Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Safeguarding places for Wildlife and Nature Blue Green Infrastructure and the Natural Environment Policy 6 - Safeguarding Places for Wildlife and Nature [View all comments on this section]
Comment ID DLPP713
Respondent KSL Planning ID-2905 [View all comments by this respondent]
Response Date 18 Sep 2018
Current Status Accepted

Sevenoaks District Council Regulation 18 Consultation - Draft Local Plan
Thank you for consulting us on the above. We have reviewed the draft Local Plan (LP), and
find that as it stands, this draft is “unsound” as it fails to address the following issues:
 New developments leading to net gain in wildlife value, as stated in the National
Planning Policy Framework (NPPF), paragraph 170.
 The requirements of the Water Framework Directive - Thames River Basin
Management Plan.
Please see further details on this and other issues below.
Fisheries, Biodiversity and Geomorphology
Policy 6 New Development
The plan should state that new developments must lead to a net gain in wildlife value. No net
loss is not an acceptable proposal, and is not in line with the latest national planning guidance.
The examples given for including biodiversity on sites are not sufficient to offset losses and
therefore the text is not clear enough that there must be a net gain.
In accordance with the requirements of the Water Framework Directive and that of the Thames
River Basin Management Plan, the LP should categorically state that development proposals
must not deteriorate watercourses and should actively enhance the natural functioning, habitat
and protection of watercourses wherever feasible. This should include providing adequate
natural buffers to watercourses to prevent damage, reinstating natural buffers where this has
previously been lost and unculverting piped watercourses, and restoring damaged
Any necessary access points should utilise clear spanning bridges where possible to allow
natural river processes and wildlife to continue to utilise the river corridor.
We would expect using more specific policy guidance in the LP for the Rivers Darent and Eden
(and tributaries) to provide deliverable actions for these catchments. This approach has
successfully been adopted in urban authorities to provide clearer expectations.
Local Allocations
Masterplanning should be more specific, particularly if an initial appraisal of the ecological
value had already been carried out. For larger greenfield development sites it would be helpful
to have more baseline information, which is currently lacking in the draft plan. Where estimated
housing quotas have been provided, there is no clear estimation of land required for green
infrastructure in order to achieve a net gain for biodiversity.
Rather than stating ‘opportunities for biodiversity enhancement’, we would expect specifying
a minimum amount of habitat and habitat type that should be delivered. This way, the LP will quantify how much net gain the development plan will aim to achieve over the plan period. At
present it is not clear how much net gain will be achieved in habitat area (although biodiversity
net gain is more than just habitat area)

Flood Risk
The Flood Risk Policy outlined in the LP: "Residential development must avoid, and non
residential development should avoid, areas at risk of flooding and no development should
take place in Flood Zones 2 and 3 without agreement from the Environment Agency." is
satisfactory and will help to ensure that flood risk is not made worse.
There were no specific areas identified that we have major concerns about so long as the
standard consultation process with the Environment Agency is undertaken for sites within
Flood Zones 2 and 3.
Groundwater and Contaminated Land
We have no detailed comments in relation to groundwater protection and contaminated land
to make in reference to the LP. We would recommend that site allocations on land with
previous use will need to address potential contamination issues by adequate investigation
and risk assessment.
Detailed comments on any specific site will be provided at the planning application stage, to
ensure adequate investigation and if necessary remediation is carried out to address any
identified contamination and risks to controlled waters.

Any new proposals should ensure that sustainable drainage design will achieve appropriate
protection of groundwater. In the case of limited mains sewer provision, we would object to
major development sites that do not tie into upgrade of sewer capacity in the area. This is for
the LPA and utility company to manage in terms of timing for release of permissions for sites
being developed.