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 DLPP1147
Respondent Jenny Knowles ID-2500 [View all comments by this respondent]
Response Date 01 Oct 2018
Current Status Accepted

Thank you for the opportunity to respond to the above consultation. I am pleased to submit the Borough Council’s response.

Objectively Assessed Need

We note that Sevenoaks District Council’s identified housing need has seen an increase from the figure previously set out in the Regulation 18 consultation in October 2017, in order to reflect the Government’s Standardised Methodology. The annualised figure of 698 is not dissimilar to that for Tonbridge and Malling at 696. Although we welcome the Sevenoaks Vision 2015-2035 to ‘strive to meet housing and employment need’, Section 1.6 suggests that, given the Green Belt and Area of Outstanding Natural Beauty constraints, the ability to meet the identified need may be impacted. This, coupled with the historic delivery rates achieved in Sevenoaks, raise concerns over the ability to meet the full identified need.

The identified need is 13,960 units. At present between 6,582 -13,382 units are being planned for (including 6,800 on current Green Belt sites – see Green Belt comments). This leaves a residential undersupply of 578 units over the plan period. This raises the question as to where any unmet need may be provided for.

Statement of Common Ground

The Draft Local Plan makes several references to a Statement of Common Ground having been produced. Although Tonbridge and Malling Borough Council have been involved, alongside Sevenoaks District Council and Tonbridge Wells Borough Council in the West 

Kent Statement of Common Ground Pilot Project with the Planning Advisory Service (PAS), we have as yet not seen a draft of the Statement or Common Ground, or been asked to agree a position on the content and therefore this remains a work in progress.

Green Belt

Tonbridge and Malling Borough Council welcomes the decision by Sevenoaks District Council to consider the release of land from the Green Belt in order to try and help meet the identified need. However it is not clear exactly which sites are under consideration or how their potential yield has been calculated. The table on pages 25-30 suggests 12 sites are under consideration for release from the Green Belt, however the table on page 33 only lists 9 potential sites. It is also unclear how the potential yield for each of these sites has been calculated as the number of units proposed does not appear to be consistent with the approach to housing density as set out in Policy 12.

Para. 1.14 states

“To re-iterate, the inclusion of these sites in this consultation does not guarantee their inclusion in the final draft Local Plan. We are still assessing whether the infrastructure proposed meets a genuine evidenced need and whether the exceptional circumstances proposed are sufficient to warrant a Green Belt amendment, and this work will be informed by the stakeholder and community consultation.”

The uncertainty as to whether all or any of these potential sites (or part of them) are to be carried forward in the Local Plan calls in to question their ability to contribute to the supply of housing at this stage. The table of page 33 suggests that these sites could yield 6,800 units over the plan period, and this full figure has been included in the calculations to demonstrate that Sevenoaks District Council is close to meeting the identified need, when this may not be the case following this consultation period. We believe these sites should only be included when there is certainty over their deliverability.