Sevenoaks District Council’s Local Plan strategy
The draft Local Plan (2015-35) sets out the council’s strategy of:
- providing 13,960 homes to meet its local housing need
- focusing growth at existing settlements and maximising supply (through increased density)
- redevelopment of previously developed land (and of locally-defined brownfield land in sustainable locations)
- development of greenfield Green Belt land only in exceptional circumstances, where social and community infrastructure is being proposed in addition to housing, which could help address evidenced infrastructure deficiencies in the local area
Locally-defined brownfield land
Sevenoaks District Council is seeking to introduce the concept of locally- defined brownfield land as a means of gleaning as many housing sites as possible to contribute towards the requirement of 13,960 homes.
This definition goes beyond the (Nationally Planning Policy Framework) NPPF definition of previously developed land (PDL) – and could have serious repercussions for other Kent Green Belt authorities.
Locally-defined exceptional circumstances
The council is also seeking to include a local definition of exceptional circumstances.
The draft NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified.
The council is exploring in its draft Local Plan whether its Green Belt boundaries should be altered to meet its housing need. Twelve exceptional-circumstances sites have been put forward for consideration.
The council acknowledges that Sevenoaks is a highly constrained district, with 93% being Green Belt and 60% (Area of Outstanding Natural Beauty) AONB.
It is explained at para 1.14 of the draft Plan that consultation is taking place on all these sites to receive stakeholder comments… and that the inclusion of these sites in this consultation does not guarantee their inclusion in the final draft Local Plan.
The table below lists the 12 exceptional-circumstances sites.
Location Policy No. of units Site area (hectares)
Sevenoaks Quarry MX43 600 94
Land west of Chevening MX49 26-30 1.7
Road, Chipstead HO53
Land east of London MX50 40 8.5
Road, Dunton Green HO70
Land between Beechlea MX54a/b 750 39.5
Lane and Highlands Hill, HO188
Pedham Place, Swanley/ MX48 c2,500 117.6
Land south and east of HO189 & 515 27.2
Four Elms Road or HO190
———————————— MX25 &
Land at Crouch House MX51 250 18.4
Road or HO158
Land at Breezehurst MX10 450 18
Land west of Romani MX44 80 6.7
Land north and east of HO371 & 600 21.8
Corinthian and MX52 & Corinthian 570 74.6
Banckside MX53 Banckside 230
———————————— HO162 &
Broke Hill golf course MX41 800 60.2
CPRE Kent observations on the Sevenoaks Local Plan
In general, CPRE Kent supports a development strategy that meets the following criteria:
- Prioritises the redevelopment of appropriate, sustainably-located previously-developed land. It does not support development on locally-defined brownfield land in unsustainable locations.
- Does not lead to the loss of best and most versatile agricultural land, Green Belt, AONB and other designations.
- Focuses growth at existing settlements and maximises supply through increased densities at sustainable locations.
- Recognises the acute need for rural affordable housing.
CPRE Kent is concerned about the level of housing proposed. It is noted that the 2015 SHMA sets out objectively assessed need based on the Office for National Statistics (ONS) 2012-based sub-national population projections and 2012-based household projection figures.
These figures will need to be reviewed in light of the 2016 mid-year figures and the household projections (expected next month).
Following the decline in population (2012-2016), it would seem reasonable to assume that household projections will also be in decline. However, we wait with interest to see what the government’s stance on this will be.
CPRE Kent has serious reservations that the construction industry will be capable of delivering the proposed level of housing. Average housing completions for the district are noted as 250dpa (dwellings per annum) over the last 10 years. With the suggested local housing need of 13,960, this would rise to 698dpa.
CPRE Kent has serious reservations over the need to deliver homes in accordance with the standard methodology for calculating local housing need, for the following reasons:
- The NPPF states that the government attaches great importance to the Green Belt – it states that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of Plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the Plan period”.
- One of the Green Belt purposes is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Resisting development in the Green Belt will help encourage the bringing forward of previously developed land in the urban area.
- New housing in the Green Belt is likely to be for large properties that won’t meet the demand of local people who genuinely require housing in the villages and settlements within, or washed over, the Green Belt.
CPRE Kent does not consider that allocating land to meet local housing need with the promise of social and community infrastructure sufficiently demonstrates exceptional circumstances.
CPRE Kent is concerned that the harm caused to the purposes of the Green Belt designation and other considerations would not be outweighed by the requirements of the local housing need requirement.
Wednesday, August 22, 2018