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 DLPP1142
Respondent J Affleck ID-2174 [View all comments by this respondent]
Response Date 01 Oct 2018
Current Status Accepted

The Sevenoaks District has been told by the government to build 13,960 new homes by 2035. This number is far too high, and there is no explanation as to how it has been reached. As stated on pp 14 and 21 of the Draft Local Plan, this figure would require the building of 698 homes a year (i.e. 13,960 over 20 years), when over the past ten years 250 homes a year have been completed (i.e. 5,000 homes over 20 years).

We are told that the population of the District is expected to grow by more than 20,000 over the 2015-2035 period (page11). The current population is 118,409 (ONS estimate in 2015, page11), which would represent an increase in population of approximately 16.9 % in 20 years whereas the ONS figures for the UK are for an increase in population of around 12.1% in the 20 years from 2015-2035 (from 65.1 mill to 73.0 mill). This would suggest that the Sevenoaks District is being requested to cope with much more than it’s share of the estimated UK population growth.
There is no basis for believing that the local population will increase to the extent envisaged by the government, and the figure of 13,960 new homes imposed by the government should be challenged. This amount of development over such a short period of time could not be considered to be sustainable development. However, there is no doubt that the proportion of affordable homes should be increased.

National Planning policy sets out that the Council should aim to meet the ‘Local Housing Need’ figure provided by central government ‘unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits’ (p21). It seems clear that this is indeed the case, and could provide grounds for the Council to challenge the Government’s building requirements for this district.

As set out on p45, the general purpose of the Green Belt includes checking the unrestricted sprawl of built-up areas, preventing neighbouring towns from merging and safeguarding the countryside from encroachment.
Despite declaring (p22) that ‘we are committed to protecting the Green Belt’, a high proportion of the planned new homes (half or more – 6,800 units from EC sites (p35)) claim ‘Exceptional Circumstances’ to be built on Green Belt land. Claiming ‘Exceptional Circumstances’ for new developments seems to be becoming the norm, which goes against the stated wishes of local people, and those who set up the Green Belt. If this amount of destruction of the Green Belt is allowed to proceed, it would seem clear that any protection offered by Green Belt designation is meaningless, and the ‘Exceptional Circumstances’ let-out could be applied to any proposed development on the Green Belt.
We as a country and as a community cannot afford to lose agricultural and recreational land when it is likely that in a very uncertain future we will not be able to depend on importing the majority of our food supplies, as we do now.

For example, in Dunton Green, a village that has already nearly doubled in size from recent house-building, the proposal to use Exceptional Circumstances to build an additional 180-240 residential units on land to the rear of the village hall (Draft Local Plan Site Appraisal MX50), plus other potential plans for development in Dunton Green (HO262 (150-200 homes) and HO61 (22-30 residential homes)), will lead to precisely the kind of development which the Green Belt designation is designed to prevent – urban sprawl and ribbon development and the gradual merging of towns and villages, not to mention the increase in traffic congestion and accompanying air pollution in an area that already sees serious traffic congestion on the A224.

Similarly with the planned developments near Halstead, where approximately 800 new units planned for Broke Hill (MX41), a proposed development under Exceptional Circumstances in the Green Belt, and the Fort Halstead site, where up to 750 new units are planned, which will come close to merging the villages of Halstead, Pratts Bottom and Badgers Mount.

There is a fundamental contradiction between the amount of new building planned and the stated objectives of the Local Plan, as listed on p14. ‘Promoting a greener future’ and ‘promoting healthy living opportunities’ are not compatible with the proposed amount of new building: not only 13, 960 homes, but the roads and infrastructure that would accompany these, would inevitably lead to worsening traffic congestion and air pollution, which is already a problem in parts of the district.

Sevenoaks Wildlife Reserve, an SSSI, is a valuable space for wildlife, especially birdlife, enjoyed by many for its peace, tranquillity, beauty and nature. No developments should be permitted that threaten this unique and valued area. It is important that any further development of the former Park and Ride site off Otford Road (EM12), which is adjacent to designated SSSI land next to the Reserve, does not impact adversely on the Reserve, and other potential plans for development, such as those off the Bradbourne Vale Road, HO203, which would impinge on the Reserve, and HO259, (currently both are in the Orange Category: “Not currently for inclusion in this plan”), should not be permitted to go ahead in the future, as green areas adjacent to the Reserve act as important wildlife corridors and help to buffer the Reserve from other developments.

The A25 running through the district is an AQMA (Air Quality Management Area), but the Plan proposes large developments near to Riverhead (at Dunton Green) and Bat and Ball (600 new homes proposed for Sevenoaks Quarry), which will inevitably lead to even more traffic, congestion and air pollution at these busy road junctions. Nitrogen dioxide and particulate matter from road traffic are the main source of air pollution in the district. The severe and long-term damage to health caused by chronic exposure to poor air quality is increasingly being recognised. Apart from exacerbating respiratory diseases, ‘it is recognised as a contributing factor in the onset of heart disease and cancer’ (SDC 2017 Air Quality Annual Status Report).

The huge amount of new building that would take place under ‘Exceptional Circumstances’ on the Green Belt would mean the loss of agricultural land, loss of ‘green lungs’, countryside, recreational areas and wildlife habitats.

The loss of Sevenoaks Hospital (proposed to be replaced by 58-73 residential units), with all its facilities, would be a disaster for local people, and although the Plan states that ‘loss of health facilities will need to be addressed’, this does not provide any reassurance that the people of Sevenoaks and it’s surrounds will continue to have the good access to medical services it now has. (Draft Local Plan, Site Appraisal, 5.Yellow Category, HO365)

Interestingly, some of the proposals (EM6/EM23/EM24) cite Sevenoaks Hospital as being a nearby health centre – but another proposal (HO365) is for the hospital to be demolished and built on!

Similarly with the Adult Education Centre, proposed to be replaced by 18-22 residential units. The Plan says that ‘Adult education service is proposed to be provided elsewhere within the locality’ (Draft Local Plan, Site Appraisal, 5.Yellow Category, HO226) – but does not say where.

And the Sevenoaks Community Centre (MX29), where 20-25 residential units are proposed, is to be replaced by a ’new community centre’ – but where would this be built?

Local facilities and infrastructure, such as doctors’ surgeries, schools and roads, are already under maximum pressure, and in some cases near breaking point.
Although the Local Plan seeks ‘to reduce traffic congestion…protect public transport services…’ (p55), and states that ‘opportunities should include improving access to railway services and other public transport (i.e. buses) to help minimise congestion and improve air quality’(p55), it is difficult to comprehend how the inevitable addition of thousands more private vehicles in the district will reduce traffic congestion or improve air quality.

National Planning policy sets out that the Council should aim to meet the ‘Local Housing Need’ figure provided by central government ‘unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits’ (p21). There is no doubt that in this District the adverse impacts of attempting to meet the building requirements set by the Government can be shown to ‘significantly and demonstrably outweigh the benefits’. This could give the Sevenoaks District Council the opportunity to challenge the unreasonably high building requirements that are being imposed by the Government, and it is likely that this consultation will show that the people of the District would support them in this challenge.

This amount of development over such a short period of time could not by any reckoning be considered sustainable development (the NPPF intention is that the planning system delivers sustainable development. (p18-19)). It is also contrary to the Localism Act (2011) which aims to facilitate the devolution of decision-making powers, including planning, from central government to local communities:

‘Local Authorities can do their job best when they have genuine freedom to respond to what local people want, not what they are told to do by central government.’ (A Plain English Guide to the Localism Act, p4, Dept of Communities and Local Government, November 2011).