Sevenoaks District Draft Local Plan Consultation July 2018

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7 comments.

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RespondentResponse DateDetails
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Policy 2 - Housing and Mixed Use Site Allocations

  • Comment ID: DLPP1060
  • Status: Accepted
  • Response Type: Observations
It is assumed, though it is not entirely clear, that no housing supply from 'baseline' sites has been double counted into 'maximising supply' sites. It is not apparent why the Council is confident that legacy sites - i.e. previously allocated in the 2015 Allocations and Development Management Plan or which originate from the 2011 Core Strategy (or an even earlier Local Plan)) which have not yet been developed (and where it is reasonable to suppose it was in the land owner's interest to do so) -
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Policy 1 - A Balanced Strategy For Growth in a Constrained District

  • Comment ID: DLPP1065
  • Status: Accepted
  • Response Type: Observations
The Government is committed to "protecting Green Belt land" (NPPF chapter 13 and NPPF 133 and 134). So is the Council (see the Plan 'Vision' – 'people and housing' and Plan 'Foreword'). How this is to be achieved through decision-making (NPPF chapter 4) in response to "proposals affecting the Green Belt" (i.e. through the development management and planning application/appeal process) is articulated in NPPF 143 to 147 (and in the Plan's other policies including Policy 4 'development in the Green
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 Providing for Housing Choices Housing Density Policy 12 - Housing density

  • Comment ID: DLPP1061
  • Status: Accepted
  • Response Type: Observations
Policy 12 otherwise anticipates housing delivery (and thus the assumptions that have informed the Plan's delivery expectations – see 'Objectives' and current Local Plan 'successes') "at higher densities, on average", i.e. than even an average density of approximately 60 dph. But even Policy 12 recognises that this may not be realistic and anticipates (or at least provides scope for) a reduced density of development consistent with surrounding local character (it also does not provide a 'range' o
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 Ensuring new development respects local distinctiveness Outdoor Lighting Policy 15 - Design Principles

  • Comment ID: DLPP1062
  • Status: Accepted
  • Response Type: Observations
Policy 15 not only seeks to resist the loss of existing open spaces, including blue green infrastructure (Design Consideration 1 - Character) but also requires public and private spaces to be integrated into the design of new development (Design Consideration 6). This will act to limit increased density of development. Similarly, it has yet to be properly tested whether the Plan's expectations for increased housing density can also be reconciled with other policies of the Plan, but in particular
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 Providing for Housing Choices Housing Density Policy 12 - Housing density

  • Comment ID: DLPP1063
  • Status: Accepted
  • Response Type: Observations
In terms of housing delivery and irrespective of density, 23 of the proposed 28 'maximising supply' sites are less than 1 hectare in area (see enclosed housing site analysis spreadsheet). While the NPPF acknowledges the potential contribution of small and medium sites (NPPF 68 and as defined by NPPF 68(a)) the balance (82% small/medium sites) does not adequately reflect (absent any or all proposed 'exceptional circumstances' sites) the complimentary requirement of NPPF 72 for supply of large nu
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Policy 1 - A Balanced Strategy For Growth in a Constrained District

  • Comment ID: DLPP1064
  • Status: Accepted
  • Response Type: Observations
The Plan also seeks to "encourage the re-use of previously developed 'brownfield' land, including land in the Green Belt, where it is situated in sustainable locations." (Policy 1). The Plan incorporates "Previously Developed Land (PDL as defined within the NPPF) in the Greenbelt, provided it is situated in a sustainable location, close to services and facilities", though provides no definition of what 'close to' means (paragraph 1.9). It also relies on another separate definition of its own inv
Pro Vision (Robin Buchanan ID-5377) 27 Sep 2018

Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Policy 1 - A Balanced Strategy For Growth in a Constrained District

  • Comment ID: DLPP1059
  • Status: Accepted
  • Response Type: Observations
Housing Need The Council blames the Government for the Plan having to contemplate an unmet housing need of 13,960 new homes. However, the Council's own Strategic Housing Market Assessment 2015 had already established an unmet housing need of 12,400 new homes. This broad quantum of unmet housing need is not of the Government's making or fault. The District is 'subject to' designations of acknowledged planning significance but it is only "constrained" by these as a convenient reason or excuse, if