Sevenoaks District Draft Local Plan Consultation July 2018

Comment ID DLPP989
Document Section Draft Local Plan July 2018 Protecting, Conserving and Enhancing Green Belt, Landscape and the Natural Environment Landscape and Areas of Outstanding Natural Beauty (AONB) Policy 3 - Landscape and Areas of Outstanding Natural Beauty [View all comments on this section]
Respondent Jon Kirby ID-2728 [View all comments by this respondent]
Response Date 26 Sep 2018

Approximately 60% of Sevenoaks District is designated as an Area of Outstanding Natural Beauty (AONB).

Whilst the Council is committed to protecting this designation, any development proposed within an AONB

will need to protect and enhance the landscape. Whilst SKE support the need to protect land within the

AONB, they express serious concerns regarding the Council’s selection process of housing sites within the


5.2 Paragraph 5 of the Planning Practice Guidance document ‘Natural Environment’ states:

"Planning permission should be refused for major development in a National Park, the Broads or an Area of

Outstanding Natural Beauty except in exceptional circumstances and where it can be demonstrated to be

in the public interest."

5.3 The Town and Country Planning (Development Management Procedure)(England) Order 2015 defines major

development in relation to the provision of dwellinghouses where:

The number of dwellinghouses to be provided is 10 or more; or

The development is to be carried out on a site having an area of 0.5 ha or more.

5.4 A number of sites considered for allocation in the draft Local Plan constitute major development within an


Notwithstanding this, there is a lack of evidence to demonstrate the ‘exceptional circumstances’ under

which their potential allocation is justified. Additionally, the Council have not provided an explanation as to

why the development of these sites is in the public interest. Unless the Council provide this justification, there

is a risk the new Local Plan will be found unsound, as it will be in conflict with national planning policy.

5.6 Policy 3 of the draft Local Plan outlines that proposals within the Kent Downs and High Weald Areas of Outstanding Natural Beauty (AONB) and their settings must conserve and enhance the character of the landscape. Consideration must be given to the:

Scale and form of development;

Layout in relation to adjacent settlements and settlement patterns;

Impact on scenic beauty;

Use of materials and colours;

Rural economic impact; and

Historic use of buildings, site and surroundings.

5.7 A number of sites located in AONB propose high development densities of 40 dwellings per ha (dpa) or more, which may lead to significant adverse impacts on the setting and character of the AONB.

Notwithstanding this, none of the sites put forward have proposed suitable mitigation measures to justify

these densities.

5.8 The development of these sites will conflict with local and national planning policy, and may result in inappropriate development in AONB. In particular, it is not positively prepared or justified based upon

appropriate evidence or consideration of appropriate alternative sites.

Recommendations to ensure soundness

It is recommended that sites put forward for residential development in Areas of Outstanding Natural

Beauty should only be considered once all alternative options have been assessed, and their allocation

is justified as being in the public interest and accompanied by the appropriate mitigation measures.

This will help to ensure that the draft Local Plan is in line with national planning policy. The sites identified

in Table 5, therefore, should be omitted from the Local Plan and the land at London Road/School Lane

should be allocated for residential development.