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 DLPP1159
Respondent Lichfields (Sarah Fabes ID-3226) [View all comments by this respondent]
Response Date 02 Oct 2018
Current Status Accepted

Regardless of the above, draft Policy 1 (A Balanced Strategy for Growth in a Constrained District) seeks to establish the approach for directing new development and growth within the District.

In line with the NPPF, the policy prioritises development within the boundaries of existing town settlements and through the re-use of previously developed brownfield land. However, the policy notes that "the supplyof 'brownfield’ land is limited and therefore this is not a solution in itself." Draft Policy 1 therefore states that "…sustainable patterns of development by permitting development in the Green Belt only in ‘exceptional circumstances’, in the most sustainable locations…".

As a result, it is recognised that draft Policy 2 (Housing and Mixed-Use Site Allocations) proposes up to 87 new housing and mixed-use site allocations as well as the retention of 13 unimplemented existing housing and mixed-use site allocations from the ADMP (2015), including our client’s site (ref. H2(c)). A large number of the emerging allocations comprise sites located within existing settlements or brownfield land and U+I support this. However, almost a quarter (24%) of the draft allocations are located within the Green Belt and require further testing to demonstrate that ‘exceptional circumstances’ exist for their release before they can be taken for inclusion within the new Local Plan.

The new chapter of the NPPF, ‘making effective use of land’ (Chapter 11), requires planning policies and decisions to support development that makes efficient use of land. Where there is an existing or anticipated shortage of land for meeting identified housing needs, this means avoiding "homes being built at low densities, and ensure[ing] that developments make optimal use of the potential of each site" (paragraph 123). In line with this, draft Policy 12 (Housing Density) places increased emphasis on delivering housing at higher densities than past development and states that this will be expected from new developments. U+I agree with this approach but does not consider that it is reflected in the emerging site allocations. For example, recent planning applications relating to existing allocation ref. H2(c) seek to deliver more than 300 units. However, the Draft Local Plan indicates a capacity of only 250 units. The site is a brownfield town centre site which is well served by public transport and identified for regeneration in both the adopted and emerging plans. Therefore, in accordance with the NPPF, it is a site which should be optimised.

Whilst the inclusion of a draft capacity is a marked improvement on the current position, paragraph 123(a)

states that such sites should be subject to a minimum density standard which "…should seek a significant uplift in the average density of residential development within these areas, unless it can be shown that there are strong reasons why this would be inappropriate". Car parks and service yards are also specifically identified (NPPF para. 118(d)) as ‘under-utilised land’ where planning policies should seek to promote and support development "especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively."

To ensure that the Draft Local Plan is consistent with national planning guidance, we recommend that the capacities for the emerging and retained urban and brownfield site allocations are reviewed to ensure that first and foremost they are optimised to make as much use of previously-developed land as possible. This should include existing allocation ref. H2(c) which is capable of delivering up to 350 new homes, as well as commercial, community and other complimentary town centre uses at ground and lower floor levels. Linked to this, Policy 1 should explicitly encourage the optimisation of previously developed land as suggested below:

"We will make as much use as possible of suitable previously developed brownfield sites and

underutilised land. This will involve optimising the density of development in accordance

with Policy 12. encourage the re-use of previously developed 'brownfield' land, including land in the

Green Belt, where it is situated in sustainable locations. However, the supply of 'brownfield' land is limited

and therefore this is not a solution in itself."

Comprehensive suggested tracked changes to draft policy wording is provided at Appendix 1.