LDF INSPECTOR'S REPORT

6.7 The Housing and Market Needs Assessment identifies a general need for

affordable housing in the rural areas. The CS recognises that some rural

housing needs will be met in the nearby urban areas, or on strategic

development sites. Policy CP20 allows for sites to be developed to meet

identified local affordable housing needs, as exceptions to the usual policies

of restraint. In general, this approach provides an appropriate framework

for the delivery of affordable housing to meet needs arising in rural areas,

and will be subject to monitoring.

6.8 About a quarter of the affordable housing need in the Borough derives from

the Malling rural area. The CS identifies that allocating a large number of

greenfield sites adjacent to villages would lead to a dispersed pattern of

development in areas with relatively poor access to services and facilities.

The CS therefore proposes to meet some of these needs through the

allocation of a site at Borough Green, a rural service centre with a good

range of services and facilities. I have had regard to those representations

which express the view that Borough Green is not an appropriate location

for new housing development. However, I am satisfied that there is a

pressing need for affordable housing and that development at Borough

Green is likely to lead to a more sustainable pattern of development than

could be achieved elsewhere. I have seen no evidence to convince me that,

if necessary, local services and infrastructure cannot be upgraded to meet

the needs of new development on the scale proposed.

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6.9 The CS identifies Isles Quarry West as a strategic housing allocation. The

site is a former quarry and latterly a landfill site. It lies within the Green

Belt and the AONB. There are two areas which benefit from certificates of

lawful use or development for industrial and related activities. From the

evidence before me, and what I was able to see on my site visit, there

would appear to be potential for some intensification of existing uses which

would not require planning permission. The Employment Land Review

(RD7.4) concludes that this site performs poorly in qualitative terms, and

classified it as an ‘other local' site with potential for release. The loss of the

employment potential of the site would not, therefore, have an

unacceptable impact on the strategy for employment land.

6.10 Vehicular access to the area can currently be gained either via Quarry Hill

Road, a predominantly residential road, or along a private road, known as

the haul road. Whether or not the owners of the haul road would continue

to maintain it in the future is a matter of conjecture. However, given the

length of the road compared to the amount of industrial land available, I

can understand the concerns expressed over the viability of retaining it in

the long term. Without it, vehicular traffic to Isles Quarry, including heavy

goods vehicles, would use Quarry Hill Road. The nature of the uses, and

their lawful status, would make it very difficult to control this activity, either

through planning or highways legislation. Development of the site for

housing would significantly reduce the number of heavy goods vehicles

visiting the site. It would also offer the opportunity for a comprehensive

approach to the management of the highway network in the vicinity, so as

to minimise the impact of traffic generated by the housing development.

6.11 It is to be expected that a site such as this would have some ground

contamination. There is nothing before me to suggest that the site could

not be remediated in accordance with current good practice. Other

constraints, such as any ecological value of the site are matters that will

need to be taken into consideration as more detailed plans are developed. I

do not consider the site to be poorly related to the centre of Borough Green.

I found the walk between the site and the village centre, via Quarry Hill

Road to be a pleasant route. As its name suggests the road is on a

gradient, but I do not consider it would be unduly daunting for most people.

It would be expected that measures to promote sustainability, such as cycle

routes and enhanced bus services, would form part of a package of

development proposals.

6.12 In between the industrial sites, the land has been restored, although the

standard of restoration would not be regarded as an example of current

best practice. Even if further restoration could be achieved, the presence of

the industrial uses would limit the overall effectiveness of such measures.

Therefore, whilst the non-industrial parts of the site fall outside the

definition of previously-developed land (Annex C PPS3), I consider the

description of the site as derelict and despoiled (CS paragraph 6.3.34) to be

an accurate reflection of the visual quality of the site as a whole. The

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topography of the surrounding area means that the site is well screened in

views from the surrounding countryside. Bearing in mind the generally poor

landscape quality of the site, I consider that the proposed development

would have a broadly neutral impact on the natural beauty of the AONB.

6.13 The Council considers the site is capable of producing about 200 houses,

40% of which would be required to be affordable, under the terms of Policy

CP18. This would provide a relatively small proportion of the total

requirement for affordable housing in the Malling rural area identified in the

HMNA. However, I consider it would make a meaningful contribution.

6.14 Borough Green is encircled by the Green Belt, and there is no evidence to

suggest that sites of a substantial size within the village confines are likely

to come forward for development during the Plan period. Therefore, any

sites which could make more than a minimal contribution to affordable

housing will almost inevitably be located in the Green Belt. However, as I

indicate above, the site is well screened from the surrounding countryside,

which would help to minimise the visual impact of the loss of openness. I

do not consider that the gap between Borough Green and Ightham would be

unacceptably compromised.

6.15 It is the demonstrated need for affordable housing in the Malling rural area

which has led to the formulation of Policy CP19. The CS indicates that cross

subsidy with market housing is necessary to make the overall development

viable, and there has been criticism that the evidence base does not fully

justify this assertion. I have some sympathy with this view, as there is no

development appraisal or similar information before me which would enable

me to reach a reasoned view on this point. However, I am mindful of the

Government's policy objective to create a mix of housing, both market and

affordable (paragraph 10 PPS3). The development of sites of any

substantial size for affordable housing alone is likely to lead to a

concentration of such housing2, which would not fulfil that policy objective.

6.16 In this context, I consider that the details of the development economics of

the site, which can change over time, are less important than an indication

that the provision of a proportion of affordable housing, in accordance with

the Council's general aspirations, will be achieved. The site owners have

indicated to the Council that this is the case, and there has been some

scrutiny of this by the Council's valuers. On balance, I am not persuaded

that the lack of a detailed justification on the cross subsidy point renders

the CS unsound.

6.17 The provision of affordable housing is an important factor, but I consider

that it is the range of benefits that would be achieved, arising from the

particular circumstances of this site, which together constitute the

exceptional circumstances necessary to justify the alteration of the Green

Belt boundary. The proposed revised boundary of the Green Belt, as shown

on the Proposals Map, does not at present follow any clear features.

2 A clear indication of the Secretary of State approach to this matter can be found in a recent appeal decision which

forms RD7.27

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However, the development of the site would offer scope to create a clear

boundary.

6.18 The general location of the site is shown in diagrammatic fashion on the key

diagram which forms part of the CS. Revised Borough Green village

confines are also identified in an Annex to the CS and the site is shown on

the Proposals Map. Paragraphs 2.9 - 2.14 of PPS12 give guidance on the

content of a CS, and further guidance on key diagrams is given in Annex A

of that document. Whilst paragraph 2.12 states that core strategies should

not identify individual sites, paragraph 2.13 and Annex A give examples of

where CS polices and proposals will need to be identified on an Ordnance

Survey base Proposals Map.

6.19 Bearing in mind the national importance attached to the Green Belt, I

consider that proposals to alter the boundary can be appropriately included

in the CS. In circumstances such as Isles Quarry West, the altered Green

Belt boundary has the effect of identifying a site for development.

Furthermore, the CS should not leave difficult decisions to later DPDs. The

delivery of affordable housing is an important element of the CS and in the

context of the Malling rural area, this site can reasonably be regarded as a

strategic allocation. In all the circumstances, I do not consider that the

approach taken to the identification of the Isles Quarry Site in the CS is

inconsistent with the advice in PPS12.

6.20 Some criticism of the Isles Quarry West proposal comes from those

promoting sites which they consider to be preferable. In some cases, these

sites may be closer to some facilities, may be developable more quickly, or

may be subject to fewer planning policy restraints, although all those near

Borough Green are within the Green Belt. None, in my view, would offer

the package of benefits that could result from the Isles Quarry

development, as outlined above. I have carefully considered the points

made, but there is no site (or sites) so clearly preferable in overall terms to

the Isles Quarry West proposal, such as to convince me that the CS is

unsound. In particular, I am not persuaded that harm to the purposes of

the Green Belt would necessarily be minimised by developing a smaller site

for affordable housing only. The level of harm that would arise depends not

solely on the size of the area. For example, the loss of a relatively small

area of land where the Green Belt is narrow could be more harmful than the

loss of a larger site in other circumstances.

6.21 I have considered the points raised by local residents and others who

oppose the development of this site. However, for the reasons I have

given, I find the CS to be sound.

6.22 In summary, I find the CS to be sound in relation to the general strategy for

the provision of affordable housing and the identification of a site at Isles

Quarry West to assist in meeting the needs of the Malling Rural Area. I

consider that the tests of soundness are met, having particular regard to

tests 4, 7, 8 and 9.