Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Policy 1 - A Balanced Strategy For Growth in a Constrained District [View all comments on this section]
Comment ID DLPP1112
Respondent Maidstone Borough Council (Ann… [View all comments by this respondent]
Response Date 28 Sep 2018
Current Status Accepted
Response Type OBSERVATIONS
Comment

Thank you for consulting Maidstone Borough Council on the Sevenoaks District Draft Local
Plan Consultation July 2018. The response has been agreed by the council’s Strategic
Planning, Sustainability and Transportation Committee at its meeting on 11th September
2018.


Housing
Based on the standardised methodology, Sevenoaks District has an OAN of 13,960 over the
plan period (2015-2035). Policy 1 – A Balanced Strategy For Growth in a Constrained District
and supporting text outlines that development will be focused within existing settlements,
including building at higher density on non-Green Belt Land; the re-use of previously
development land, including land in the Green Belt, where situated in sustainable locations,
will be encouraged; and development will be permitted on greenfield sites in the Green Belt
only in exceptional circumstances, in the most sustainable locations where employment, key
services and facilities and a range of transport options are or will be available.


The Sevenoaks Local Plan indicates that, when looking at the potential Green Belt
amendment, the Council has looked at the direction of growth from the four main settlements
of Sevenoaks, Swanley, Edenbridge and Westerham. The Sevenoaks Local Plan states that,
based on this consideration of ‘directions of growth’ and land availability, through sites that
have been submitted through the ‘call for sites’, exceptional circumstance sites are under
consideration. Under the NPPF the Green Belt boundary can only be amended in exceptional
circumstances. MBC note that exceptional circumstances have been locally defined as, in
addition to housing, providing social and community infrastructure which meets an evidenced
need.


It is observed that the assessment of the exceptional circumstance sites is ongoing and at
this stage it is unknown which sites will be taken forward to the final draft of the Local Plan. If
all of the sites identified as exceptional circumstances come forward for development it would
create 6,800 dwellings, a significant contribution to the District’s need. It would mean a total
of 13,382 dwellings would be delivered. Therefore, Sevenoaks District would still fall short of
the 13,960 OAN figure.

The new NPPF (paragraph 136) indicates that Green Belt boundaries should only be altered
where exceptional circumstances are fully evidenced and justified. The Council should be able
to demonstrate that it has examined fully the use of suitable brownfield sites and
underutilised land, as well as optimising the density of development in line with Chapter 11 of
the NPPF (paragraph 137). As the current strategy for housing delivery does not meet the
OAN, it would be appropriate to look again at sites in line with paragraph 137. Furthermore, it
would not be unreasonable for the Council to release more Green Belt land in order to meet
the housing need. Sevenoaks would not be the only authority to release green belt land,
Tonbridge and Malling are proposing Green Belt release to meet its OAN.


MBC notes that the Sevenoaks District Council Green Belt Assessment (2017) reviews the
performance of a total of 101 Green Belt areas against the five purposes of Green Belt. In
total, 31 sub-areas have been identified as performing weakly and therefore suitable for
further consideration known as ‘recommended areas’. These recommended areas are all
adjacent to settlements in the Sevenoaks Settlement Hierarchy. As such, these areas could
be sustainable locations for growth and should be fully explored. MBC reiterates its comments
made to the Issues and Options Consultation in July 2017 – further assessment of the sub
areas could reveal additional, smaller parcels of land which perform weakly, or not at all,
against the Green Belt functions. It appears that this further review has not been undertaken.
Considering there remains a shortfall, such additional review would appear justified.


Policy 1 outlines that discussions with neighbouring authorities, about whether they can
accommodate some of the identified need, will continue. MBC acknowledges that there is a
Statement of Common Ground between Maidstone Borough Council and Sevenoaks District
Council (November 2016). The Statement of Common ground noted that the Council was
unable to confirm if its OAN would be met within the District at the time. The Sevenoaks
District Local Plan has since progressed and there is a clearer position on whether the OAN
can be met in full within the District. As the Local Plan shows SDC cannot meet its need in
full, MBC would expect discussions to take place with neighbouring authorities as a priority.
Sevenoaks District has strong functional links with its neighbours which is evidenced by the
fact that it shares a housing market area, travel to work area and functional economic market
area with them.

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