Plan 2040 Full Survey

The Spatial Vision should include greater emphasis on the provision of employment sites and employment areas to support the local economy, including in areas outside of town centres and settlement boundaries

The duty to cooperate will not work as no adjoining planning authorities have spare land for development. Land will need to be released from the Green Belt and the Kent Downs Area of Outstanding Natural Beauty to meet current and future demand. Such sites were being considered as part of the previous Local Plan Review.

Our Client, the O’Keefe Group, own a site which is brownfield land within an existing employment use. To the east is further brownfield land, beyond which is the M25. Development employment land is to the south. The site is well screened by trees to the north and west, beyond which lie fields and the M25.

Whilst the site is located within the Green Belt and Kent Down AONB, it is not exposed or significantly sensitive within the setting of the AONB (reflected by the fact that both the Kent Downs AONB team and Natural England voice no objection to the site as part of the sites appraisal published by Sevenoaks in December 2018.

The site has been promoted to the Council as part of the Regulation 19 consultation to the Sevenoaks Local Plan in 2019. This Local Plan was subsequently found to be unsound following a Judicial Review undertaken by Justice Dove on November 13th of 2020. On the 8th of April 2021 the Council received confirmation from the Court of Appeal that its application to challenge the decision of Mr. Justice Dove, in regard to the Councils approach to meeting the DtC (Duty to Co-operate) had not been successful.

Most recently, the site, was submitted as part of the Call for Sites Stage 2 consultation on the Sevenoaks Local Plan in January 2022.

Our client’s site, as an existing brownfield land in employment use, is a notable example of the opportunities for much needed employment land that require support through local policy to ensure delivery of adequate levels of employment land. There is a clear need for increased employment provision within the district, and demand is greatly exceeding the current supply. Proposals for employment developments in highly sustainable locations such as the subject site, should therefore be considered, as the impact of refusing such developments will be detrimental to building a strong rural and local competitive economy.

The site, therefore, should form an integral part of the district’s strategy for meeting its minimum employment requirement and the local plan should make provision for the release and redevelopment of this site, and similar sites, within its draft policies.

The density options listed above are unrealistic with no evidence for the approach.

A generic density recommendation for the entire District is unreasonable. Density should be allocated in accordance with the area within the District ability to support higher or lower densities, with regard to the various opportunities and constraints each area possesses. Edenbridge and Swanley, for example, are more modern settlements and are capable of supporting a higher density, whilst Sevenoaks, with its numerous conservation areas and historic settlement pattern is capable of providing lower densities. On the whole, areas with existing infrastructure and where new infrastructure can easily be provided (including areas with less development constraints and ability to connect to existing infrastructure) should be prioritised for higher densities. Infrastructure throughout the District should be improved to support the needs of a growing population.

With regard to the final bullet point 'the shortfall may need to be accommodated in neighbouring areas or in the Green Belt'. This should read as 'the shortfall will need to be accommodated in neighbouring areas or in the Green Belt'.

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The provision of infrastructure across the district is imperative for the success of local businesses, and essential to draw and retain future businesses to the District

Support of the release of land from the Green Belt for employment uses. The intensification of existing employment sites alone will not meet the Districts identified need for additional employment floorspace.

The retention of existing businesses and the number of new businesses that set up in the District are key markers of the economic success and expansion of the District. Furthermore, the provision of and take up of new employment floorspace is representative of economic growth and success, and should be support in local policy.

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The plan should promote and support of the provision of sufficient land for development for employment uses, including supporting the release of land from the Green Belt and AONB where appropriate and justified, and the intensification of land in such location where the existing employment use is established. Additionally, the plan should support the provision and expansion of infrastructure throughout the District to facilitate the expansion of employment sites and take advantage of technological advancements.

? No comment on the marketing evidence requirements set out within Policy EMP3. However, Policy EMP3 also identifies the criteria by which proposals for new employment space will be assessed. It is considered that Policy EMP3 should make provision for development of previously developed land and, where appropriate, well connected sites within the Green Belt, AONB and adjacent to settlement boundaries, for new employment particularly where there is an identified need and/or an existing shortfall. Furthermore, Policy EMP3 should provide explicit support for the expansion and intensification of existing employment sites, including brownfield sites previously in employment use, within the Green Belt, AONB, and throughout the District.

A variety of employment floorspace is required to meet the identified and projected needs of the District. The provision of new employment floorspace and the intensification and expansion of existing employment floorspace in areas benefiting from good infrastructure and in accessible locations is of particular importance. As identified previously, relying on the intensification of existing employment sites alone will not be sufficient to meet the Districts needs, and expansion of such sites, including those located within the Green Belt and AONB, should therefore be supported.

High quality workspaces with good access to infrastructure, transport links and green space would promote healthy workspaces and patterns in the District. The expansion, intensification and redevelopment of existing employment and brownfield sites to enable improved provision of employment floorspace should therefore be supported, including within an AONB and the Green Belt

The expansion, intensification and redevelopment of existing employment and brownfield sites within the District, including within Kent Downs AONB and the Green Belt, to provide improved employment facilities would ensure the most efficient and effective use of previously developed land.

Furthermore, the intensification and provision of new employment floorspace in accessible locations benefiting from good infrastructure would support the Districts sustainability objectives and contribute toward Net Zero by ensuring good access to transport links and modes, and reducing the need to travel within and outside of the District for employment. The Council should also seek to encourage active and sustainable transport choices.

Allowances should be made for a range of employment uses on land in rural areas benefiting from good access to infrastructure and are in accessible locations.

A combined approach that supports the retention of existing high streets and their expansion or contraction were appropriate should be supported by local policy.

Sevenoaks Town - Policy SEV1 should support the provision and expansion of infrastructure and transport connections within and too Sevenoaks Town. Specific mention should made to the support of new employment floorspace in and around Sevenoaks Town to support the economic function of the Town and ensure its continued viability.

Improved infrastructure and accessibility throughout the District.

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Presentation at the Design Review Panel should be optional.

As per our answer to the above question, presentation at the Design Review Panel should be optional.

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Small - Medium size sites

No, whilst the importance of public engagement is recognised, public engagement itself is unlikely to deliver clear and cohesive design guidance or development that responds to local character.

Release land for development in appropriate locations, including on settlement boundaries.

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Policy NE1 should recognise the need to allow major development within the Districts AONB, particularly where it relates to the expansion, intensification and/or redevelopment of existing brownfield sites.

The importance of protecting the characteristics and quality of AONB’s is well recognised, however, this should not preclude development itself and allowanced should be made where appropriate and where there is an identified local need.

Furthermore, in relation to design criteria within AONB, flexibility should be made for employment sites, which may not be able to accord with strict design criteria.

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The importance of protecting biodiversity and the natural environment is recognized. However, this should be balanced against the development needs of the District. Policy BW1 should make allowances for large scale development and the redevelopment, expansion and or/intensification of existing sites in appropriate locations where there is an identified need for the development. Mitigation measures should be enabled to alleviate any concerns over biodiversity and environmental impact.

The current national requirement for 10% biodiversity net gain is proving difficult to achieve on many sites. A 20% target is excessive for many sites in Sevenoaks District Council. It is considered that 10% should be the policy requirement to ensure the aims and objectives of local and national policy are met, with an aspirational objective of 20%.

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Water infrastructure should be spread across the district

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The need to shift toward sustainable modes of transport is recognized. However, this should be balanced against the development needs of the District and not be applied restrictively. Allowances should be made for development that would help facilitate (for example through financial contributions) improvements to existing and provision of new sustainable transport infrastructure.

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Yes, This should be determined on a case by case basis.

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