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 DLPP1122
Respondent Montreal Park Residents' Assoc… [View all comments by this respondent]
Response Date 01 Oct 2018
Current Status Accepted

Suggest amending wording of Policy 1 in five respects:

  1. Add the following words as a new sentence after the first sentence of Policy 1:  "Mixed use developments which intensify the use of land by incorporating housing will be supported and encouraged, particularly on sites that are close to services and facilities and/or well-connected by public transport, walking and cycling".   
  2. Add at end of first para a new sentence. “Development proposals for the four towns will be expected to comply with the proposals and priorities listed in the table in para.1.4.” This is essential to give teeth to the table and to ensure it genuinely represents “proposals” in the Local Plan.
  3. Delete second sentence in second para (“However…itself”), since this is “comment” rather than policy for a development plan.
  4. Delete the remainder of para 3 after ‘exceptional circumstances’. We believe it is a mistake for the policy statement to go beyond stating that development will only be permitted in exceptional circumstances. Trying to define the conditions under which such development would be acceptable merely weakens the commitment to protecting the Green Belt. It opens the door for developers to argue that their developments meet the requirements for sustainable development and should therefore be permitted whether or not the circumstances are exceptional.
  5. Delete fourth para (which in any case contains a superfluous “about”), since this is mere statement of intention, not development plan policy, and is repetitive of what is contained in para 1.8.

Para 1.4 The table of “proposals and priorities” in para 1.4 appears to replace the entirety of the section of the Issues and Options Consultation headed “Placemaking Areas”. However, there is no specific policy relating to it, hence the suggested amendment to Policy 1. Additionally in respect of the heading “Place-making” for the Sevenoaks Urban Area, we suggest:

  1. With respect to the second item, before “redevelopment of land east of the high street” is promoted, should not consideration be given to the minimal spare capacity at the High Street/Suffolk Way junction which appears to present an absolute bar to this suggestion?
  2. In the same item, there is a reference to “opportunity areas”. Should not this phrase be defined in the Glossary?
  3. In the same item, should not there be a specific reference to “vacant and/or undeveloped sites where there is a need to ensure prompt redevelopment”, perhaps specifically naming the Farmers site and the Edwards Electrical sites?
  4. In the same item, we suggest rewording the final phrase to read: “retail, high density housing and community uses”, because there is a real need for more housing in Sevenoaks, whereas the estimates of demand for additional retail space are highly uncertain given the changes which are taking place nationally in high street retail spending.. Our approach is consistent with the wording of the final sentence of the second para of Policy 14.
  5. The fourth item “Promote…town centre” is poorly worded. Is it intended to “promote [both] increased density and [increased] quality” or simply both “increased density” and “quality”? Assuming the latter, it would be better to change the wording to “Promote quality and increased density of development…”
  6. In the same item, “gateway locations” appears to be defined by reference to “train stations” and “town centre”. Whilst both railway stations in Sevenoaks could be regarded as “gateway locations”, it is hard to see how the “town centre” is a gateway location itself. Suggest amend to read: “…at gateway locations, such as train stations, and in the town centre”.
  7. We suggest adding a fifth item: “Undertaking, and keeping up to date, a comprehensive traffic and transport study of the town centre, looking particularly at the impact of development on the Tarmac site, the growth of the Wildernesse education campus, the overall growth in household numbers, the question of improving access to Knole House and Park, changing demands for parking and ways of improving the pedestrian environment in the town centre.” We believe that this is particularly important if the town centre is to maintain its vitality at a time when high street retailing is coming under increasing pressure.

Para 1.8 This refers to the discussions between the Council and neighbouring authorites.  The Plan should take into account major regeneration schemes in adjoining districts, such as Ebbsfleet Garden City and others planned for the Thames Estuary which aim to deliver tens of thousands of new homes close to the Sevenoaks District and clarify the extent to which those proposals could meet some of the housing demand within the District. 

Para 1.10

  1. Either delete ‘evidenced’ in para 1.10 or provide somewhere an explanation of how infrastructure needs are to be ‘evidenced’.
  1. 2) To avoid confusion, repeat the point that any social and community infrastructure should be in addition to housing at the end of this para by adding “in addition to housing” at the end of the last sentence.       Since the principal need is for “social rented housing” as defined in the Glossary, we suggest that in para 1.10 “affordable homes” should read “affordable homes, including particularly social rented housing”.
  3. The draft should make it clear that the definition of “exceptional circumstances” justifying building on greenfield sites in Green Belt means the provision of social and community infrastructure which is genuinely over and above infrastructure that a developer would be required to provide through s106 obligations etc. in any event such as highway alterations or the provision of other infrastructure to overcome planning objections and mitigate any adverse impacts of the underlying development proposal. Similarly, the underlying development proposal itself should be excluded from the definition (even where this is housing) as otherwise, this would be entirely circular and would defeat the purpose of the definition (unless the underlying development proposal itself is wholly non-commercial and purely of social or community benefit).
  5. The definition of “Exceptional circumstances (local) in the Glossary should be amended to read: “The Government does not define exceptional circumstances, but as part of the new Local Plan, it is suggested that this may occur, for example, where development ensures the delivery of new and needed key infrastructure (meaning infrastructure that is over and above that which the developer would be required to provide in any event in order to mitigate the impact of the development and other than housing) and which helps achieve significant compensatory improvements in the Green Belt”.