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        Local Plan – frequently asked questions


        What has been published for comment?

        • the Publication draft Local Plan
        • the Sustainability Appraisal of the draft Local Plan
        • a draft Transport Strategy for the district that supports the Local Plan
        • a Landscape Character Assessment, which the Council intends to adopt as supplementary planning guidance (what is known as a Supplementary Planning Document or SPD)



        Where can I see and comment on the draft Plan?

        You can view the Publication draft Local Plan (and the other documents mentioned above) using this link:

        If you view the draft Local Plan at local libraries, you will need to look at the draft Local Plan document and the Local Plan Addendum.  The Addendum lists all the changes agreed by the Council in July 2018, and explains how they relate to the main Local Plan document.


        Where can I find the council’s supporting evidence?

        Our evidence base, including various studies, can be viewed here: Evidence Base

        Some of the studies supporting this consultation can also be found on the council’s consultation portal, and in local libraries.


        What communication has there been about the Publication stage?

        The following communications has being carried out to publicise the opportunity to comment during the Publication period:

        • Emails/letters to everyone on the council’s consultation mailing list, including all those who have previously made comments at earlier stages of the draft Plan
        • Public notice published two weeks running in local press
        • Adverts in local press – including the Thanet Extra; the Margate Mercury and the Isle of Thanet News website
        • Press release issued to key local media outlets – related articles have been published in the local press and on local news websites – circulation 36,000 (108,000 opportunities to see)
        • Council’s Facebook post reached over 16,000 people, with nearly 1,300 click-throughs (13 Sept 2018)
        • Council’s Twitter post sent to over 7,000 followers; seen by just under 1,400 people (13 Sept 2018)

        Why do we need a Local Plan?

        The plan shapes how Thanet will develop to 2031 and sets out how much development is needed to support the future population and economy. The Local Plan will give Thanet District Council greater control over where and what type of new developments can take place.  It also helps to provide certainty for local people, developers and investors.

        The plan must be based on evidence from a number of studies covering a wide range of subjects and take account of national policy.


        What are the main changes since the Council decided not to publish a draft Local Plan in January this year?

        There are a number of key changes:

        1. Manston Airport is no longer allocated for mixed-use development – there is no specific allocation for the site, but the Council recognises the Development Consent Order process for continued aviation use at the Airport, and does not wish to prejudice that process;
        2. As a result of the decision on the Airport, the Council has had to identify alternative sites to meet the housing provision (2,500 dwellings) that had previously been accommodated on the Airport site. These are:
          • Birchington strategic allocation – increase allocation from 1,000 dwellings to 1,600 dwellings;
          • Westgate strategic allocation – increase allocation from 1,000 dwellings to 2,000 dwellings;
          • Manston Court Road/Haine Road, Westwood – increase housing allocation from 700 dwellings to 1,200 dwellings;
          • Hartsdown/Shottendane Road, Margate – new site allocation for 300 dwellings; and
          • Tothill Street, Minster – increase housing allocation from 150 dwellings to 250 dwellings;

        3. In response to concerns from partner organisations, a new policy has been developed to prevent the provision of new fostering homes in the Cliftonville West Ward;

        4. A number of new Local Green Spaces are proposed for designation in Westgate.


        What is this stage of the Local Plan process?

        This stage of the process is known as Publication stage (Reg 19).  It is the last formal stage before an independent Examination of the draft Plan is carried out by Planning Inspectors.  It gives people the opportunity to make formal comments on any part of the draft Plan, and comments will be forwarded by the Council to the Planning Inspector to be considered.

        Comments made about previous drafts of the Local Plan will not be considered by the Inspector.  If you want your comments to be considered as part of the Examination process, it is important that you make comments at this stage.


        What is “sound-ness”?

        An independent Planning Inspector looks at the draft Plan to make sure it is “sound”, which means:

        1. Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
        2. Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
        3. Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
        4. Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

        This means that the council must prepare a Plan that meets the development needs of the area; is based on evidence; is capable of being implemented and follows Government guidance.

        If you make comments on the draft Plan at this stage, it would be helpful if you can identify which of the above tests you are concerned about.  There are guidance notes available which explains the soundness tests and how to respond in more detail.


        When will we know more detail on layout of the developments?

        The Local Plan allocates land for potential development. The detail of what will be built will come at the planning application stage when a developer proposes a scheme. Their proposals will need to include the requirements of the relevant policy in the Local Plan. The council will consult with residents and other stakeholders on the planning application before it is decided.


        Why haven’t you taken my previous comments into account?

        The council does try to take people’s concerns into account in preparing the Local Plan.

        For example, at previous consultations, people have raised a lot of concerns about the provision of infrastructure – education, health, utilities, transport, etc. Although the council is not directly responsible for a lot of these matters, it has been working actively with the various service providers to try to ensure that the necessary services are provided alongside new development.

        However, like all planning authorities, the council is to some extent limited in terms of how its Plan can be framed. This is because it must follow national government guidance in order to ensure that the Local Plan is accepted through the independent Examination process (is found “sound” as mentioned above)

        So, for example, the overall housing numbers that the council needs to find are determined by a specific formula in national guidance, and it is expected that councils will prepare Plans that meet those housing requirements. This means that objections relating to housing numbers have to be considered in this context. It is not open to the council to simply ignore those housing numbers.



        What will happen if we don’t plan for more houses? Why can’t we just say no?

        If the council does not allocate land for houses, the draft Plan would be likely to be found “not sound”, which means that the council could not adopt it. Landowners/developers could then apply for planning permission to build houses anywhere and it would be difficult for the council to refuse those applications.


        How are housing numbers determined?

        There is a methodology set out in Government guidance, which councils have to follow to calculate their “objectively assessed need” for housing. This takes into account likely population change, any additional requirement arising from economic requirements, household size and other factors. Population projections are undertaken by the Office for National Statistics (ONS), and household projections by the Ministry for Housing, Communities & Local Government (MHCLG), and these form the basis for calculating the housing requirement.


        Why have housing numbers gone up to 17,140?

        In 2016, a new set of household projections were published by the government, which meant that the Council had to recalculate its housing requirement based on the new figures.


        What about Brexit? Won’t that reduce housing requirements?

        At this point, it is impossible to say what the impact of Brexit will be on housing numbers, as there are many factors to be considered. Once the Brexit process is finalised, we will be clearer about how housing figures might be affected. This would need to be addressed in a future review of the Local Plan.


        Who will be living in the houses once they are built? Could they be filled by people from outside the area?

        In this Local Plan, the council is not planning to meet the housing needs of other areas. However, it is not possible to be precise about how many residents of the new housing market will be Thanet residents. In terms of affordable housing, the council has a policy of requiring new development to provide 30% affordable housing. The council is able to nominate people for the affordable housing from its own housing register. In 2013, the council closed its housing register to people outside Thanet. The nominations are based on the council’s policy of prioritising people with a local connection of three years or more.


        Is the council allocating areas of precious, prime agricultural land for housing development that should be used for growing food?

        In developing the Local Plan we have allocated some 25% of new homes on previously-developed land.

        However this still leaves a shortfall in the amount of houses required, which means we have had to also look at allocating greenfield or undeveloped land for possible housing developments.


        Why has the council allocated more land at Birchington, Westgate and Margate?

        With the mixed-use allocation being removed from the Airport site, it was necessary to find alternative sites to provide the 2,500 dwellings previously proposed there. Of the available sites, these were considered the most suitable sites for additional new housing.


        Unemployment is high in Thanet, we need industry not houses, how will this be addressed?

        Government’s National Planning Policy Framework requires us to objectively assess future housing requirements and meet them. The level of provision in the draft Plan has been informed by a range of forecasts taking into account past trends and potential employment growth.

        The Plan also contains measures to accommodate employment growth. The council has recently adopted a new Economic Growth Strategy which will support this.

        A significant part of the future housing requirement relates to the needs of the District’s existing population, such as young people, who will come to need a home of their own.


        What is the council doing to stop Thanet being turned into a large housing estate?

        The Local Plan allows us to control where and how many houses are built in Thanet. Without the Local Plan it would be harder for us to prevent development in non-allocated areas.

        The Local Plan aims to safeguard the individual identity and essential separation of individual towns and villages.


        How will the council ensure that the new developments in rural areas do not result in existing villages losing their identity?

        The Local Plan includes further information about how we have decided on the development in rural areas.  The Draft Plan also includes policies to try to ensure that new development, wherever it is located, reflects the character of the area.


        What is the criteria used to identify/assess potential housing sites?

        A range of criteria is applied and these are identified in our Strategic Housing Land Availability Assessment report. The Sustainability Appraisal work identified as preferable locations the urban areas and urban edges and the larger villages with a good range of services. Other matters that have to be considered are areas at risk of flooding, archaeology and transport/access.


        What are the plans to improve infrastructure for the proposed housing sites ie: doctors, dentists, schools, roads etc?

        The council is working with the agencies responsible for delivering medical services, schools and transport infrastructure on an ongoing basis.

        The council has published a working draft Infrastructure Delivery Plan (IDP) as a background document to this consultation.

        The draft IDP covers a range of infrastructure (including transport; education; health and utilities), but a lot of work with key stakeholders and service providers is still ongoing to try to ensure that infrastructure is provided alongside new development.


        We bought a house recently, why didn’t the search pick the housing allocation up?

        The Local Plan is still only a draft so the sites which we propose for allocation will not yet show up on your search.


        Why can’t all the empty properties be used for new housing instead of finding new sites?

        The council works vigorously to bring empty property back into use, and has an active Empty Homes programme. The team was recently increased to try to achieve higher rates of empty property returns to use. The council can count some empty homes as part of the housing supply if:

        1. The properties in question have been empty for a period of four years or more. This is based on the position that over that period it can be argued that those properties have been vacant and unused for such a long period that they are no longer available in the housing market and therefore not part of the active housing stock; and
        2. The council has an active and robust programme for bringing those properties back into use.

        Manston Airport

        Why is the council not allocating the Airport for development when it is a brownfield site?

        The council commissioned Avia (an aviation consultancy) to produce a report on the financial feasibility of operating Manston Airport as a standalone entity. The report concluded that the reopening of an airport would be highly unlikely to be viable.

        However, the Council wants to allow the opportunity for the current Development Consent Order application (for continued aviation at Manston) to proceed, and for the Local Plan to reflect that process.



        Thanet is already a water stressed area – will there be enough water for all of these new houses?

        The council has been working with Southern Water to make sure that they provide water and sewage facilities for the predicted growth included in the draft Local Plan. We will continue to work with them throughout the process, and our draft Local Plan has informed their business plan so they can ensure our growth needs are met.

        The council is also proposing to implement higher water efficiency requirements in new development.



        Where are the new roads going to go?

        The draft Plan is not prescriptive about the specific location or alignment of a new road link, but it does show a general line for the new roads, under the New Strategic Routes Policy.

        This would be a matter to be considered when any planning application is received.


        When is this likely to happen if approved?

        Planning for this is still taking place and is included in the draft Infrastructure Delivery Plan.


        Roads are already at capacity. 17,000 households will add to the problem. What plans are there to deal with this?

        We have worked with KCC Highways to prepare a draft Transport Strategy, and this has been published alongside the draft Local Plan. A key element of the Strategy is the Inner Circuit, which seeks to relieve pressure on the existing road network. Detailed schemes will be drawn up at the planning applications stage and advice will be sought from KCC as the highways authority.



        Why are there 17,000 houses but only 5,000 proposed jobs? There is high unemployment here – won’t this make it worse?

        The level of housing proposed is 17,000 new homes over the 20 year period to 2031. Housing numbers are not determined by jobs numbers alone, and so there is not a direct relationship between homes and jobs. This figure takes account of both the homes needed to accommodate changes in the existing population together with some in migration, including homes for the additional labour force associated with the target of 5,000 additional jobs.

        Homes are required to reflect new households forming as younger people leave the family home (where some will already have jobs), people retiring to the area and people moving into the area (some of whom already have jobs).


        Where are these jobs coming from?

        Experian carried out employment forecasting for the council, a few years ago, and this was updated in 2016 using job projections from the EEFM, a well-known economic forecasting model. The report showed that there is already strong growth in the tourism and green sectors of the economy and this is likely to continue. Thanet is also strong in cultural, retail and public administration professions.

        Most of these jobs are likely to arise in smaller numbers across a large number of companies, rather than a lot of jobs in a small number of companies. The council has adopted a new Economic Growth Strategy which will support this.


        Why are you focussing retail development at Westwood?

        Thanet’s town centres all perform different and complementary functions and retail development is supported at all of them.  The draft Local Plan allows for some floorspace growth at each of the centres.

        The Local Plan does not propose to expand Westwood beyond its existing boundaries.  In fact, a recent assessment for the council shows that retail floorspace needs for the district are not projected to rise as much as previously expected.  No additional land at Westwood is being identified for new retail development.


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