Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Supporting a Vibrant and Balanced Economy Visitor Economy Policy 14 - Town and Local Centres [View all comments on this section]
Comment ID DLPP914
Respondent Seal Parish Council (Tim Marti… [View all comments by this respondent]
Response Date 06 Sep 2018
Current Status Accepted

Retail Guidelines

The guidelines are for an additional 10,400sqm convenience and 21,700sqm comparison floorspace (para. 6.16). The Plan should explain what this means for development; for example a large out of centre food store or DIY store would be approximately 5,000sqm.

Proposed Retail centre allocations para. 6.17

Otford Road Retail Areas (North and South) and the Polhill Garden Centre

Seal Parish Council objects to the allocation of the Otford Road Retail Areas (North and South) and the Polhill Garden Centre as ‘Neighbourhood Centres’. They should be designated in the local plan as ‘out-of-centre retail locations’ which serve a wide area, and should not be confused with neighbourhood centres serving a local community.

The NPPF states that the sequential approach to the location of town centre uses "should not be applied to applications for small scale rural offices or other small scale rural development". Large out of centre retail locations and neighbourhood/village centres should be clearly differentiated in the local plan’s policies.

Policy 14 - Town and Local Centres

It is unlikely that the same distribution for food and non-food space will be appropriate. Given the need to find employment and housing land, the constraint of the Green Belt and traffic pressure on the A25, out of centre sites should not be allocated or permitted at Sevenoaks for retail use. Retail use should be discouraged from encroaching further onto existing employment sites. Sevenoaks District as a whole is a very accessible location and policy should discourage opportunist development outside town centres to take advantage of the accessibility offered by M25, M26 and A21.

The NPPF (2018) at paragraph 85 provides a sequence for the location of retail and other town centre development that should be followed by local plans:

‘e) where suitable and viable town centre sites are not available … allocate appropriate edge of centre sites... If sufficient edge of centre sites cannot be identified, policies should explain how identified needs can be met in other accessible locations that are well connected to the town centre’.

The draft Plan does not explain whether town centre or edge of centre sites (or local centres) could accommodate the guidelines for additional retail space. Policy 14 says only that ‘The distribution of additional retail floorspace … will be allocated according to the most sustainable locations as defined by the Settlement Hierarchy and Retail Study.’

Clear guidance is needed in the local plan for the location of major new retail provision. By far the largest concentration of potential residential sites is in the Swanley area and the largest retail provision should also be there, especially since Swanley and nearby settlements are less well provided than Sevenoaks, which has six food stores operated by national retailers (one under construction) and a variety of comparison shops and retail warehouses. Sevenoaks also has serious congestion to the north of the town on A25 and its junctions due in part to the concentration of out of centre retail in that area.

Accordingly the first sentence of Policy 14 should be amended to provide guidance for the location of major new retail floorspace as follows:

"Additional retail floorspace will be concentrated at the most accessible town centres in the Settlement Hierarchy, being the Principal Town of Sevenoaks and the Towns of Swanley, Edenbridge & Westerham. Its location will also have regard to existing retail provision, new housing, the capacity of the town centres (including edge of centre sites), and whether, if required, accessible out of centre locations exist. Proposals will encourage the reuse of existing retail units, where appropriate, to ensure active frontages.

The Council will not permit major new out of centre convenience or comparison goods retail development at Sevenoaks, where there is good existing provision. At Swanley major new retail provision is supported to meet the needs of new housing and the existing population."

Paragraphs 5 and 7 of Policy 14 deal with village and neighbourhood centres such as Seal. They should be combined as follows:

"Within village and neighbourhood centres a range of shops (A1 Class use) and facilities (A2, A3, A4 and A5) will be maintained to meet the day-to-day retail needs of the communities which they serve. Proposals to develop new retail provision in neighbourhood and village centres will be permitted, where the development is of a scale consistent with the existing character of the centre and does not undermine the balance of existing uses".

A new paragraph should be included in Policy 14 to deal with out of centre allocations as follows:

"The Local Plan allocates the Otford Road Retail Areas (North and South) and Polhill Garden Centre as ‘Out-of-Centre Retail Locations’ at Sevenoaks which serve a wide area. The Council will not permit the extension of these sites, but will support proposals to improve their access, design and viability, subject to an assessment of the impact on town and local centres.

Policy 14 Tourism and the Visitor Economy

Policy 14 has the title ‘Town and Local Centres’ but the 3rd section on ‘Tourism and the Visitor Economy’ includes development outside centres and in rural areas. The policy for tourism should be separate, and in supporting sustainable tourism should refer to the enhancement of the natural attraction of the District and projects such as the ‘Sevenoaks Greensand Commons’.

The first sentence of the 3rd section of Policy 14 should be amended as follows:

"Proposals to provide new sustainable tourism such as enhancement of the countryside, heritage assets and public access, and development including hotels …etc."