NPPF 159: “Local planning authorities should have a clear understanding of housing needs in their area.”

Critically, NPPF 47 provides: “47. To boost significantly the supply of housing, local planning authorities should:

  • use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area , as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;”

the assessment of soundness is a matter of planning judgment, challengeable only on Wednesbury grounds, ie unreasonableness.

So good luck with your comments.

To finish with we know healthcare provision across Shepway is in a critical condition left in a corridor, seemingly forgotten, so wish to explain about how important it is for GP’s,  Patient Participation Groups to lobby SKC CCG for s106 money for development in your areas which may affect your community and the provision of healthcare and services for you as an individual and as a community.

South Kent Coast Clinical Commissioning Group (SKC CCG) adopted a s106 Policy (Overall Page 72 of 146), in June 2017. SKC CCG is a statutory consultee and is a named body in any Local Plan. It is known SKC CCG has recently employed a s106 officer, so we hope they will be putting in claims for developments as soon as possible, for and on behalf of GP’s surgeries across the district as that Golden Hello delivered NOT at pace by Mr Collins, means it is now even more essential to drawn down the monies to help attract GP’s to our wonderful district.

Most s106 agreements allow for the following improvements; which may be attractive to new GP’s:

  • The expansion of health premises to provide addition facilities and services to meet increased patient or user numbers. (Only three surgeries saw a decrease in numbers in 2017)

  • New health premises or services at local level

  • Any new facility to compensate for the loss of a health facility caused by development.

Historically the need for a health facility or the sum to be requested in SKC CCG area for health under s106 was based on a calculation consisting of estimated occupancy x number of units in the development x £360.00

Screenshot from 2018-02-14 07-18-21

So how much will that bring in for Princes Parade, Otterpool Park, Biggins Wood and other development set out in the draft local plan? A fair sum, a sum to help and enlarge our GP Premises facilities and provide new services to the people of Shepway.

So to put that into perspective, if a proposal for a 400 dwelling development the initial calculation would be 2.8 persons x 400 dwelling units x £360 = £403,200.

Shepway DC planning is currently holding onto agreements from a number of s106/CIL agreements that need to be committed to health estate improvements, or actively engaged in securing s106 agreements. The s106 agreement determines where the funds should be spent and the specific project.

We hope you’ll pass this onto your doctor, and your patient participation group within your surgery, asking them to lobby the CCG for monies as they’ll be plenty of development and your Surgery could expand its health premises and offer new services to you and your community. A worthy cause to lobby the CCG for we believe, what do you think?

The Shepwayvox Team

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