Sevenoaks draft Local Plan: a briefing and CPRE Kent observations

Sevenoaks District Council’s Local Plan strategy

The draft Local Plan (2015-35) sets out the council’s strategy of:

• providing 13,960 homes to meet its local housing need
• focusing growth at existing settlements and maximising supply (through increased density)
• redevelopment of previously developed land (and of locally-defined brownfield land in sustainable locations)
• development of greenfield Green Belt land only in exceptional circumstances, where social and community infrastructure is being proposed in addition to housing, which could help address evidenced infrastructure deficiencies in the local area

Locally-defined brownfield land
Sevenoaks District Council is seeking to introduce the concept of locally- defined brownfield land as a means of gleaning as many housing sites as possible to contribute towards the requirement of 13,960 homes.
This definition goes beyond the (Nationally Planning Policy Framework) NPPF definition of previously developed land (PDL) – and could have serious repercussions for other Kent Green Belt authorities.

Locally-defined exceptional circumstances
The council is also seeking to include a local definition of exceptional circumstances.
The draft NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified.
The council is exploring in its draft Local Plan whether its Green Belt boundaries should be altered to meet its housing need. Twelve exceptional-circumstances sites have been put forward for consideration.
The council acknowledges that Sevenoaks is a highly constrained district, with 93% being Green Belt and 60% (Area of Outstanding Natural Beauty) AONB.
It is explained at para 1.14 of the draft Plan that consultation is taking place on all these sites to receive stakeholder comments… and that the inclusion of these sites in this consultation does not guarantee their inclusion in the final draft Local Plan.
The table below lists the 12 exceptional-circumstances sites.

Location                               Policy            No. of units            Site area (hectares)

Sevenoaks
Sevenoaks Quarry                 MX43             600                            94

Land west of Chevening        MX49             26-30                        1.7
Road, Chipstead                    HO53

Land east of London             MX50             40                              8.5
Road, Dunton Green             HO70

Swanley
Land between Beechlea       MX54a/b         750                            39.5
Lane and Highlands Hill,      HO188
Swanley

Pedham Place, Swanley/      MX48             c2,500                       117.6
Farningham/Eynsford

Edenbridge
Land south and east of        HO189 &        515                             27.2
Four Elms Road or              HO190
———————————— MX25 &
———————————–  MX26
———————————— HO223

Land at Crouch House        MX51              250                             18.4
Road or                              HO158

Land at Breezehurst            MX10             450                             18
Farm

and
Land west of Romani          MX44             80                               6.7
Way

Westerham
Land north and east of        HO371 &       600                             21.8
Westerham                          HO372
————————————-HO373 &
———————————— HO374
———————————— EM17

Fawkham/Hartley
Corinthian and                     MX52 &         Corinthian 570        74.6
Banckside                            MX53             Banckside  230
———————————— HO162 &
———————————— HO163

Halstead/Pratt’s
Bottom
Broke Hill golf course        MX41             800                             60.2

Subtotal       6,800

CPRE Kent observations on the Sevenoaks Local Plan

In general, CPRE Kent supports a development strategy that meets the following criteria:

1. Prioritises the redevelopment of appropriate, sustainably-located previously-developed land. It does not support development on locally-defined brownfield land in unsustainable locations.
2. Does not lead to the loss of best and most versatile agricultural land, Green Belt, AONB and other designations.
3. Focuses growth at existing settlements and maximises supply through increased densities at sustainable locations.
4. Recognises the acute need for rural affordable housing.

CPRE Kent is concerned about the level of housing proposed. It is noted that the 2015 SHMA sets out objectively assessed need based on the Office for National Statistics (ONS) 2012-based sub-national population projections and 2012-based household projection figures.
These figures will need to be reviewed in light of the 2016 mid-year figures and the household projections (expected next month).
Following the decline in population (2012-2016), it would seem reasonable to assume that household projections will also be in decline. However, we wait with interest to see what the government’s stance on this will be.

CPRE Kent has serious reservations that the construction industry will be capable of delivering the proposed level of housing. Average housing completions for the district are noted as 250dpa (dwellings per annum) over the last 10 years. With the suggested local housing need of 13,960, this would rise to 698dpa.

CPRE Kent has serious reservations over the need to deliver homes in accordance with the standard methodology for calculating local housing need, for the following reasons:

1. The NPPF states that the government attaches great importance to the Green Belt – it states that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of Plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the Plan period”.
2. One of the Green Belt purposes is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Resisting development in the Green Belt will help encourage the bringing forward of previously developed land in the urban area.
3. New housing in the Green Belt is likely to be for large properties that won’t meet the demand of local people who genuinely require housing in the villages and settlements within, or washed over, the Green Belt.

CPRE Kent does not consider that allocating land to meet local housing need with the promise of social and community infrastructure sufficiently demonstrates exceptional circumstances.
CPRE Kent is concerned that the harm caused to the purposes of the Green Belt designation and other considerations would not be outweighed by the requirements of the local housing need requirement.

Wednesday, August 22, 2018 

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document