Sevenoaks: the sites that could be taking a housing hit

Planners at Sevenoaks District Council have revealed the Green Belt sites they have identified for major housing development – greenfield sites with no development at present.
They are satisfied there are “exceptional circumstances” to justify changing the Green Belt boundary for these cases, their verdict coming after this summer’s consultation on the district’s draft Local Plan.
If the proposals are approved by cabinet on Thursday (December 6) they will be included in the final consultation on the Plan (the Regulation 19 stage) before it goes to public inquiry in the spring.
The government’s Objectively Assessed Need formula has arrived at a figure of 13,960 properties to be built in Sevenoaks district from 2015-2035. Sites on previously developed land (PDL) are expected to take some 6,000 properties.
At the Draft Plan consultation stage (Regulation 18), 12 ‘exceptional circumstances’ Green Belt sites were proposed for potential development. Of those, the following are being taken forward to consultation:

• Four Elms Road, Edenbridge (350 units)
• Sevenoaks Quarry (600 units)
• East of London Road, Dunton Green (240 units)

In addition, Pedham Place, land in the AONB near Swanley, is identified as a “broad location for development” for 2,500 houses.
At the Planning Advisory Committee meeting on Thursday, November 22, councillors voiced strong objection to the site, but a motion to exclude it was lost by a 5-6 margin.
Further consideration will be given to the release of this site from the Green Belt when the Plan is reviewed in the mid-2020s.
The local authority received 8,500 comments on the draft Plan from some 6,000 representors, including CPRE’s Sevenoaks committee, the majority objecting to the allocation of these ‘exceptional circumstances’ greenfield sites in the Green Belt.
Nigel Britten, the chairman, said: “Justification for making changes to the Green Belt boundary now is justification for making more changes in the future.
“But the Green Belt and the two Areas of Outstanding Natural Beauty are what define the special quality of the Sevenoaks countryside and we will do our utmost to protect it.”
The council received additional site submissions for greenfield Green Belt sites during the draft Plan consultation. The following are considered potentially suitable for inclusion in the Local Plan and will be consulted on alongside the Regulation 19 consultation:

• South of Redhill Road, New Ash Green
• Between Hartfield Road and Hever Road, Edenbridge
• West of Childsbridge Lane and south of the recreation ground, Kemsing
• North and south of Kemsing station

The Regulation 19 version of the Plan will include the associated Supplementary Planning Documents – Affordable Housing SPD, Development in the Green Belt SPD and Design Review Panel SPD.
The council will ultimately publish the Regulation 19 version on the basis that it considers it to be sound, legally compliant and prepared in accordance with the ‘duty to cooperate’ with neighbouring planning authorities.
Prior to the submission of the Plan for examination, the council will prepare an Issues Paper to demonstrate that an appropriate approach has been taken with regard to density.
It must also show the supply of housing sites is deliverable (for the first five years of the Plan) and developable (years 6-10). Further, it must provide evidence that all non-Green Belt sites have been fully explored before going through a peer review process with the Planning Inspectorate.
It is anticipated public consultation on the pre-submission version of the Plan will take place from Tuesday, December 18, to Sunday, February 3, followed by submission and examination in the spring or summer of next year, with adoption by the end of 2019.

• For more on this story, see here
• To read the papers for the cabinet, see here
• To track the changes being made to the Local Plan, visit Appendix 5 of the Cabinet papers here

Monday, December 3, 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