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ERA RESPONSE TO TDC CORE STRATEGY PROPOSALS (with explanations) The Role and Identity of Thanet's Towns and Villages - Options A1-A4 NB In order to get a full understanding of the Core Strategy the full consultation document must be read in full. Only key and relevant sections have been reproduced here to get a general understanding of the various sections. NB TDC Preferred Options are in BOLD. A1. Maintain protection of the open character of the areas between Thanet's main towns currently identified as Green Wedges. A2. Remove such policy protection A3. Maintain protection of the rural and open character of the areas between Thanet's villages. A4. Allow the gaps between the villages to be developed. Options A1-A4: Do you agree with the Preferred Options? Yes 74% - ERA response No 26% The Level of Housing Growth - Options B1-B3 B1. Provide for the quantity of new homes as set in the South East Plan B2. Provide for a quantity of housing above that in the South East Plan B3. Plan for/allow the market to determine the actual level of provisions. Options B1-B3: Do you agree with the Preferred Options? Yes 46% No 54% - ERA response ERA reason for answer: Option B1 needs to be tweaked to enable TDC to develop a strategy to encourage appropriate redevelopment of existing deteriorated housing stock in the Coastal towns . Redevelopment needs to be given priority over building new housing stock The Development Pattern - Options C1-C3 C1a) Maximise development provisions within the existing built up areas of the towns and villages in order to minimise use of greenfield land. C1b) Allow higher level policy, infrastructure capacity and the market to determine the make up and density of new housing in the existing built up areas. C1c) Focus on urban areas but with criteria (for example) to safeguard back gardens and family homes . C1d) Focus provision on greenfield sites and aim to restrict housing sites in the urban area to those important for regeneration. - How the greenfield housing land element should be accommodated C2a) at a single location C2b) at a small number of locations C2c) at dispersed sites -Where the greenfield housing land element should be accommodated C3a) adjoining the urban area C3b) adjoining the villages C3c) at freestanding countryside sites. Options C1-C3: Do you agree with the Preferred Options? Yes 45% No 55% - ERA response ERA reason for answer: Options selected need to give priority to redevelopment of existing deteriorated housing stock Providing for Economic Prosperity - Options D1-D9 Options D1-D9: Do you agree with the Preferred Options? D1 Continue to support development of Kent International Airport D2 Express support for the growth proposals outlined in the Airport operator's draft master plan. D3 Support alternative use of the Airport site. D4 Remove existing business park allocations D5 Retain selected business parks allocations D6 Retain all business parks allocations D7. Take a less prescriptive approach to types of employment use on allocated sites D8 No specific criteria for determining planning applications for job-creating development other than directing them to allocated or safeguarded sites and usual planning considerations. D9 Set out specific objective-based criteria to be weighed against other relevant policies when determining applications for job-creating development whose requirements may not be met by existing allocated or safeguarded sites. Yes 44% No 56% - ERA response ERA reason for answer: 1) Expansion of Manston has the potential to bring great benefits to Thanet - but will undoubtedly have a blighting effect on Ramsgate. The core strategy plan doesn't recognise that the quality of living of 33 % of Thanet's residents and the values of their homes could be seriously affected by insensitive airport expansion. Obviously ERA does not want to see Ramsgate blighted by airport operations - and we believe development of the airport should only proceed if the quality life in Ramsgate is preserved. The policy on developing the airport needs to explicitly recognise that any development is likely to have a blighting effect on Ramsgate and that the effect on Ramsgate must be taken into account when deciding whether to proceed. 2) The loss suffered by Ramsgate will be significantly more than the drop in current property values The new high speed rail connection, if combined with intelligent strategy set in place by the Ramsgate Town Council, give Ramsgate the potential for substantial regeneration and for large growth in property values. The true cost of insensitive expansion of the airport includes sacrificing that potential. 3) Ramsgate property owners should receive full compensation from TDC or the airport operator for the millions of pounds the town will miss out on if TDC puts the needs of Thanet as a whole ahead of, and to the detriment of, Ramsgate. 4) The plan does not consider what should be done if the airport expansion doesn't actually happen. The plan acknowledges that the Eurokent business park concept has not produced the desired result - but this plan does not consider that, for commercial reasons, the airport might also fail . There is no Plan B. TDC needs to devise a plan B, and incorporate it into the core strategy . The Future Role of Westwood - Options E1-E7 E1. Leave Westwood to evolve with no further specific policy guidance E2. The development pattern at Westwood should evolve and consolidate in line with a land use and access strategy outlining various components of a mixed residential and business community and facilitating connectivity between them. E3 Reject any further retail development at Westwood. E4 Permit an appropriate level of retail development supporting the role of Westwood as Thanet's principal town centre. E5 Continue to maintain Eurokent purely for employment purposes. E6 Remove the (Eurokent) allocation for employment use to accommodate a mix of uses more compatible with the proposed residential and business community role for Westwood. E7 Accommodate an element of the new homes to be provided over the period of the core strategy at Westwood. Options E1-E7: Do you agree with the Preferred Options? Yes 45% No 55% - ERA response ERA reason for answer: 1) Whilst ERA supports the eventual expansion of Westwood, this should not be done if the town centre of Ramsgate, or the town centres of the other Coastal towns, suffer. We want Ramsgate town centre to develop alongside West wood and do not desire further shop closures and movement of town centre outlets to Westwood Cross. To enable the Coastal towns to recover we recommend a 10 year moratorium on further expansion of Westwood. 2) Allowing office based businesses into Westwood is a serious error of judgement. This will suck those businesses out of the coastal towns, in turn leading to further decay in those towns. Allowing the cinemas and casinos in Westwood has had a serious effect on the entertainment business in the coastal towns, and allowing professional services to relocate to Westwood will, in the same way, suck the office based businesses out of those towns. 3) Allowing significant amounts of new housing at Westwood is likely to reduce the chances of existing housing stock in Margate and Ramsgate being refurbished. There are many fine buildings in both towns that would make wonderful family homes, and converting them back to such homes would provide a major impetus to the regeneration of those towns, and would also be desirable activity from an environmental point of view. We recommend a block on residential development at Westwood for at least 10 years to allow the regeneration of the housing stock in the costal towns. The Coastal Town Centres - Options F1-F4 The future of Margate could be shaped through F1 no additional intervention or policy and allow the market to determine the type and location of development. F2 a land use plan outlining a range of projects and measures to support the economic well-being and rejuvenation of the town. F3 specific guidance for redevelopment/re-use of key sites. F4 policy to reduce the over-supply of shops and reshape and refocus the town's commercial core. Options F1-F4: Do you agree with the Preferred Options? Yes 46% No 54% - ERA response ERA reason for answer: Ramsgate needs to developed aswell. The phraseology should be changed to: The future of Margate and Ramsgate could be shaped through......... The following sections (DSC1-DSC7) relate to the development of Manston Business Park, Kent International Airport and Westwood. Direct reference must be made to TDC Core Strategy document as it is too lengthy to reproduce here. Policy DCS1 Do you agree with Policy DCS1? Yes 39% No 61% - ERA response ERA reason for answer: Manston Airport : As noted in our answers to the policies in D1 to D9 1. The policy on developing the airport needs to explicitly recognise that any development is likely to have a blighting effect on Ramsgate and that the effect on Ramsgate must be taken into account when deciding whether to proceed. 2. The policy should recognise that the loss suffered by Ramsgate will be significantly more than the drop in current property values. 3. The policy should require that Ramsgate property owners receive full compensation from TDC or the airport operator for the millions of pounds the town will miss out on if TDC puts the needs of Thanet as a whole ahead of, and to the detriment of, Ramsgate. The compensation paid must cover the drop in current property values, and also the loss from being unable to regenerate the town to its full potential. In addition: 4) The policy on the airport should explicitly require independently monitored measures to be put in place to manage safety issues ,surface transport and environmental impact. Westwood: To Para 4 of the proposed policy add: " as a sustainable residential and business community , but that such allocation will only proceed once the three coastal town centres have had a number of years to recover from their present degeneration ." Revitalisation of Ramsgate and Broadstairs. While Margate has slid back more than the other towns, the needs of Ramsgate and Broadstairs cannot be overlooked. Therefore policy should be amended as below: To Para 5 add: "….physical revitalisation of Margate and Cliftonville West, together with the protection and regeneration of the coastal towns of Ramsgate and Broadstairs." Policy DCS2 Do you agree with Policy DCS2? Yes 59% - ERA response No 41% Policy DCS3 Do you agree with Policy DCS3? Yes 50% No 50% - ERA response ERA reason for answer: As noted in our answers to the policies in D1 to D9: 1) Manston Airport should only be developed in ways that do not blight Ramsgate - or if development is to proceed despite the quality of life in Ramsgate being affected , and/or Ramsgate's potential to develop being reduced , full compensation must be paid to those affected. Policy DCS3 should reflect this. 2) This policy should address what should happen to land which has been allocated for airport use if the airport fails to expand as envisaged ( ie provide a Plan B) Policy DCS4 Do you agree with Policy DCS4? Yes 57% No 43% - ERA response Policy DCS5 Do you agree with Policy DCS5? Yes 54% - ERA response No 46% Policy DCS6 Do you agree with Policy DCS6? Yes 57% - ERA response No 43% Policy DCS7 Do you agree with Policy DCS7? Yes 50% - ERA response No 50% DCS8-13 relate specifically to Westwood Policy DCS8 Do you agree with Policy DCS8? Yes 46% No 54% - ERA response ERA reason for answer: As noted in our answers to the policies in D1 to D9 1)Whilst ERA supports the eventual expansion of Westwood, this should not be done if the town centre of Ramsgate, or the town centres of the other Coastal towns, suffer. We want Ramsgate town centre to develop alongside West wood and do not desire further shop closures and movement of town centre outlets to Westwood Cross. To enable the Coastal towns to recover we recommend a 10 year moratorium on further expansion of Westwood. 2) Allowing office based businesses into Westwood is a serious error of judgement. This will suck those businesses out of the coastal towns, in turn leading to further decay in those towns. Allowing the cinemas and casinos in Westwood has had a serious effect on the entertainment business in the coastal towns, and allowing professional services to relocate to Westwood will, in the same way, suck the office based businesses out of those towns. Policy DCS9 Do you agree with Policy DCS9? Yes 32% - ERA response No 68% Policy DCS10 Do you agree with Policy DCS10? Yes 72% - ERA response No 28% Policy DCS11 Do you agree with Policy DCS11? Yes 37% No 63% - ERA response ERA reason for answer: As noted in our answers to the policies in D1 to D9 Allowing significant amounts of new housing at Westwood or other greenfield sites in Thanet is likely to reduce the chances of existing housing stock in Margate and Ramsgate being refurbished. There are many fine buildings in both towns that would make wonderful family homes, and converting them back to such homes would provide a major impetus to the regeneration of those towns, and would also be desirable activity from an environmental point of view. We recommend a block on residential development at Westwood and other greenfield sites for at least 10 years to allow the regeneration of the housing stock in the costal towns. Policy DCS12 Do you agree with Policy DCS12? Yes 35% No 65% - ERA response ERA reason for answer: See notes in section DCS11 Policy DCS13 Do you agree with Policy DCS13? Yes 71% No 29% - ERA response ERA reason for answer: We are opposed to the relocation of Thanet Tech Collection because of the detrimental effect to Broadstairs. Policy DCS14 Jackey Bakers Sports Ground Do you agree with Policy DCS14? Yes 92% - ERA response No 8% Policy DCS15 Margate Town and Seafront Do you agree with Policy DCS15? Yes 60% - ERA response No 40% Policy DCS16 Cliftonville West Do you agree with Policy DCS16? Yes 93% - ERA response No 7% Policy DCS17 Ramsgate Waterfront Land at Ramsgate Waterfront is identified for development for a mixture of leisure, tourism, retail and residential purposes including the following elements: (1) Land west of the Harbour - new residential, leisure, commercial (class b1) and boat yard (repair and storage) ; and (2) Ramsgate Royal Harbour - continued development of mixed leisure and marina facilities, in particular at the military road arches; and (3) Eastern undercliff - mixed leisure, tourism and residential uses. Do you agree with Policy DCS17? Yes 79% No 21% - ERA response ERA reason for answer: 1. We feel Land west of the Harbour is not suitable for residential development. 2. Agreed 3. Agreed Policy DCS18 Ramsgate Port Further development will be permitted at Ramsgate port if it facilitates the improvement of Ramsgate as a port for shipping, traffic through the port, new routes and complementary land-based facilities including marine engineering associated with offshore wind turbines, subject to the following criteria:- (1) a demonstrable port-related need for any proposed land based facilities to be located in the area of the new port, and also a demonstrable lack of suitable alternative inland locations; and (2) compatibility with the character and function of Ramsgate seafront and the Royal Harbour as a commercial and leisure facility; and (3) an acceptable environmental assessment of the impact of the proposed development upon the harbour, its setting and surrounding property, and the impact of any proposed land reclamation upon nature conservation, conservation of the built environment, the coast and archaeological heritage, together with any proposals to mitigate the impact. Land reclamation will not be permitted beyond the western extremity of the existing limit of reclaimed land. Do you agree with Policy DCS18? Yes 92% - ERA response No 8% Policy DCS19 The Council will seek to strengthen Thanet's economic and employment base, and promote access for Thanet's residents to a good range of housing, employment, education, retail, recreational, leisure and community facilities while safeguarding :- • the distinctiveness and attractive character, townscape & setting of the Thanet towns and villages • the health, economic well-being and safety of the community • the character and quality of the coast, the beaches, local landscapes, the wider countryside and biodiversity. • the quality of natural resources including water supply and drainage, air and soil. • against the effects of climate change and flood risk. • historic and cultural features of acknowledged importance • provision of essential services to the public The Council will seek to support the provision and improvements to the quality, capacity, versatility and accessibility of community services including training and education facilities. These should be accessible to the client population, including where appropriate through co-location of services. Greenfield land release may be permitted to accommodate planned expansion of schools, where no alternative option is feasible. Do you agree with Policy DCS19? Yes 88% No 12% - ERA response ERA reason for answer: Existing conservation areas should be safeguarded. Policy DCS20 A) Urban Area & Strategic development Sites New development will be focused on the existing built up parts of the urban belt from Birchington to Ramsgate within defined urban confines, within existing built up and allocated land at Westwood and on land at Manston Park and Kent International Airport as indicated on the key diagram. B) Rural Settlements The scale of development at rural settlements will be limited to minor development such as infilling within village confines. C) Countryside Development outside urban and village confines and not otherwise allocated for development will not be permitted. D) Development will be expected to maintain and promote enhancement of the character and function of the area it is located in. E) Development generating a significant number of trips will only be permitted at locations where a range of services are or will be conveniently accessible on foot, by cycle or public transport. Proposals should consider the needs for access by all groups including people with limited mobility. Do you agree with Policy DCS20? Yes 75% - ERA response No 25% Policy DCS21 Within the Green Wedges new development (including changes of use) will not be permitted unless it can be demonstrated that the development: (1) is not detrimental or contrary to the stated aims of the policy; or (2) is essential for the proposed development to be located within the Green Wedges. Where open sports and recreational uses are proposed, any related built development should be kept to the minimum necessary to support the open use, and be sensitively located. New development that is permitted by virtue of this policy should make a positive contribution to the area in terms of siting, design, scale and use of materials. Do you agree with Policy DCS21? Yes 68% No 32% - ERA response ERA reason for answer: What are the aims of the policy? Policy DCS22 New development aims Do you agree with Policy DCS22? Yes 77% - ERA response No 23% Policy DCS23 Energy Efficiency and Renewable Energy Do you agree with Policy DCS23? Yes 86% - ERA response No 14% Policy DCS24 New employment provision Do you agree with Policy DCS24? Yes 56% - ERA response No 44% Policy DCS25 planning applications for economic development Do you agree with Policy DCS25? Yes 70% - ERA response No 30% Policy DCS26 How land will be identified for 7,500 dwellings over the period to 2026 Do you agree with Policy DCS26? Yes 32% No 68% - ERA response ERA reason for answer: There are numerous run down and empty homes in Ramsgate. Developers should be encouraged to renovate and refurbish these. New build homes should be secondary to this. Policy DCS27 Housing stock Do you agree with Policy DCS27? Yes 80% - ERA response No 20% Policy DCS28 Affordable housing within residential schemes Do you agree with Policy DCS28? Yes 68% - ERA response No 32% Policy DCS29 Development of housesvs flats Do you agree with Policy DCS29? Yes 76% - ERA response No 24% Policy DCS30 On developments of 15 or more dwellings, at least 20% of market units and 100% of affordable units should be developed to Lifetime Standards. Do you agree with Policy DCS30? Yes 88% - ERA response No 12% Policy DCS31 Development resulting in the loss of one or more properties currently or last lawfully used as single family accommodation or by a single household, will be permitted only where the resultant intensity of occupation and form of development are considered compatible with existing residential amenity and the prevailing character of the locality. Do you agree with Policy DCS31? Yes 76% - ERA response No 24% Policy DCS32 Do you agree with Policy DCS32? The use of land to provide accommodation for Gypsies and Travellers or Travelling Showpeople will be permitted provided the proposed use will be compatible with surrounding uses and the site has reasonable access to local facilities and services, particularly schools and healthcare. Yes 79% - ERA response No 21% Policy DCS33 New development will be expected to be supported by all relevant transport, social, physical and green infrastructure. Do you agree with Policy DCS33? Yes 79% - ERA response No 21% CS1 Do you think the Core Strategy is founded on a robust and credible evidence base? Yes 30% No 70% - ERA response CS2 Do you think the Core Strategy is the most appropriate strategy when considered against the reasonable alternatives? Yes 32% No 68% - ERA response CS3 Do you think the Core Strategy is deliverable? Yes 33% No 67% - ERA response CS4 Do you think the Core Strategy is flexible? Yes 33% No 67% - ERA response CS5 Do you think the Core Strategy is able to be monitored? Yes 58% No 42% - ERA response CS6 Do you think the Core Strategy is consistent with national policy? Yes 46% No 54% - ERA response CS7: ERA reason for answers C1-C6: We are not in a position to give a yes/no answer to these questions therefore we have said no to all of them. It is quite possible that some of the above are a 'yes' answer but, as there are areas within the Core Startegy with which we disagree, we have to say no to them all. CS8 Do you think there are any other matters which the Core Strategy should contain? Not answered. |