Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Providing for Housing Choices Housing Density Policy 12 - Housing density [View all comments on this section]
Comment ID DLPP741
Respondent Strutt & Parker (Stuart Cricke… [View all comments by this respondent]
Response Date 10 Sep 2018
Current Status Accepted
Response Type OBSERVATIONS
Comment

2.27 Policy 12 seeks to deliver development at a density above 60 dwellings per hectare which

would represent an increase in the density of recent developments. The policy includes a

number of criteria that development would need to meet including:

Ensuring development is of a high quality of design and respects local character

Includes a mix of housing types and sizes that reflects identified needs

Is well served by public transport and local services and facilities

A case can be made to demonstrate that the area is able to accommodate

additional development.

2.28 Paragraph 122 and 123 of the NPPF concern the density of development. Paragraph 122

supports the provision of high density development provided local market conditions and

viability, amongst other matters, are considered. The wording of Draft Policy 12 currently

does not appear to refer to any viability matters which could affect the density of

development. We would recommend the wording is amended to reflect this element of

national planning policy.

2.29 Paragraph 123 applies where Local Planning Authorities considered there to be an existing

or anticipated shortage of land to meet housing needs and in such circumstances planning

policies should support higher density developments. The consultation document is

considered to be in accordance with the NPPF in this regard through the inclusion of a draft

policy concerning development density. However, Croudace are concerned that the whilst

the intention to achieve higher densities of development within the existing urban areas is

being proposed the Council need to be realistic. The higher densities being planned for

should be informed by clear assessment within the new plan¡¯s evidence base which

currently does not appear to have been presented. Moreover, Croudace suggest it would

be prudent for the Council to build-in to the new plan a fallback position that is capable of

achieving any shortfall where intended higher density sites are not achieved. One such

approach being to identify and allocate safeguarded sites for release in the event housing

needs are not being met.

2.30 We note that the draft policy as currently worded does not refer to the provision of minimum

densities for town centre locations or locations that are well served by public transport. It

is suggested that the draft policy is embellished with the inclusion of density standards for

sustainable urban locations and for other out of centre locations to ensure that the draft

plan is in accordance with the NPPF

 

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