Housing and new communities
We have a diverse range of communities living within the district and it is important that everyone has a place to call home. Different households will have different requirements, and to reflect the needs of our communities, different sizes and types of houses will be needed.
We want to create attractive, well-designed places that respond to the district’s distinct characteristics and support the shift to net zero carbon emissions. Places that are well designed, promote active travel and integrate with existing communities, with access to open space; like sports facilities, allotments and wildlife sites, and community facilities; such as schools and GP surgeries.
Through the consultation and engagement so far we know that these issues are also really important to our communities, and we’ve prepared options for how we should approach these issues through the new Local Plan.
In this section we’re asking about things like design and zero carbon housing, how we get the right sizes and types of new homes to meet the needs of our communities, and how we make sure that infrastructure is delivered at the right time to support development.
Meeting housing needs
Making sure the right types and tenures of housing are provided
Meeting the housing needs of the community means making sure there is a mix of different sized properties, different number of bedrooms and different tenures (sale or rent) available.
This could mean providing more flatted developments or homes with one or two bedrooms in town centres, while providing larger three or more bedroom family homes in school catchment areas, or providing a different mix of the number of bedrooms in affordable homes or market homes.
The Housing Needs Assessment (HNA) (2021) provides a breakdown of the different types of housing needed by our communities; for example how many family homes, smaller properties such as flats and bungalows and how many homes for rent will be needed.
The HNA identified that the greatest need is for three bedroom homes. Bungalows were also looked at specifically with a need of around 2,440 – 2,950 additional bungalows by 2040. The new Local Plan will set out how those needs can be met.
The responses identified the need for homes to be built for a variety of people in the community, from small homes for young couples to family housing, providing a mix of size, types and tenures. There was conflicting information about priorities, with some people wanting more small homes for young people, while others wanted more bungalows for older people, and others expressed a desire for more family homes.
Issue HNC1. How should we make sure the right types and tenures of housing are provided?
Option HNC1A – continue current approach to allow some flexibility for developers to provide a mix of homes within a broad range
This option is based on the approach currently being used through the existing Housing Strategy.
Housing developments must provide a mix of homes within a range set out in the Housing Strategy, for example 10 – 20% should be two bedroom properties, 20 – 30% should be three bedroom properties.
Anywhere within this range will usually be acceptable, and sites can be designed to reflect these ranges, but with enough flexibility to allow for site specific circumstances.
Option HNC1B – set specific housing mix targets which each site must deliver based on the identified needs for size, type and tenure, across different parts of the district
This option would include a more binding set of requirements for all sites to meet local needs.
Removing the range would limit flexibility for developers but should see the identified mix of homes being delivered for each site.
Different figures would be set out based on the needs identified for different parts of the district (Canterbury, Herne Bay, Whitstable and rural). For small sites, or difficult sites which provide justification that it’s needed, an alternative mix could be considered.
Option HNC1C – (preferred option) – set specific housing mix targets which each site must deliver and identify opportunity sites for specific types or tenures
This option builds on Option HNC1B, but also allows for the identification of opportunity sites for specific types or tenures of homes.
These sites would be based on locational, or other, circumstances which promote the delivery of certain types or tenures of housing. For example, if there is a need for one bed accommodation, these might be most appropriate as flatted schemes in or close by to a town centre.
Providing opportunities for small and medium sized housing developments
The level of housing need identified by the government’s calculations means that new greenfield sites, including some large strategic sites, will be needed to meet identified needs.
This could take various forms like satellite settlements or urban extensions, as set out in the Growth Options section.
Our current Local Plan strategy is highly focused on very large strategic sites, generally with 800+ homes.
This limits the diversity of the sites available to developers to build new homes, and might restrict the ability of Small and Medium Enterprises (SMEs) to engage effectively in the housing market in the district.
The government says that a minimum of 10% of our housing needs must be met through small and medium sized sites of less than 1 hectare.
Based on the government’s standard methodology, we think we’ll need to provide 1,120 homes a year, of which 112 would need to come from sites smaller than 1 hectare.
Small and medium sized sites have benefits like supporting SMEs which are often local companies – they normally come with fewer major infrastructure requirements and they often have more bespoke designs.
These types of sites can be built quickly, and more emphasis on small and medium sized sites through the new Local Plan would support the acceleration of housing delivery in sustainable locations.
It was expressed that a variety of different sized sites would be needed, and should be supported through the Local Plan.
Issue HNC2. How should we approach providing opportunities for small and medium sized housing developments?
Option HNC2A – continue current approach to small and medium sites
The current Local Plan focuses on large strategic sites, often of more than 800 homes.
Few small and medium sites are allocated in the existing Local Plan, and most developments of this size typically come forward as ‘windfall’ developments – sites which are not identified in the Local Plan.
The required 10% small and medium sites might still be achievable by continuing the current approach.
Option HNC2B – increase proportion of supply coming from small and medium sites through additional allocations and windfall sites
This option provides more focus on the delivery of small and medium sites by identifying and allocating land for these types of developments, alongside the windfall approach.
This approach would allow for more proactive management of how and where sites are delivered, including by setting out clear requirements for things like design and infrastructure.
Option HNC2C (preferred option) – maximise opportunities for delivery of small and medium sites to deliver new homes
This option builds on Option HNC2B – taking a more proactive approach to identifying opportunities for small and medium sites – with additional policy support for windfall and organic growth within urban areas.
This includes things like redevelopment opportunities, encouraging the subdivision of large sites for SMEs and considering opportunities for proportionate extensions to sustainable rural settlements to meet identified local needs like affordable housing, including through neighbourhood plans.
Provide opportunities for suitable brownfield and regeneration developments
Brownfield land (also known as previously developed land) is land which is, or was, occupied by a permanent structure.
It doesn’t include agricultural or forestry buildings, land used for minerals extraction or waste disposal by landfill (where provision for restoration has been made), land in built-up areas like residential gardens, parks, recreation grounds and allotments, or land where the remains of the permanent structure has blended into the landscape.
Development needs like housing, employment, community or social facilities should be met on suitable brownfield land as far as possible; however the opportunities for brownfield redevelopment can be limited by factors like land values and land availability.
In some situations brownfield may not be appropriate for development, for example, when it is dangerous to human health or where the site supports important species which can only thrive in certain conditions
Regeneration of areas is one way to make effective use of land. By redesigning and redeveloping areas they can become more desirable, sustainable places to live, work or play, improving the health and wellbeing of our communities.
National planning policies encourage us to make the best use of available suitable brownfield sites, and we have published a Brownfield Land Register which currently has 43 sites.
The current Local Plan identifies land at Chaucer Road as an opportunity site in the longer term for new housing, and a retail area in Wincheap for regeneration.
There might be further opportunities – over the period of the new Local Plan to 2040 – to renew and regenerate areas across the district, like council housing estates and underused, derelict brownfield sites.
People raised various views in regards to brownfield development.
Some said that only brownfield land should be built on, some said brownfield should be built on first then greenfield if there is a need for more land, and others said that brownfield land can be highly important to certain species, so should not always be lost to development.
Issue HNC3. How should we provide opportunities for suitable brownfield and regeneration developments?
Option HNC3A – continue with the current approach to brownfield sites
This would mean continuing to encourage development on previously developed land in suitable locations for new development, rather than locating development on greenfield land.
Option HNC3B (preferred option) – maximise opportunities for delivery of suitable brownfield and regeneration developments
This approach would build on Option HNC3A, exploring further opportunities for regeneration through the new Local Plan.
Making sure that the right densities are delivered in developments across the district
Development should make efficient use of land to minimise the amount of countryside and agricultural land that is built on. This means in some locations, like town centres and near to transport hubs, higher densities might be appropriate.
However, it is not necessarily the case that one density will be appropriate across the entire district. In some areas, lower densities will be appropriate to make sure that new development respects the character, landscape or historic nature of the area.
Recent changes to the national planning policies highlight the importance government places on using land efficiently, particularly where there is an anticipated shortage of land to meet an area’s development needs.
Developments need to make optimal use of the potential of each site and avoid low density schemes unless there are specific reasons for this.
The density of developments must be linked to good design and creating communities, making sure that proposals provide an appropriate mix of homes compatible with the local area, and helping deliver smaller or higher densities in the appropriate locations.
There were mixed views about the density of developments.
Some people encouraged high densities around transport nodes, others commented that it was preferable to build on greenfield land rather than increase the densities of development in the urban areas, and some felt that new developments are designed too densely.
Issue HNC4. How should we make sure that the right densities are delivered in developments across the district?
Option HNC4A – continue current approach of influencing site density through good design
This option continues the approach in the current Local Plan, where it’s influenced through good design and must be considered in its local context on a site-by-site basis.
Option HNC4B – identify a minimum density for the district as a whole, and continue the current approach of influencing site density through good design
This option would reflect the national focus on the need to make efficient use of land, by identifying a minimum density for the district as a whole.
This will not prevent developments being able to build out at a higher density where appropriate, influenced by the local context and good design.
Option HNC4C (preferred option) – set specific densities, or a range of densities, for areas of the district to make best use of the land. Site allocation densities would be influenced by the local distinctiveness and character so that housing fits in with surroundings
This option would build on Option HNC4B by setting out appropriate densities for site allocations or proposals to meet in different parts of the district.
This approach would reflect the different characteristics of areas so for example, there would be higher density development required on sites at or close to town centres, than for sites in the rural areas.
This would reflect the national focus on the need to make efficient use of land, while still allowing proposals to be influenced by local context and good design.
Making sure housing is provided for rural communities
Outside of the city of Canterbury and the coastal towns of Herne Bay and Whitstable, a large proportion of the district is made up of the rural areas, home to many thriving villages and small hamlets of varying sizes and characters.
New housing developments at these rural settlements can provide homes for local people, including affordable housing, and can help to sustain local services and facilities.
The current Local Plan focuses any rural growth at the larger ‘service’ villages which have the most facilities; however many of the district’s rural settlements have seen very limited development in recent years.
This places pressure on existing housing stock, affecting the ability of young people in the area to find housing locally, and can also make it difficult for villages to retain services like pubs or shops.
National planning policies set out a presumption against new isolated homes in the countryside, unless specific circumstances apply.
The new Local Plan will need to set out an approach which allows our rural communities to grow and thrive, while making sure that new development is proportionate and sensitive to the character of our villages.
The existing Local Plan generally limits rural housing development outside of the allocated sites, like at Sturry and Hersden. Development on the edge of villages is largely restricted and there are restrictions too on ‘infill’ housing developments, within the built form of smaller settlements.
Although this approach prevents the rapid expansion or overdevelopment of many of our rural settlements and protects their existing character, it severely limits opportunities for the provision of homes in most of our villages. There is a clear need for additional affordable housing across the district, including in the rural areas.
The Rural Settlement Study (2020) updates our understanding of the relative sustainability of each of the district’s rural settlements.
It shows that many of our villages – the ‘rural service centres’ – have a comprehensive range of services and facilities which allow residents to meet their day-to-day needs without needing to travel into the urban areas.
The study also looks at the relationship between these rural service centres and smaller villages and hamlets nearby.
It suggests that there are various clusters of rural settlements across the district, each centred on a rural service centre, allowing residents in nearby smaller settlements to access a range of facilities without the need to travel into the urban areas. The identified clusters are:
- Sturry and Hersden
In each of these clusters are smaller settlements, categorised as local centres, villages and hamlets, according to the level of services available.
Understanding the relationships and networks between settlements is helpful because national planning policies encourage us to think about whether housing development in smaller rural settlements can help to sustain services and facilities in other nearby settlements.
Some people commented that development should be restricted in the rural areas to protect the character of settlements and their surrounding landscapes.
Many settlements are located within the Kent Downs Area Of Outstanding Natural Beauty, where major housing development is restricted by national planning policies. However, many people recognised that house prices in the villages mean that housing is unaffordable for many people, including young people, and that this issue needs to be addressed.
There was some support for providing more housing in rural areas, and in particular where this helps to meet local needs and enables young people to find housing in the villages.
It was also felt by some that proportionate housing growth should be accommodated at the villages to help to sustain services and facilities which would, in turn, benefit existing residents.
Issue HNC5. How should we make sure housing is provided for rural communities?
Option HNC5A – continue existing approach to rural housing development
This option would keep the current approach which focuses growth only on the more sustainable rural settlements through specific allocations.
It would aim to locate any new rural homes at the settlements with the most services, and would protect the character of other smaller settlements by preventing their expansion and limiting opportunities for infill developments.
Option HNC5B – focus rural housing development at the rural service centres, and support infill development at other settlements within village boundaries
This option would aim to provide opportunities for the rural service centres to grow, and to continue to be the focus for rural housing development. This would include identifying specific sites for development with the design principles set through the Local Plan.
Development at smaller settlements would be permitted where this is within the built form, or village boundary of the settlement, and is acceptable in terms of design and other planning considerations.
This approach would support the delivery of affordable housing in the rural areas by focusing on medium sized developments which would normally deliver a proportion of affordable homes as part of the development.
Option HNC5C (preferred option) – support housing developments at and next to rural services centres, local centres and villages where this provides affordable housing
This option would aim to provide opportunities for the rural service centres, local centres and villages to grow according to their existing size and character.
This would include identifying specific sites for development, setting out design principles, and things like the provision of community facilities and open spaces. Any extensions to settlements would need to be of a sufficient size so that it can provide affordable housing (normally 11+ homes).
Infill developments would also be supported within village boundaries where they are acceptable in terms of design and other planning considerations.
This approach would aim to provide affordable housing in a range of settlements across the district, and more homes would help to sustain existing and potentially additional services in the rural areas, recognising that developments in smaller settlements can support services and facilities in larger settlements nearby.
Community infrastructure and design
Supporting sustainable living in new communities
Sustainable communities are places where people want to live and work, now and in the future.
It is important that new communities have a mix of homes, accessible jobs, facilities like schools, healthcare and shops, and a clean, safe environment. Communities also need opportunities for active travel, access to public transport and open spaces where they can relax.
The Local Plan can influence the sustainability of communities through policies which can support the provision of social and community infrastructure.
This includes services and facilities which communities will rely on to meet day-to-day needs; like primary schools, shops and community meeting spaces, and open spaces.
For larger developments, providing jobs in new communities, for example with flexible or co-working space, can further enhance the sustainability of communities and reduce the need to travel.
National planning policies make it clear that Local Plans should support strong, vibrant and healthy communities to reflect the diverse needs of existing and future generations.
This should be done by promoting a well designed and safe built environment to contribute to a high quality of life, with accessible services and open spaces that support communities’ health, social and cultural wellbeing.
Creating highly sustainable communities can:
- improve the quality of life for residents
- reduce environmental impacts
- promote healthy active communities
- strengthen community cohesion
In the last year, COVID-19 has highlighted the importance for communities to have enough access to services such as local shops and open spaces without needing to travel.
Many people commented on the importance of providing essential services such as shops, medical centres, schools and community facilities; alongside new developments to support sustainable communities.
Others highlighted the need for services to be walkable for communities to reduce the need to travel.
There was also support for new developments to include areas of public open space at their core, and connecting wildlife corridors to support biodiversity and create healthy communities.
Some suggested community hubs could offer co-working spaces in light of COVID-19, as many transitioned to work from home.
Issue HNC6. How can we support sustainable living in new communities?
Option HNC6A – continue with the existing approach to supporting sustainable living in new communities
The current approach needs strategic development sites to incorporate social infrastructure, and community facilities based on garden city principles, like open space, recreational and cultural facilities, and shopping.
This approach provides a set of guiding principles for the very largest sites, but allows significant flexibility on how these principles are then delivered at the planning application stage, where more information is normally available.
Option HNC6B – set clear requirements for new or improved social and community infrastructure to be delivered as part of strategic developments
This option would set specific requirements for the delivery of social infrastructure and community facilities at strategic development sites in the Local Plan.
These would normally be provided within the site, although there might be some cases where it is preferable to make provision off-site, or by improving or expanding existing facilities.
For example, this approach could mean that new developments of 100 or more homes have to provide a neighbourhood or local centre with a shop, and sites over 500 new homes have to provide a new community hub, which could support a co-working area and other community facilities.
Option HNC6C – (preferred option) set clear requirements for new or improved social and community infrastructure to be delivered as part of strategic developments, and large developments must show that essential services can be accessed within 15 minutes walking or cycling time
This option would build on Option HNC6B to broaden and step up the requirements for large (but non-strategic) developments.
For example, it would make sure that proposals of 50 or more homes would need to show that key services, such as primary schools and shops, can be accessed within 15 minutes walking or cycling times.
Making sure all design is high quality
Design influences how we feel, and how we experience the places where we live, work and spend our leisure time.
There are a number of design tools we can consider as part of the new Local Plan, which would provide different approaches to securing high quality design from new developments.
Design codes can help to proactively plan for better design of a site or area. They are a visual and descriptive set of rules which can set out the design requirements on:
- the layout of new development, including street pattern
- how landscaping should be approached including the importance of streets being tree-lined
- the factors to be considered when deciding whether façades of buildings are high quality enough
- the environmental performance of places and buildings, making sure they contribute to
net zero targets
- how developments take account of local architecture, heritage and materials
A masterplan sets the vision, objectives and implementation strategy for a development. It is likely to include a range of information, such as:
- the site context – where the site is, what land uses and facilities are currently on the site, next to it or nearby
- any service information, like water, electricity, and gas
- the landscape strategy, taking account of existing natural features and new structural elements
- the amount and position of open space provision
- the number of homes and other uses
- the points of access and connection to the wider street network
- the broad position of the primary and secondary streets (but not local streets)
- the position of the local centre if relevant
- the area types that will apply to different parts of the site (which will reference rules on density, height, street building line and so on)
Design and Access statements submitted at the planning application stage help to make sure that development proposals are based on a thorough design process with a sustainable approach to access.
Well designed places influence the experiences we have in the places where we live, work and spend our leisure time.
The National Design Guide highlights that well designed places have been shown to benefit health and wellbeing, feelings of safety, security, inclusion and belonging, and sense of community cohesion.
Stakeholders made it clear they want to see high quality design across the district in order to create healthier communities and contribute positively to the council’s objectives for climate change.
The consultation and conference evidence supports the use of master plans for new developments, and people suggested that the community should be more involved in the process.
Issue HNC7. How should we make sure all design is high quality?
Option HNC7A – continue current criteria based approach to design
This option sets out design criteria to be addressed by applicants – for all types of developments including commercial or office development – and means that strategic sites at planning application stage must have a master plan.
For the very largest sites, this should identify through the planning application; how the site fits into the wider surroundings, physical and social infrastructure provision, phasing and timing, and detailed design proposals.
Option HNC7B – use the new National Design Guide and National Model Design Code
This option would use the National Design Guide and the National Model Design Code to provide a high level overarching framework for all types of development.
This would be used to help prepare more detailed design guides and codes for sites or areas, which would be developed outside of the Local Plan.
Option HNC7C (preferred option) – embed master plans and design requirements for strategic development sites in the Local Plan, and continue current design criteria based approach for other sites and types of development; setting out when specific design tools like design codes should be used
This option reflects a more proactive and upfront approach to the design and delivery of key strategic development sites, providing more certainty and clarity on how sites will be designed and built out through the Local Plan itself.
Design criteria would remain applicable for other developments; like commercial, office or smaller housing developments, but there might be circumstances where it would be beneficial for tools like design codes to be developed outside of the Local Plan – for example, through neighbourhood plans or for opportunity with regeneration sites.
Delivering low carbon and energy efficient housing
Heating and powering buildings currently accounts for 40% of the UK’s total energy usage, and this is a similar proportion at a Canterbury district level. It is government policy to set minimum energy efficiency standards for buildings to put the nation on the right path to achieve the net zero target by 2050.
This covers a range of issues related to low carbon and energy efficient housing; including new homes, changes to existing homes, water efficiency and renewable energy.
Alongside the need to make buildings that use much less energy, there are other important sustainability goals to make the built environment good for people and for natural resources. Buildings need to be resilient to overheating and prepared for heavier extreme rainfall events.
As well as new construction, around 7,000 homes in the district undergo major building work each year. Projects to improve homes are the ideal time to improve energy efficiency, reduce carbon emissions and cut energy costs.
It is more cost effective to make these changes at the same time, and so the new Local Plan will need to think about how best to support the transition of all homes in the district to net zero by 2050.
Retrofitting existing buildings to make them more energy efficient is critical for the district to hit 2050 net-zero carbon targets. The Local Plan can help to achieve this target by applying tighter controls to planning applications for changes to existing homes.
Currently there is no requirement for changes under 1000sqm to achieve energy efficiency standards. The Local Plan will need to think about how existing buildings can reach net zero.
Energy plans are one method which can be used to show how development proposals will meet carbon emissions targets. A development-level energy plan will set out how the energy requirements for space heating, hot water and electricity will be met, with the objective of generating the lowest possible operational carbon emissions.
Larger developments might have opportunities to deliver integrated community-level solutions like heat or energy networks.
Other methods for getting effective and timely emissions reductions include setting local energy and carbon emissions standards for new construction, and changes to existing buildings.
Retrospectively changing and adapting the fabric and infrastructure of existing buildings to address energy, climate change and sustainability issues is expensive, disruptive and has not been happening at the pace needed.
The development of new standards for buildings at national level though the Future Homes Standard provides clear evidence for setting standards for designing and constructing buildings that have high thermal performance and are net zero ready.
This means that homes will be constructed to high thermal standards and that further retrofit work to transform them to zero carbon homes would be minimised.
London Borough planning authorities have implemented net zero emissions standards for new developments since 2016.
Best practice guidance from the Royal Institute of British Architects is to set the sustainability outcomes upfront in the project, and this is helped by clear requirements through the Local Plan.
Stakeholders made it clear that the energy and sustainability of standards for new buildings and major changes to existing buildings should be set at the highest possible level.
A minority of people wanted to stick to minimum standards.
Issue HNC8. How can we deliver low carbon and energy efficient housing?
Option HNC8A – continue current approach but with indicative net zero
This option would continue the current Local Plan approach, which doesn’t set any particular local building standards for energy or sustainability, as it relies on national standards.
We would continue to encourage developers to aim for higher standards to indicate how net zero might be achieved, but this wouldn’t be mandatory.
Option HNC8B – early introduction of Future Homes Standard
This option would introduce the need for new buildings design to meet the Future Homes and Buildings Standards from 2023, two years earlier than its planned introduction in 2025.
The Future Homes Standard will make sure that an average home will produce at least 75% lower operational CO2 emissions than one built to current energy efficiency requirements, and that homes built under the Future Homes Standard will be zero carbon ready.
This would accelerate the transition to better homes, as well as leading to a direct reduction in emissions at a district level, and greater resilience for homes built in the early years of the new Local Plan.
Option HNC8C – (preferred option) all new homes delivered to net zero
This option would incorporate new standards into the new Local Plan at full net zero operational emissions.
The method for deciding this at design stage would need to be set out using an agreed approach like the emissions rate in the Standard Assessment Procedure or Passive House design, and then checked at the completion stage through the Energy Performance Certificate or Passive House Certification.
This option would also include a method for payment for any developments failing to meet the standard using an agreed carbon price which would contribute to a district decarbonisation fund.
Refurbishments and changes to existing homes
Option HNC8D – require planning applications to have an energy plan for improvements to energy performance
This option would encourage people making adaptations and doing work that need planning permission to think about opportunities, through an energy plan, to improve the performance of the overall building.
Option HNC8E – apply the requirement to meet Building Regulations Part L energy standards to changes to buildings to all but the smallest extensions, and require planning applications to have an energy plan for improvements to energy performance
Currently a building change that needs planning permission, like a loft conversion or extension, doesn’t need higher energy performance unless it is over 1,000 sqm.
This option would mean applications would need to change a building to achieve the latest standards of building regulation energy efficiency, and would also need an energy plan to look at opportunities to improve the performance of the overall building.
Option HNC8F – (preferred option) set higher local domestic build energy standards for changes to existing homes, and require planning applications to have an energy plan for improvements to energy performance
This option would build on Option HNC8E, to set local standards for energy performance and sustainability as well as making sure applications have an energy plan for improvements to energy performance.
For example, this could mean that an existing home which needs planning permission for an extension would need to lower operational emissions of the whole property by improving the insulation, ventilation of the existing building and changing the primary heating system from a gas boiler to a heat pump.
This approach would lead to a more rapid improvement of the district’s existing building stock to reduce energy use and move towards net zero carbon emissions goals.
Improving water efficiency
The south east of England has some of the lowest rainfall in the UK and is classed as a ‘water stressed’ area by the Environment Agency.
Climate change forecasting shows that more serious water shortages are expected in the next 20 years, affecting the balance between water supply and demand. Without significant innovation and increased water efficiency, we will need to rely on expensive water transfers and new supply options.
National planning policies encourage Local Plans to take a proactive approach to mitigating and adapting to climate change, which includes thinking about the long term implications for water supply.
In this context, it is important we achieve higher water efficiency standards of 110 litres per person per day for all developments.
With the move towards ever greater efficiency, and the scope through new technologies to integrate water recycling and management systems and green infrastructure – for example with grey water systems – the new Local Plan will need to think about whether higher efficiency targets should be introduced for the very large or strategic developments sites.
South East Water explained how the water supply in this area is reliant on the groundwater that also feeds the River Stour.
The future resilience of this resource is vulnerable to increasing demand, predicted drier winters and reduced recharge due to land management practices and new development.
They said that the new Local Plan offers a strong opportunity to lock in water efficiency, resilience and adaptivity into development.
Southern Water also gave their support for thinking about how to reduce water consumption and manage water supply.
Issue HNC8. How should we improve water efficiency?
Option HNC8G – continue with the current approach to water efficiency
The current approach encourages developments to minimise water use as far as possible by incorporating appropriate water efficiency and water recycling measures.
In new homes, we ask for a required level of 110 litres maximum daily allowable usage per person, but there are no requirements for developments to show that this standard is achieved.
Option HNC8H – require proposals for new homes to show the higher water efficiency standard of 110 litres per person per day
This option would strengthen the existing approach that all residential developments show, through the planning application process, that the higher water efficiency standard of 110 litres per person per day (including external water use) will be achieved.
All developments would need to show how water efficiency and water reuse measures have been maximised.
Option HNC8I – (preferred option) blended approach to require proposals for new homes to show the higher water efficiency standard, and for large or strategic sites to exceed the current building regulations
This option would build on Option HNC8H by requiring large or strategic sites to show water efficiency standards that exceed the current building regulations, to achieve a maximum use of 90 litres per person per day of potable water (including external water use).
This would expect large or strategic sites to show water efficiency and demand management measures to be implemented to minimise water use and maximise the recycling and reuse of water resources, using integrated water management solutions. We would also welcome views on whether water efficiency levels higher than this are achievable.
Incorporating renewable energy within new developments
As well as the need to reduce the energy demand within the new and existing commercial and housing developments through energy efficiency measures, there is a need to increase renewable energy generation to the maximum potential to reduce carbon emissions and the causes of climate change.
Within the built environment, solar photovoltaic panels that generate electricity are a tried and tested renewable energy technology. Solar thermal panels that produce hot water are also effective.
Canterbury district has nearly the highest solar energy potential in the UK. Although both solar technologies are well established and cost effective measures to reduce carbon emissions, the uptake within the district is far below potential and needs to accelerate in order to meet net zero goals.
Stakeholders are very supportive of an approach to maximise the use of rooftop solar panels for both new and existing construction and for all types of buildings, with the exception of some concerns about some heritage buildings.
Issue HNC8. How should we incorporate renewable energy in new developments?
Option HNC8J – continue with the current approach to reducing carbon emissions associated with energy from new developments
This option would continue to encourage new development in the district to include proportionate measures to reduce carbon and greenhouse gas emissions.
The current policy doesn’t insist on renewable energy generation, but national policy encourages 10% of the energy demand to be met by onsite renewable energy for developments over 10 properties.
Option HNC8K – (preferred option) require all new large or strategic developments to show decentralised energy supply
This option would mean all new developments have to comply with requirements for decentralised energy supply; maximising the renewable energy generation at the development site, unless they can show that it’s not feasible, for example because of the type of development or its design.
This will require applications to look at landform, layout, building orientation, massing and landscaping to minimise energy consumption and integrate renewable energy generation to the development.
Specialist housing needs
Based on the national methodology for determining Local Housing Need (LHN), we currently have an identified annual need for 1,120 new properties.
The LHN includes the need for different types of homes. We need to make sure that there are homes for everyone, including those who need particular types of homes such as:
- key workers
- affordable housing (rent and shared ownership)
- families with children
- older people (from independent living or care homes)
- people with disabilities
- service families
- first time buyers
- gypsies and travellers
The availability of affordable housing is a key issue across the district and the Housing Need Assessment (HNA) (2021) has identified the amount of affordable housing needed. Without considering any anticipated supply (like from sites with planning permissions) the HNA identifies a need for around 464 affordable units per year over the period of the new Local Plan to 2040.
National planning policies define the different types of affordable housing products which can be secured through the planning system, which split broadly into two tenure categories – those for affordable rent (typically at 80% of market rent values) and those for affordable home ownership, such as shared ownership.
Of the overall need of 464 affordable homes per year identified in the HNA, 308 are for affordable rent while 156 are for affordable home ownership.
The current Local Plan requires that 30% of homes of sites of 11 or more properties are delivered as affordable housing; of which 70% is for rent and 30% is for ownership. The HNA indicates that this split across the tenures remains broadly stable, however the level of affordable housing need is significantly higher than 30% of the total housing need, as was the case for the current Local Plan.
The government undertook consultation last year on a potential new affordable housing product known as First Homes; based on the idea of providing market homes at a 30% discount for first time buyers. We will need to consider how best to approach this once the details of the scheme are finalised.
Although the Growth Options section sets out options which could boost the supply of affordable housing, the percentage of affordable homes required from new development sites will be considered at the next stage of the process, alongside other things that affect development viability.
Providing housing for older people
People are living longer, which means that the numbers of older people in the population is increasing. Older people can have specific housing needs and require a choice of accommodation to suit their changing needs; supporting them to live independently for longer and stay connected with their communities.
The health and lifestyles of older people can differ greatly, and so there are a range different accommodation products being offered by the market:
- independent living: often in adapted existing homes, or bungalows for those less able to get about
- age-restricted general market housing: generally for people aged 55 and over and the active elderly. These developments often include some shared amenities such as communal gardens, but would not include support or care services
- retirement living or sheltered housing: usually in purpose-built flats or bungalows with limited communal facilities such as a lounge, laundry room and guest room. Care services are not normally provided, but there is some support like 24 hour on-site assistance (alarm) and a warden or house manager to support residents to live independently
- extra care housing or housing-with-care: normally purpose-built or adapted flats or bungalows with a medium to high level of care available. Residents are able to live independently but, if required, there is 24 hour access to support services and staff, and meals are provided. There are extensive communal areas, such as space to socialise or a wellbeing centre. These developments can be known as retirement communities or villages, as the intention is for residents to benefit from varying levels of care as time progresses
- residential care homes and nursing homes (including dementia care homes): usually individual rooms within a residential building providing a high level of care meeting all activities of daily living
With an aging population, it is anticipated that a variety of accommodation will be required to meet the needs for specialist older persons housing. The HNA provides a breakdown of the scale and type of accommodation needed by older people, including around 1,150 extra care home beds with about 26% providing nursing support, around 576 age exclusive housing and around 1,732 specialist units (this includes sheltered housing and extra care housing).
Many people commented that there was not enough housing for older people in the district, and this was an increasing concern.
It was also felt that housing for older people should be appropriately located so that they can access local facilities like community halls, post offices and shops.
Issue HNC9. How should we provide housing for older people?
Option HNC9A – all large or strategic sites to provide a proportion of the site for older persons’ housing (for example 5%)
This option would mean that larger or strategic sites would set aside a proportion of their site for older persons’ accommodation.
The type would be directed by the HNA so that communities are supported by the appropriate type of accommodation. Therefore, these sites would support a mix of affordable and market homes, along with older persons accommodation, so that older persons’ housing is effectively integrated in new communities.
Option HNC9B – allocate specific sites for the delivery of older persons’ housing
This option would identify specific sites for the delivery of bespoke older persons’ accommodation in the Local Plan, where suitable sites are identified.
Given the scale of the need identified in the HNA it might not be possible to meet the needs in full with this approach.
Option HNC9C (preferred option) – provide a blended approach with a proportion of the site being delivered through large or strategic sites and allocated specific sites
This option would look to maximise the availability of land for older persons’ housing developments, taking opportunities to allocate specific sites where available, and also setting requirements for large or strategic sites to make sure that some older persons’ accommodation came forward within these large new communities.
Providing accessible and disability-friendly homes
Buildings and places should be designed to meet the highest standards possible for access and inclusion. An inclusive environment is easy to use and access, and with homes that are adaptable over time to meet changing needs. It is important to make sure that full access is integrated into all design features, rather than being seen as an add-on or just for disabled people.
Inclusive flexible design should futureproof developments to make sure that they are accessible to all sections of the community, and homes designed so that they can adapt with the changing needs of our aging population.
The new Local Plan will need to reflect the housing needs for different groups in the community, including people with disabilities and older people. Development should be designed to be accessible and inclusive for these groups within the community, now and in the future.
National planning policies allow us to set local standards for the provision of adapted homes, reflecting identified local needs based on the categories set out within Building Regulations. This means we can set requirements for the provision of adapted properties through the Local Plan, like:
- M4(2): accessible and adaptable properties – new homes make reasonable provision for most people to access the property and have some features to make them suitable for older people and individuals with reduced mobility; or
- M4(3): wheelchair user properties – new homes provide for a wheelchair user to live in the property, to use the outdoor space, communal facilities and parking
The HNA sets out that we will need an additional 2,200 homes to have some form of adaptation by 2040. Although most of this need is for M4 (2) standards, around 700 – 1,000 people will need homes built to M4 (3) standards by 2040.
Most of this need for wheelchair user properties is in the older age groups, including care home residents.
The consultation highlighted that people thought more engagement was needed with people with disabilities to find solutions for greater access, and that more wheelchair accessible homes should be built to support the needs of the community.
Issue HNC10. How should we provide accessible and disability-friendly homes?
Option HNC10A – continue current approach for 20% of new properties to be built to M4 (2) standards on major developments and strategic sites
This option would continue the current approach so that major developments (such as those of 11 or more properties) and strategic sites would need to provide 20% of new properties built to M4 (2) standards.
Option HNC10B – make sure that all new properties are built to a minimum of M4 (2) standards, and encourage M4 (3) standards
This option would make sure that all new homes are built to a minimum of M4 (2) standards. This would go beyond the quantitative needs and could have impacts on viability, but would give equal access to all new homes for a greater proportion of our community. M4 (3): Wheelchair users standard would be encouraged but not specifically required.
Option HNC10C (preferred option) – require around 15% of new properties to be built to M4 (2) standards, and around 5% to be built to M4 (3) standards on major developments and strategic sites, to better reflect the needs
This option would provide a mix of homes of M4 (2) and M4 (3) standards which would reflect the needs identified within the HNA.
By requiring some new properties to be built to M4 (3) standards, this would make sure that a proportion are built to be accessible for wheelchair users, which is not a requirement in the current Local Plan. Where appropriate, the 5% M4 (3) standards would generally be directed towards older person accommodation.
Providing opportunities for new student accommodation
Our district supports a large student population, with four universities: University of Kent, Canterbury Christ Church University, University for the Creative Arts, and Girne American University. Plus there are several further education establishments like Canterbury College and CATS College Canterbury.
Most students need accommodation in the local area and in easy reach of their academic spaces; accessible by walking, cycling or public transport. Although some students will live at home with their families, most will meet their accommodation needs through purpose built accommodation or shared houses – known as houses in multiple occupation (HMOs).
Not all students live the entire year in our district, but given the scale of the student population, the location and design of student accommodation can have a significant impact on local areas and communities.
The existing Local Plan includes a policy restricting the proportion of HMOs in the residential areas of Canterbury to manage the balance of students and residents in these areas. The HMO policy limits the number of residential properties which are converted into HMOs to not exceed 10% within a 100m radius.
Although we don’t currently have any evidence that this needs changing, this will be kept under review as we progress the Local Plan.
The number of students enrolled at local universities has increased substantially since 2001, with an estimated 30,000 students now enrolled at three campuses in the district. Around 24,300 of these are full-time students, a significant increase on the 2011 Census count of 18,354.
Our district has one of the highest ratios of students to permanent residents in England at 16.4%, compared to a national average of 6%.
The number of purpose-built student accommodation (PBSA) bedspace is estimated at 8,850, meaning that approximately 55% of all students who move to Canterbury to study can be accommodated in this type of housing.
The recent growth in PBSA now means that there are 1.9 full-time students for each PBSA bedspace. This ratio has changed significantly in recent years – it was 3.6 students for each bedspace in the 2011 Census.
The University of Kent and Christ Church University have both published ambitious master plans for their campuses, designed to consolidate and expand their capacity for teaching and research.
The challenges for our universities as a result of COVID-19 have been, and continue to be, unprecedented. Over the past year they have radically changed how they operate, providing almost exclusively online services to students.
The UK’s exit from the European Union will also affect access to important European research funds, and might affect the recruitment of students from overseas, particularly from the EU. This has the potential to impact the proportion of overseas students coming to the district to study, in particular for the University of Kent.
However, between 2003–2012 there were high levels of births across the UK meaning the number of young adults considering entry to higher education is projected to increase. This may help to offset some of the future challenges.
With the expectation that academic spaces will grow, supporting a larger student population, more accommodation will be needed. The HNA (2021) has provided some guidance on the accommodation needs of the students over the period of the new Local Plan.
Some people raised concerns about the high numbers of purpose built accommodation developments and HMOs for students in the district. However, it was also mentioned that more purpose built accommodation would free up existing housing stock for local residents. A solution of prioritising unused student accommodation as affordable housing was also suggested.
It was also mentioned that there is a level of uncertainty around the number of students who will physically travel to university and need accommodation in the future, because of the impacts of COVID-19. There might be a change to more online learning, as has been the case over the last year.
Issue HNC11. How and where should we provide new student accommodation?
Option HNC11A – continue current approach to purpose built student accommodation
The current approach provides significant flexibility in how and where purpose built accommodation can be delivered.
Option HNC11B – provide purpose built student accommodation only on or near campus, for example within a 5-10 minute walk of the campus
This option would restrict the potential locations for new purpose built accommodation to areas in or close to campus.
As mentioned above, many students rely on public transport and walking, so having student accommodation close to the campus is likely to be preferable for students, although this approach might limit the availability of suitable land to deliver new accommodation.
Option HNC11C (preferred option) – provide purpose built student accommodation on or near campus, for example a 5-10 minute walk, but also have some flexibility on alternative locations subject to strict criteria
This option would make sure that new student accommodation was provided close to campus. However, while some further and higher education institutions might have space in their campus to support the accommodation requirements of all their students, this might not be applicable for every institution.
In cases where there is no appropriate location on or near the campus, the applicant would have to show why that is the case and how the proposed site is appropriate for criteria like public transport accessibility.
Providing accommodation for gypsies and travellers
It is important that we plan positively to meet the housing needs of gypsies and travellers, and travelling showpeople. Gypsies and travellers are defined through the planning system as people of nomadic (wandering) habit of life, whatever their race or origin. Travelling showpeople are defined as members of a group organised for the purposes of holding fairs, circuses or shows. Meeting the housing needs of these groups could be through seasonal, temporary or permanent use of land.
National planning policies set out that Local Plans should assess the needs of gypsies and travellers and travelling show people, and set a target to meet that need. Local Plans can meet an identified through identifying land or by setting criteria to assess planning applications against.
The current Local Plan sets out criteria for assessing gypsy and traveller planning applications, but does not include any allocated sites for these uses.
The 2018 Gypsy and Traveller Accommodation Assessment (GTAA) set out a five year supply requirement (2017- 2022) of 17 pitches, and a longer term need (up to 2037) of 29 pitches for gypsy and travellers. There was no identified need for travelling show people.
Completion data from 2017 to 2020 showed delivery of 14 pitches over the last three years. A further nine pitches have been granted planning permission, providing supply for future years. We currently have a five year Gypsy and Travellers position of 6.96 years.
The HNA (2021) builds on the 2018 GTAA and identifies that there is a need for 20 pitches for gypsies and travellers, and no identified need for travelling showpeople between 2020-2040.
The need for suitable sites was identified as an issue through the consultation, and some people commented that more gypsy and travellers sites are needed.
Issue HNC12. How should we provide accommodation for gypsies and travellers?
Option HNC12A – continue current approach to meeting gypsy and traveller housing needs
This option continues the current responsive approach to the changing needs of the gypsy and travellers in our community. New sites or extensions to existing sites would be needed to meet a set of criteria similar to that already in use.
Option HNC12B – allocate new pitches (either as new sites or extensions to existing sites) to meet gypsy and traveller housing needs
This option would allocate the number of pitches needed to meet our district’s identified need for the entire Local Plan period (until 2040).
This would not allow for a dynamic response to changes, and windfall sites would have a high criteria to reach to be considered appropriate as the need would be met elsewhere.
Option HNC12C (preferred option) – continue current approach and take opportunities through the Local Plan to allocate new pitches where suitable sites are identified
This option would continue the current responsive approach to the changing needs of the gypsy and travellers in our community.
New sites or extensions to existing sites would be needed to meet a criteria similar to that already in use. However, if they are identified through the Local Plan process, they could be allocated towards the identified needs – providing a positive and flexible approach for people wanting gypsy and traveller accommodation.
Supporting opportunities for self and custom-build housing
Self and custom-builds are normally projects where an individual or family has a piece of land on which they build a home designed to their specific requirements, that they then live in.
This allows people to design their own home to suit their lifestyle and budget, instead of buying an already constructed home.
The current Local Plan does not identify specific requirements for self and custom-build housing, however these homes are being delivered as ‘windfall’ developments. The new Local Plan will need to set out a positive strategy for delivering self and custom-built homes to support high quality, sustainable designs, and to widen the choice for people who want to do this.
We keep a Self Build and Custom Housebuilding register to monitor the demand for people who want to build their own homes in the district. As of April 2021, there were 31 entries on the register, of which 22 had a local connection to the district.
Using the register, the HNA (2021) identified that the demand for self-build housing is less important when considered against the overall housing need figure; the type and size of housing requirement should be considered in the overall property mix.
Many people supported different ways of providing housing with greater flexibility, including providing a blend of market properties and self build plots, and considering using council owned land to provide plots for self and custom-build housing developments.
Issue HNC13. How should we support opportunities for self and custom-build housing?
Option HNC13A – all large or strategic sites to provide a proportion of plots for self and custom-built homes (for example 5%)
This option would mean that larger or strategic sites will set aside a proportion of their site for self and custom-built homes. This will mean the larger strategic sites have a mix of affordable, market and self and custom-built homes, and therefore broaden the different types of housing needs being met through these sites.
Option HNC13B – allocate specific small sites (up to 10 units) for the delivery of self and custom-build housing
This option would allocate small sites (for example up to 10 units) specifically for self and custom-built homes.
This could provide parcels of land for the construction of bespoke homes; however the effectiveness of this approach might be limited by the opportunities available to deliver this type of housing on suitable sites.
Option HNC13C (preferred option) – provide a blended approach with a proportion of plots being delivered through large or strategic sites, and allocated specific small sites
This option would maximise the availability of land for self and custom-built homes, taking opportunities to allocate specific sites where available, and also setting requirements for large or strategic sites to make sure that some building plots came forward in these large new communities.
Delivering infrastructure to support growth
Maximising the benefits of strategic infrastructure investment
The provision of strategic infrastructure, like schools, hospitals and broadband connectivity, is critical for supporting population and housing growth in our district. Infrastructure brings communities together and improves people’s daily lives, from meeting residents’ water and energy needs, to making sure that there is good access to healthcare and school places.
Strategic infrastructure also underpins the economy of the district. Well-planned, high quality infrastructure is a major factor for companies in determining where to locate and expand.
We will need to work collaboratively with key infrastructure providers to align with their investment strategies, which will provide not only district-wide but regional outcomes.
Infrastructure providers working in our district have identified infrastructure improvement opportunities to support growth into the long term future.
We need to take into account and support the delivery of local strategies to improve health. Kent and Medway NHS have been developing proposals and have a shortlist for two options for hospital provision in east Kent. Our preferred option is to develop a new hospital at Kent and Canterbury Hospital and to refurbish some of the current hospital buildings to provide a modern A&E and specialist services which would serve the whole of east Kent. The alternative option would see investment focused at Ashford and Margate.
It is important that we make sure there is enough choice of school places for children in the district. KCC is responsible for planning for school places, but the Local Plan can play an important role by securing land and developer contributions towards the delivery of key school infrastructure alongside new homes. KCC has been clear for some time now that there is a need for additional secondary and grammar places at the coast.
Local Plans can also play a part in helping to increase the use and supply of renewable and low carbon energy and heat, which is a key area in the efforts to meet our climate change objectives. The government recognises that nationally, while the UK leads the world in the deployment of offshore wind, there are opportunities to develop greater energy generation through onshore wind and solar too.
Locally we are well placed to capitalise on these opportunities, with our coastline and higher annual average of sunshine hours compared to other parts of the UK. There is also an opportunity to boost support and economic growth for the low-carbon energy sector to lead to more schemes similar to the new hydrogen plant facility being built at Herne Bay.
We know that the south east of England is under water stress and suffers from water shortages in the summer. To help to make sure there is enough clean water, South East Water has confirmed that a new reservoir at Broad Oak will be needed by 2033, which is in the period of the new Local Plan.
We will continue to engage with Southern Water to understand the need for any additional treatment and sewerage capacity to serve new development in the district, and to make sure that development is coordinated with the necessary wastewater infrastructure.
The new Local Plan will need to allow the expansion of electronic communications networks, including next generation mobile technology (like 5G) and full fibre broadband connections.
KCC have said that it is essential that new-build properties are able to access high-quality and future-proofed broadband connectivity, as opposed to retro-fitting later.
The Government Digital Connectivity Portal guidance says that Local Plans should outline how planning policies will support the rollout of both fixed and mobile digital infrastructure, for example, by making sure that all new developments have sufficient ducting space for full fibre connectivity, and supporting the effective use of rooftops and street furniture to accommodate digital infrastructure, including small cells for 5G.
The consultation responses highlighted opportunities to address existing deficiencies in infrastructure capacity and quality.
Concerns around the current healthcare provision in the district primarily centered around the need for accident and emergency services, and there was support for the redevelopment of Kent and Canterbury Hospital. KCC said that they would like the hospital site to be placed where it can be accessed by both the city and directly off the A2, and/or an improved A28, to reduce hospital-bound traffic from using the central ring road.
Concerns were also voiced about there being limited school places, especially in areas with new housing communities. It was felt that travel to and from schools, especially to and from the coastal towns to Canterbury, is a significant contributor to traffic congestion. There was support for the provision of another secondary school or grammar school on the coast to reduce the number of pupils travelling into Canterbury.
To help to tackle climate change, there was endorsement for greater renewable energy generation in the district. Suggestions included the creation of more solar farms and onshore and offshore wind turbines, and there was a call to find sites for these purposes. Options for renewable energy infrastructure are in the next section.
There were several concerns raised about the resilience of the clean water supply, and there was support of a new reservoir at Broad Oak. It was felt that a new reservoir will provide opportunities to enhance the existing natural and historic landscape.
Concern was also expressed about waste water discharge creating environmental issues, like those at Stodmarsh. The consultation pointed to the need for better sustainable drainage systems for new developments, which involve green infrastructure.
In terms of digital infrastructure, there was support for faster and more reliable broadband across the district; particularly in rural areas, to support rural businesses and home working. The consultation also showed support for next-generation mobile networks like the rollout of 5G.
Issue HNC14. How can we maximise the benefits of strategic infrastructure investment for residents and businesses?
Option HNC14A – continue current approach to strategic infrastructure projects
The current approach provides broad encouragement for strategic infrastructure projects, to make sure enough provision is made for various infrastructure types alongside new development.
This support for strategic infrastructure is reflected in different ways, across several policies directed at various infrastructure types. The Local Plan mentions strategic infrastructure projects like the Broad Oak Reservoir, and it identifies a specific allocation for new development related to Kent and Canterbury Hospital.
Option HNC14B – provide overarching general support for strategic infrastructure projects which are needed to support growth
This option builds on the current approach in the Local Plan, but reflects this through a single strategic policy which provides support to infrastructure proposals needed to support development.
It would set out generic requirements for strategic infrastructure projects; for example that primary healthcare facilities are accessible by sustainable transport (walking, cycling and public transport), and to not create unacceptable environmental impacts.
This option allows flexibility but also some certainty to infrastructure providers to progress major infrastructure projects from outline to design stage and beyond.
Option HNC14C (preferred option) – provide overarching general support for strategic infrastructure projects needed to support growth, and identify specific allocations and set criteria like design for proposals where justified
This option would build on Option HNC14B to allocate sites and take a more proactive approach to the delivery and design of infrastructure projects, if this is justified and where they are sufficiently progressed.
This would involve setting policy criteria for each allocation; related to the scheme design, connectivity, capacity, and other public benefits, to manage some of the outcomes of projects through the Local Plan.
Land would be allocated in the Local Plan for all infrastructure types where the need for strategic infrastructure projects has already been established, which might include a new hospital at Canterbury, a new secondary school on the coast and a reservoir at Broad Oak.
Enhancing the production of renewable energy
Renewable energy provides reliable power supplies and fuel diversification which enhances energy security and reduces the need for imported fuels. They emit no or low greenhouse gases and no polluting energy, making them the cleanest, most viable solution to prevent environmental degradation.
Clean energy is vital for combating climate change and limiting its most devastating effects. Renewable energy also helps conserve the nation’s natural resources and will continue to be a key component to tackling the climate crisis.
Community and utility scale renewable energy relate to solar and wind energy generation with a primary purpose of exporting to the grid. It can also include other related renewable energy infrastructure like hydrogen generation and battery storage.
KCC commissioned research and modelling from Anthesis as part of the Business Energy and Industrial Strategy project, to provide regional and local projections for emissions reduction pathways to net zero emissions.
The hierarchy of actions used by the Anthesis SCATTER models is based on an established supply-demand balance method in accordance with national strategies to reach net zero emissions: reducing the need for fossil-fuel energy, switching to electricity as the principal transmission of energy, decarbonising the electricity production and offsetting any remaining carbon emissions.
The Anthesis projections need a large and rapid increase in electricity from wind power. Canterbury district has a high wind energy potential, and with year-round generation, the largest share of the renewable energy mix is projected to be from wind power.
The potential for solar photovoltaic generation in Canterbury district is also high. The increasing annual sunshine provides a large energy yield that can be harnessed through a broad combination of rooftop solar on both domestic and commercial buildings, canopies on car parks, some open spaces and in agriculture that can provide co-benefits of shade and rainwater collection and some large-scale solar operations.
The new Local Plan will need to consider how onshore wind generation can be delivered in order to meet carbon emissions reduction goals.
Stakeholders were supportive of developing renewable energy in the district to combat climate change.
Issue HNC15. How can we enhance the production of community and utility scale renewable energy?
Option HNC15A – continue with the current approach to renewable and low carbon energy production development
This option would continue to encourage proposals for the utilisation, distribution and development of renewable and low-carbon sources of energy, including freestanding installations in the appropriate locations as long as they show overall need.
Option HNC15B – (preferred option) actively support renewable or low carbon energy by removing the requirement for applicants to show need, and map areas for prioritising community and utility scale renewable energy projects
This option would remove the requirement for applicants to show the overall need for renewable or low carbon energy, recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions, and approve the application if its impacts are (or can be made) acceptable.
This option could also provide a map to show where community and utility scale renewable energy projects – wind and solar generation with associated infrastructure – are particularly needed to meet the district’s energy needs and contribution to net zero emissions.
This mapping would need to take into account things like closeness to other development, closeness to district power infrastructure, and any heritage or other relevant land use considerations.
Making sure that infrastructure is delivered at the right time to support development
Pressures on existing infrastructure can be made worse by new development, and this is a particular issue if the delivery of new infrastructure does not happen at the right time.
This additional pressure can lead to infrastructure being stretched, which in turn can impact people’s daily lives; for example, if roads become congested or GP waiting times increase.
The new Local Plan will need to make enough provision for transport, telecoms, waste, water; and community facilities like health, education and cultural infrastructure.
We also need to set out infrastructure contributions expected from development and show that necessary infrastructure will be delivered at the right time to support growth.
Normally the provision of infrastructure as part of a development, or the timing of financial contributions towards infrastructure, is planned to take place in time to serve the additional need created by the development. For example, a capacity increase at a school may be planned at the same time that a substantial amount of houses in a new housing development are occupied.
The government is increasingly advocating a move towards infrastructure being delivered up front, although some of the key mechanisms for delivering this remain under development. KCC also champion this ‘infrastructure first’ approach, and promote the creation of appropriate infrastructure to be delivered ahead of housing growth where necessary.
There was a strong, consistent message that infrastructure needs to be planned effectively alongside housing and economic growth. It should be provided early on in the development, even if temporary. This is especially important for roads.
KCC also strongly supports an infrastructure first approach to development, and believes that this approach leads to the most successful, sustainable communities.
The way in which the viability of developments can be impacted by the requirement and timing of financial contributions towards infrastructure also emerged from the consultation as a concern.
Infrastructure delivery and a shift towards a more infrastructure-first approach would therefore need to be considered with the overall viability of delivering growth.
Issue HNC16. How can we make sure that infrastructure is delivered at the right time to support development?
Option HNC16A – continue current approach to infrastructure delivery
The current Local Plan does not contain a policy which sets out when infrastructure should be provided to best support development.
Instead, the timing of infrastructure provision is negotiated at the planning application stage. Although this approach provides flexibility at the point of decisions, it can be difficult to secure the delivery of infrastructure at the right time in some cases; for example where there might be viability issues.
Option HNC16B – set clear requirements that necessary infrastructure must be provided at the right time to address the impacts of development
This option would set out a clear policy requirement that infrastructure improvements or contributions towards infrastructure must be delivered at the time it is needed to serve development.
Developments would need to show either that existing infrastructure has enough capacity, or that their development will provide enough capacity at the time it is needed to mitigate any pressures created.
Option HNC16C (preferred option) – set clear requirements for necessary infrastructure to provided at the right time and explore opportunities to deliver critical infrastructure ahead of development
This option would build on Option HNC15B by promoting an ‘infrastructure first’ or infrastructure-led approach to the delivery of critical infrastructure.
Working with infrastructure providers, developers and national and regional agencies, we would explore opportunities and mechanisms to deliver key priority infrastructure projects like major transport schemes ahead of housing growth in an area or ahead of development being occupied.
Addressing changes in development viability at the planning application stage
Viability is central in plan making and decision taking. We need to show that the plan is deliverable; in other words, we need to show that the combined costs of developments (like land, materials and infrastructure) do not exceed the total value of the scheme. If we don’t get this balance right, sites we identify may not be developed as intended.
The Community Infrastructure Levy (CIL) Viability Study completed in 2018 showed that various development types like housing, hotels and student accommodation, had enough headroom to remain viable when charged through the CIL. This is useful context, as it shows that development viability is generally positive in our district, which can support future growth and the delivery of infrastructure and affordable housing.
Going forward, we will need to set out the contributions expected from development, like the level of affordable housing and what infrastructure will be needed to support new development sites.
New national planning guidance on viability looks to put the viability assessment of development sites to the Local Plan stage first, to provide more certainty to developers, stakeholders and the community about how identified sites will be delivered.
We will assess the viability of the whole plan at the next stage of the process, to show that it is deliverable. These parameters will then be fixed and should not need further assessment at the planning application stage.
Several concerns were raised about viability issues impacting on the quality of new developments, as well as the ability for them to go ahead.
There was specific concern about developers being able to renegotiate a scheme at application stage, which can lead to less affordable housing being achieved than was originally expected, for example.
A move towards putting the development viability assessments first by completing them at plan making stage instead of planning application stage is required by the new national planning guidance, and also saw support in the consultations and conferences.
Other responses suggested that we tackle viability issues by exploring how we can receive more grants from central government or other grant funding bodies.
Issue HNC17. How should we address changes in development viability at the planning application stage?
Option HNC17A – continue current approach to accepting viability assessments
We currently accept viability assessments at planning stage but encourage them to be submitted at pre-application stage if there are any early concerns about viability, to prevent potentially long delays created by a review of viability at the planning approval stage.
Option HNC17B – no new viability evidence is accepted at planning application stage
This option would see no new viability evidence accepted at the planning application stage, on the basis that potential risks to developers are already accounted for in the Local Plan’s viability assessment assumptions.
Although this would set out a very clear position, important values like build costs or sales values do change over time, so this might cause deliverability issues to some sites over the period of the new Local Plan to 2040.
Option HNC17C (preferred option) – set clear and limited criteria where new viability evidence is accepted at planning application stage
This option would severely scale back the circumstances where new viability evidence is accepted at the planning application stage, on the basis that key values and expectations are fixed through the Local Plan.
For example, some factors like land values and developer profits would be non-negotiable, but other factors like build costs or house price values might have changed and could be open to review at the application stage.
Reflecting the national guidance, any new viability evidence would need to show the extent to which the specific values applied in the Local Plan viability assessment have changed.