Sevenoaks District Draft Local Plan Consultation July 2018

Comment ID DLPP560
Document Section Draft Local Plan July 2018 A Balanced Strategy for Sustainable Growth in a Constrained District Finding Places for New Homes View all on this section
Respondent Steve Birkin ID-5705 View all by this respondent
Response Date 10 Sep 2018

I am overwhelmed by the length and detail of your draft local plan for the Sevenoaks area for the years 2019-2035.

I therefore do not feel I am in a position to make comments on every proposed development area. Clearly those directly affected by the proposed development sites will be raising concerns about these and how they will have an impact on their immediate environment.

In my case, I wish to make general comments, as a resident of the Sevenoaks District, relating to my alarm about the general proposals which, it seems, are being made simply to adhere to what appears to be a crudely calculated housing requirement. 

Surely, SDC must take note of the National Planning Policy Framework which sets out the government's planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for housing and other development can be produced.

I have read the section relating to the use of Green Belt land in the NPPF policy document published in July 2018. I cannot see how the 12 proposed development sites in your plan which are currently green belt land can be seen as being justified at all. The 'locally defined' exceptional circumstances for building on green belt land, as described in your draft proposals are not compatible with the NPPF policy. The importance of protecting green belt land cannot be overestimated.

The Green Belt needs to be protected as part of positive planning. It is there to stop urban sprawl and encourages the vital regeneration of our urban areas. The proposed destruction, through housing development, of 12 green belt sites in your draft local plan will see suburbanisation to the extent that Sevenoaks will be linked in an urban sprawl fashion with outer London. Swanley and Farningham will become part of a huge conurbation; Halstead and Knockholt will be consumed into a range of developments which will totally overwhelm them. The very nature of these areas will be irrevocably and detrimentally altered. 

As a reminder, the NPPF lists five stated purposes of including land within the Green Belt. 

  • To preserve the setting and special character of historic towns
  • To prevent neighbouring towns from merging into one another
  • To check the unrestricted sprawl of large built-up areas
  • To assist in safeguarding the countryside from encroachment
  • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

Your proposals listed in the draft local plan are in conflict with all these purposes. They will have all kinds of negative consequences including loss of farmland and recreational land and loss of habitat for and consequently loss of wildlife. It will result in increased car use in already congested areas, and an inadequate infrastructure generally which will blight the whole of the northern section of Sevenoaks District. Research in many areas of the UK suggests that insufficient research is made into the availability of 'brownfield' sites for the purposes of providing housing. We are told that the SDC is forced to look at development in the Green Belt due to lack of suitable brownfield sites. I am not convinced this is the case and strongly oppose the use of green belt land (such as the two development sites on golf course land) for the purposes of the SDC's plan. There is now the dreadful prospect of golf course owners in future years submitting planning applications for housing developments all over the district on the back of the current draft plan.  

I have a further worry about your proposals in that I am deeply concerned by the 'locally defined' interpretation of brownfield land. This interpretation goes beyond the definition in the National Planning Policy Framework. The Framework states that  a brownfield site is defined as 'previously developed land' that has the potential for being redeveloped. It is usually land that has been used for industrial and commercial development and is now derelict. 

The SDC definition of a brownfield site is open to being abused by property developers. It is known that there is a practice of deliberately ceasing to use sections of agricultural land and buildings in order to claim that it is then appropriate for commercial and residential development, even though, under alternative ownership, it would still be used for agriculture.