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 2 - Housing and Mixed Use Site Allocations [View all comments on this section]
Comment ID DLPP1146
Respondent dha Planning (David Bedford ID… [View all comments by this respondent]
Response Date 01 Oct 2018
Current Status Accepted
Response Type OBSERVATIONS
Comment

This statement has been prepared on behalf of Mr J W Sparrow in response to the
Sevenoaks District Council Draft Local Plan Consultation. Our client controls site
HO103, land north east of Robinwood Drive, Seal and is promoting it for residential
allocation.
Based on the current national and local planning context, we consider our client’s
site to be suitable area to release the Green Belt.
Notwithstanding our site-specific representations, we have significant concerns
about the progress of the Local Plan to date and the key assumptions that are
being made. For example, we consider the Council has too quickly assumed that
the full local housing need cannot be delivered owing to Green Belt constraints
and see development as a hinderance rather than an opportunity.
We consider that the assumptions about ‘exceptional circumstances’ remain
extremely flawed and do not represent the guidance set out within case law nor
the recently published NPPF. Housing need alone is enough to positively plan for
Green Belt review as part of the local plan review process, yet the draft strategy
does not recognise this important point.
The evidence base upon which the Local Plan is being prepared is not robust. The
inability to properly explore Green Belt boundaries and the decision of Arup to
parcel land into unusually large areas has resulted in leading results that does not
form a sound basis for the plan.
In conclusion, we consider the draft Local Plan to be of limited value and certainly
not a robust foundation for progressing to Regulation 19. We therefore strongly
recommend that the process and evidence base be reviewed with a greater level
of stakeholder involvement.

Please see attached for further information.

Attachments