Plan 2040 Full Survey

There is not enough recognition within the ‘Homes to meet local needs’ strategic issue, that homes need to be provided across the entirety of the District, not just within existing settlements. The objectives within this strategic issue are broadly agreed with but whilst we support a continued focus on sites within existing settlements in general, raising densities to "optimise" housing delivery should not come at the detriment either of the character of these sites themselves or the areas surrounding them - many of which will be covered by other protective landscape or heritage designations.

We would also question whether there should be recognition that many of the strategic issues will actually compete with each other and it may not be possible to fully deliver on some whilst meeting others.

Whilst we broadly agree with the overall aspirations of the development strategy, it is known from previous work undertaken on the Local Plan that neighbouring authorities are just as constrained as Sevenoaks DC and all have indicated very little if any ability to assist Sevenoaks in meeting their housing needs as they are not able to meet their own. A development strategy which relies on identifying areas for housing in other authority areas as a second from top priority does not offer a robust strategy for meeting housing needs in Sevenoaks. We would suggest that the Step 2 Duty to Co-operate should be Step 3 and Green Belt release should be Step 2 given this context. Green Belt release, particularly on the on the edge of settlements where there are good connections offer the opportunity to contribute to housing supply without prejudicing the role of the Green Belt. Larger scale release of land has been considered previously but we consider that combination of smaller sites and larger scale release on the edge of settlements needs to be given more consideration if housing needs are to be met. It is not appropriate to accept a position of housing shortfall from the outset if all options for meeting housing needs have not been fully considered. Indeed, the Council is already well aware that there is insufficient land to meet the authority’s housing needs over the plan period without some Green Belt release. This must form a constituent and recognised part of the development strategy if the new Local Plan is to be robust.

The density options are unrealistic and there is no evidence provided as to how they have been arrived at. Imposing generic density levels across the District does not reflect the capability of different areas or settlements to absorb or accommodate new housing development. It also takes no account of site-specific aspects of developing individual sites which will firmly dictate the capacity and density that is achievable. There is also little acknowledgement of forthcoming national requirements such as mandatory Biodiversity Net Gain which will place significant pressure on the capacity of all development sites. Density should be allocated in accordance with the ability to support higher or lower densities which requires more consideration of the circumstances and context within which they would be developed. Many sites within existing settlement are covered by heritage and landscape designations and have grown at low density as a result. Looking to cram more development into these sensitive areas runs a significant risk of prejudicing their character and the reasons for their protection. This could be avoided by careful and efficient release of Green Belt land. The Local Plan should be identifying specific sites and individual densities for them that are appropriate to their context. Preparing a robust evidence base with which to demonstrate how that can be achieved is key. Simply imposing a generic density level across the District, which in each scenario offers a shortfall anyway, is not the right approach. It is concerning to see a reluctance on the part of the Council to accept the position they are in and to positively acknowledge that identified shortfalls will have to be met outside of existing settlements, in the Green Belt or in neighbouring authorities, of which, none are known to have capacity to assist.

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We agree with all of the design and technical criteria except for the first bullet point requiring a prescribed dwelling mix in accordance with the 2022 Housing Needs Survey. Housing Needs in 2022 will bear no relevance to those experienced in later years of the plan period. The Local Plan should look to maintain an up to date evidence base and a housing needs survey is a critical part of this. Any reference in this policy should simply be to an up to date housing needs survey and the Council should ensure this survey is updated regularly.

We are concerned about the impact of the affordable housing thresholds particularly on smaller sites. The size area of 0.5 ha with a corresponding 30% provision for previously developed brownfield and 40% for greenfield could have a significant impact on the viability of developing smaller sites and their consequent delivery. Whilst we accept there is a substantial need for affordable housing across the District, historically this level of provision has not been achieved and we would urge further consideration of either removing the site size area threshold or increasing it to a higher level to ensure that smaller sites are not unduly prejudiced.

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Similarly to our comments in relation to Policy H1, the direct reference to the 2022 Housing Needs Survey should be removed and simply referred to as an “up to date housing needs survey”. Specialist care accommodation including elderly care requires a much larger land take than standard mainstream housing because of the additional facilities and technical standard of space and accommodation required. It can be difficult to find sites big enough within existing settlements to accommodate these which means that meeting the locational requirements of the policy could be difficult. The local plan should positively plan for all housing needs across the District and the elderly and specialist care sectors are no exception. There is no commitment within this policy to identifying specific sites for housing in this sector and we consider that the plan should look to do this to ensure that sites are available and operators are not having to compete with market housing developers.

Policy H5 unnecessarily confines build to rent development to the built-up areas of Sevenoaks, Edenbridge and Swanley. There are many other settlements and areas on the edge of well-connected villages that would be suitable for this type of development. Lafone Properties Ltd own a large tract of land on the edge of the developed area Chiddingstone Causeway situated to the rear of the Little Brown Jug PH, Tonbridge Road – known as the former aerodrome.

This site extends to approximately 10 ha and immediately abuts the edge of the village settlement. It offers direct pedestrian access into the village via the footway running along the B2027 Tonbridge Road. The centre of the village is well within walking distance and provides a general store, community hall and public house. The village is well served by transport links, being on the Tonbridge to Redhill railway line with Penshurst railway station located within the centre of the village. Two bus routes pass through the village offering services to Tonbridge where more substantial shopping and other services can be found. Unusually for a settlement of this size, Chiddingstone Causeway offers employment premises and new community facilities as well as easy access to major centres, which suggests that it is a sustainable location capable of accommodating additional appropriate development. The aerodrome site would make a significant and much needed contribution to the District’s housing land supply.

In a similar manner Lafone properties Ltd also own and are promoting two smaller sites at Charcott Village, both of which lie immediately adjacent to the settlement boundary and offer direct access to the village. However, under Policy H5 both the former Aerodrome and Charcott sites would not be considered suitable for build to rent development, simply by virtue of their location outside of the three major towns. The opportunity to secure larger and smaller scale residential development on a sustainable site would be missed by adhering to an overly prescriptive policy wording such as this. Policy H5 should be expanded to remove any reference to the three major settlements and to allow for sustainable and available sites to come forward across the entirety of the District where they meet all relevant development plan policies and accord with the tenets of the NPPF. This restriction is arbitrary and unnecessary and would not meet the objectives of the policy. There is no reason why build to rent properties should not be positively promoted and secured in appropriate locations across the entirety of the District.

Intensification of existing smaller sites will only be achieved with substantial increases in density and/or height of buildings – both of which have the potential to create significant design, amenity and character issues if left open ended. Realistic and clearly defined parameters for density and height on smaller sites (both allocated and unallocated) must be included within the development plan and particularly within Policy H6 to ensure a detailed framework of guidance with which to ensure sites are able to be delivered. We would also urge the Council to broaden the remit of this policy to allow for consideration of smaller sites outside and on the edge of existing settlements where they are sustainably located. Once again restricting support for development of smaller sites to just those within existing settlement boundaries artificially reduces the pool of eligible sites and is unnecessarily restrictive. This will not help to deliver more housing development on smaller sites and would not meet the objectives of the policy which aim to do so.

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As detailed previously density is a one dimensional and relatively crude means of determining capacity which takes no account of site specific constraints and opportunities. Prescribing density ranges for generic broad-brush areas makes no allowance for individual circumstance. We do broadly support the Council’s focus on ensuring most efficient use of land is achieved and that development capacity within sites is maximised. However, there is no evidence that the density parameters set out in Policy H7 have been formulated with any consideration of the impacts of national legislation change in relation to Biodiversity Bet Gain which will have significant impact on the developable area and consequent capacity of many development sites. Employing a generic housing density policy such as Policy H7 will place greater pressure on developers to design housing that may not accord with the pattern and character of the local area simply to ensure capacity. There is a very real risk that being overly prescriptive in this regard will mean that competing development pressures cannot be balanced and sites (particularly smaller sites) remain undeveloped. Equally there may well be sites that can offer greater density of development than the ranges set out given their size and circumstance. The policy needs to have the flexibility to allow sites to achieve higher densities where they can and to support smaller sites in offering a density of development that is appropriate to its location and context.

Locations for taller buildings and land suitable for intensification cannot be determined in any generic standardised way. This should be assessed on a case-by-case basis and informed by local context. We consider that the intensification of all brownfield land should be supported in principle but consideration must be given to the site-specific circumstances such as accessibility and proximity to facilities, visual and landscape impact etc.

The policy should be reworded to remove reference to generic density ranges and to provide greater flexibility for sites to deliver housing according to individual circumstance and to respond to local conditions.

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Provision of adequate infrastructure and housing.

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We have nothing further to add but would generally support a period of one year's marketing as adequate demonstration of a lack demand.

The general shift away from office-based working to home working represents a major change in behaviour. Live-work schemes and development which allows for greater home working should be supported particularly as this offers the ability to reduce travel and keep employment opportunities local

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Supporting and promoting live-work schemes.

Support for live work schemes. Greater flexibility and support for re-use of rural buildings and endeavours to secure alternative commercial uses through diversification.

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Preparing a Climate Impact Assessment could be a significant and costly exercise for smaller scale developments. The policy should set out a site size threshold above which such an assessment is required. The Council should also make clear what is expected within such a document. Building Regulations cover this area comprehensively and there is no requirement for duplication.

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Design Review Panels can be a useful tool for larger and more complex developments but would not be necessary for all. The policy should be clear that Design Review Panels are optional. Commitment to ensuring the review panels are run regularly and the costs of funding the process are not prohibitive is also key.

As above - they should be optional.

We cannot see the benefit of including this policy. The TCPA 1990 (as amended) sets out clearly what is required of an outline application, there is no need to duplicate this in policy.

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Small to medium sized sites. Larger sites will require bespoke masterplanning.

Public engagement itself is unlikely to deliver clear and cohesive design guidance or development that responds to local character. It is an important element of the planning process but not critical to securing appropriate design.

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

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Conservation Area status already conveys sufficient protection.

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This is generally held as best practice already.

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20% BNG is significantly higher than the 10% set out in the Environment Act. Achieving 10% is already proving very difficult for many sites with small-medium sized sites experiencing the greatest challenges. Requiring BNG at this level is likely to have a major impact on the delivery of sites and present significnat cost implications for development. The Council is relying on the delivery of smaller sites within existing settlements and this policy would apply equally to all development, regardless of size. Employing a 20% requirement is uneccessary and is liley to impact negatively upon housing delivery. Given the level of constraint to development already experienced across the District, there is no need to go above and beyond the targets already set out as mandatory requirements in legislation. The figure should be reduced to 10% in line with the Environment Act.

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If open space is being delivered it needs to be usable, well maintained and offer a meaningful facility. Smaller sites are not well suited to delivering public open space given their spatial constraints and costs of ongoing maintenance liability.

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Water capacity issues are experienced District wide and infrastructure provision should be prioritised in all parts of the authority area.

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The Council has identified housing need but continues to accept a position of shortfall from the outset, stating that they do not intend to meet their housing needs in full. We do not consider this to be an acceptable position to take without having explored all options to meet housing needs – which does not appear to be the intention. The Local Plan consultation focuses very heavily on maximising the capacity of sites within existing settlements. Whilst we are largely supportive of this it should not and cannot offer the whole solution in isolation. We equally acknowledge that the constraints facing the District are considerable but we have significant concerns about focusing so heavily on sites within existing settlements.

The Council has outlined the need for smaller sites to come forward and an ongoing issue with affordability of housing across the District. We are entirely supportive of a focus on smaller sites. However, focusing on those within the existing settlements narrows the number of sites available and places far greater pressure on maximum capacity being delivered in an artificially reduced pool. We cannot see how this would not come at the detriment of the character of some sites and areas. The proposed focus on maximising/optimising development density across smaller sites within existing settlements is of concern as it may well lead to substandard designs and cramming development into areas that cannot sustain this level of development – particularly in rural villages. The Local Plan consultation takes no account of the additional pressures of new legislation requiring Biodiversity Net Gain which will further squeeze the capacity of development sites across the District. Smaller sites will be hit particularly hard in this respect and are already struggling to meet the Governments requirements.

Further land in the Green Belt must be identified to meet housing need in the District for the plan period and beyond. A more dispersed and District wide growth strategy that looks to both maximise available sites within existing settlements and to make limited Green Belt release, particularly for sites on the edge of settlements which offer the same sustainability credentials as those sites located within would offer a better strategy to actually meeting housing needs. A mediated and more than one dimensional approach is better equipped to avoid damage and harm to the character of landscape and historic villages across the District, whilst meeting housing needs. The land at the former aerodrome in Chiddingstone Causeway and the two site owner by Lafone Properties Ltd in Charcott Village all offer sites that are available and suitable for housing development on the edge of existing settlements. Each of these sites and in particular the former aerodrome land offer excellent sustainability credentials that are no different to the sites identified for allocation within the village settlement during the last Local Plan. We would urge the Council to not to rule out high performing and well-located sites such as these which could make a significant contribution to housing delivery simply because they do not lie within a settlement boundary.

There is not enough land within existing settlements to meet the Council’s housing needs in a way that can be sustained and it has been established already that neighbouring authorities are just as constrained and have little if any capacity to accommodate Sevenoaks District housing requirement. Given this, it would seem abundantly clear that there is an overriding need and the exceptional circumstances currently required by Government, to warrant some Green Belt release. The evidence base for the previous Local Plan acknowledged this need and we consider there to have been no change in this respect. The development strategy proposed is flawed in so far as it is following one dimensional path that does not provide give adequate commitment to considering all options. To reiterate our initial point – the Council should not be accepting and indeed planning for a shortfall from the outset when there are other options such as Green Belt release, available.