Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Providing for Housing Choices Gypsies & Travellers Policy 11: Provision for the Gypsy and Traveller Community [View all comments on this section]
Comment ID DLPP603
Respondent Kent Downs AONB Unit (Katie Mi… [View all comments by this respondent]
Response Date 11 Sep 2018
Current Status Accepted
Response Type OBSERVATIONS
Comment

While reference to development being required to minimise the potential impacts on surround landscape,
including AONBs in the policy wording is welcomed, this falls someway short of meeting the statutory
requirement of requiring proposals to ‘conserve and enhance’ AONBs. Development in AONBs needs to be
of the highest quality and maintain the local character, qualities and distinctiveness of the AONB, in line
with AONB Management Plan policies SD1, SD2 and SD9. The nature of gypsy sites means they will often
be inappropriate development within an AONB; we would like to see a requirement for any sites that are
located within the AONB to be required to meet the key test of conserving and enhancing the AONB.
We query the proposed strategy to include ‘existing temporary pitches on suitable sites that can be made
permanent’. The fact a site has temporary permission should not influence its inclusion as an allocated site;
the assessment of suitability should be made on the basis of a new site in the condition the site was prior to
its occupation by gypsies/travellers.
The Planning Policy for Traveller Sites, August 2015 confirms that local plans must be consistent with
policies in the NPPF, including the presumption in favour of sustainable development and the application of
specific policies in the Framework. This means that paragraph 172 of the revised NPPF is relevant.
GT2 – Early Autumn, East Hill, Shoreham
The site has been established as a gypsy site for a significant period and is located within a locality where
there is a dispersed settlement pattern. It is well screened and has limited impact on the landscape.
GT3 – St Georges Stable, Shoreham
The establishment of a gypsy site in this location is considered wholly inappropriate. The site comprises
open countryside, unrelated to existing settlement pattern in an unsustainable location. While the mobile
home is relatively well contained in the wider landscape as a result of topography and vegetative screening,
the presence of occupation of the site is nevertheless apparent, including as a result of entrance gates of an
inappropriate design. We note that a previous appeal on this site for a gypsy site was dismissed on the
grounds of harm to the AONB and Green Belt. While we note a temporary permission has subsequently
been granted by Sevenoaks District Council for a single plot, we do not consider that this is justification for
allocating the site thereby resulting in the permanent stationing of a gypsy site in this inappropriate
location, that would neither conserve nor enhance the Kent Downs AONB.
GT8 – Knatts Valley Caravan Park, West Kingsdown
This site is located on the Knatts Valley Road in an area of established ribbon development and the site of
the proposed allocation has been used as a caravan site since the 1960s, before the AONB was designated.
The caravans extend in some depth from the road on rising ground up the valley side meaning they are
more prominent in views from the road and the site has become more formalised in recent years, with
large areas of the site now comprising hard standing. In order to help mitigate impacts on the AONB, if the
site is allocated we would like to see a requirement for tree planting within the site to help filter views of
the caravans.
GT9 – Hollywood Gardens, School Lane, West Kingsdown
This site is located in amongst existing residential development and is relatively well contained in the wider
landscape, however the mobile home is visible from School Lane. School Lane has a heavily treed character

and in the venet of the site being allocated, we consider that the site would benefit from the planting of a
tree(s) that can established a large crown in the grassed area at the entrance to the site to help mitigate
the impacts on the AONB and be in keeping with the established character of the area.
GT10 – Two Barns, Knatts lane, West Kingsdown
Whilst there is a dispersed settlement pattern in this locality, the proposed allocation is located some
distance away from the rural lane network in the open countryside and on the side of a valley. A gypsy site
in this location would fail to reflect local settlement pattern and would not conserve nor enhance the
AONB. The LCA undertaken by Sevenoaks District Council places this site in the 3b ‘East Hill Wooded
Downs’ Landscape Character Area of the Sevenoaks LCA where suburban land uses are noted to detract
from the condition of the rural landscape. Local objectives for this area include enhancing local vernacular
built form and respecting the special qualities of the Kent Downs AONB. The proposed allocation would not
comply with the objectives. The AONB Unit objects to this allocation.


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