Sevenoaks & Swanley Lib Dem comments on the Local Plan now on SDC website
Our submissions on the Local Plan are now on the District Council website. But they are much easier to read here!
So here goes .........
Sevenoaks & Swanley Liberal Democrats' comments on Sevenoaks Local Plan call for:
- review of the governments housing targets for Sevenoaks, as the international situation changes
- recognition that any real increase in housing is only possible with better transport
- objections to overdevelopment which would overwhelm some of our villages
- more focus on community housing developments for the rising numbers of older people
- more affordable homes for those who work in Sevenoaks, including social rented housing
- real action rather than warm words on safer streets, air pollution, tackling speeding traffic and encouraging walking and cycling
- action to cater for thousands of extra school students who will change Sevenoaks in the next ten years
- recognition that improving the environment in Sevenoaks communities as attractive places to live, work and visit drives our economy. Our economy isn't limited by environmental standards; it depends on them.
Constraints
The main constraint on Sevenoaks District Council in its plan is the artificial government target for housing numbers. Changes in the economic and social pressures on different communities present real risks to the plan. The role of international workers in the London economy which Sevenoaks serves, and in local industry and services is high, and the impact of leaving the EU will be significant. It is therefore vital that the targets are reviewed early in the life of the plan.
In-migration to Sevenoaks depends critically on transport links to London for employment for residents. The rail links on which many workers depend,are at full capacity, with no new investment planned beyond limited new services via Otford and Swanley on Thameslink, promised for 2018 but not yet delivered.
Significant increases in housing must be conditional on new rail capacity delivered on the Darenth Valley line, improvements on the West Kent Mainline through Sevenoaks and from Swanley during the plan period.
The other key constraint is the Green Belt and AONBs which gives the District its special character. We accept that some brownfeld areas may need to be used for new purposes. However, 'Exceptional Circumstances' Greenbelt sites should not have to deliver such a high proportion of the total number of homes, 6,800 out of 13,400 - over half.
As a high proportion of additional residents are forecast to be retired people, there should be greater emphasis on attractive, higher density community / co-housing sites (like Rockdale in Sevenoaks), encouraging their development at the heart of existing communities. This would support the sustainability of our town and village centres, and help grow the already vital contribution of older and retired people to their communities. More efficient use of land, and of the housing stock, must be central to the plan, with roles for housing associations better defined.
Where 'Exceptional Circumstances' sites are included in the plan there must be clear evidence that social and transport infrastructure will be developed to support them. More important, they must not be so large that the developments overwhelm the communities around them. The proposals at Pedham Place and in Westerham fail both these tests, and should not be included in their current form.
The major developments at Edenbridge and Swanley are also challenging; to be accepted these need clear resolution of transport and social infrastructure needs. The total for developments in Halstead also run the risk of overwhelming the local community, and the access links.
Major development proposed around the quarries in north Sevenoaks needs to be limited to avoid impinging on Seal and Kemsing, and to safeguard the function of the Green Belt separating settlements. Seal Parish Council make the point that neither the draft Local Plan nor Tarmac acknowledge that existing mineral conditions on the quarry site require restoration and public access for recreation, without the need for enabling development, This omission requires correction, to make absolutely sure that funding generated by new development contributes to new infrastructure, and is not diverted for restoration which the site owners are already required to carry out.
Housing Choice
The shortage of affordable homes in Sevenoaks for people who work here is acute. It is a key reason for traffic congestion and poor air quality as so many people have to drive in from elsewhere to work The key shortage is social rented housing, which should have a higher share of the allocation; this should be done by tightening 'viability exemptions' which allow developers to escape requirements to contribute to affordable homes.
The plan refers to the problems in keeping smaller houses available, because of the frequency with which existing homes are extended. Diversity of types and sizes of homes should be explicitly encouraged through imaginative conversion of existing buildings, and encouragement of self build homes.
Local Economy
The plan should recognise explicitly that maintaining and improving the environment in Sevenoaks communities as attractive places to live, work and visit drives our economy. Our economy isn't limited by environmental standards; it depends on them.
We support the objective of supporting existing town and village centres, with a flexible approach to take account of changing economic demands. Two major trends which should be more explicitly reflected in the plan are:
- the increasing numbers of people working part time from home in high value services, with needs for local support and networking
- the continuing rise of on-line retail, which may make redundant the additional retail space suggested in the plan.
Commercial space planning for high tech / high value services, and the clusters and networks to support their successful development needs better explanation.
Accessibility and connectivity will be critical for a sucessful economy as population grows. If the number of people in Sevenoaks District is 25% + higher at the end of the period than it is today, there is no way in which their transport needs can be met by private cars. The plan requires better identification of practical steps to improve public transport infrastructure, and support to make walking and cycling more attractive.
Quality of Life
Most of Sevenoaks District has an outstanding quality of residential environment. This is what has driven its growth and its character. Further growth must not undermine the quality of our communities which make them special.
The impact of increasing, and speeding, traffic poses the biggest threat to quality of life for families living in our towns and villages. The plan must make clear how noise, pollution, congestion and danger which damages them will be dealt with. It must show how:
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- real action on Air Quality Management will develop as the plan is implemented
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- speeding and noisy traffic in residential roads will be controlled
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- safety for walkers, cyclists and rising numbers of mobility scooters will improve.
Concrete action to make walking and cycling safer requires a strategic approach. Simply relying on Kent's reactive policies, which kick in after death or serious injury, is unnacceptable. The plan needs clear proposals for walking and cycling, including safe crossings for major roads like the A25, extension of 20 mph zones, new safe walking and cycle links, and a timetable to make all of them happen.
Education and health
Within 5 years there will be many more school students in and close to Sevenoaks Town during the day, as both primary and secondary schools continue major expansion. Most will be along the A25. They will have specific needs to get around safely, and to be educated in unpolluted air. Identifying their transport needs, and reducing the impact of traffic pollution on their learning environment needs to be part of the plan.
Local education and health services will see significant additional demand, and investment needs to be sustained and planned. Sevenoaks must find ways of avoiding wasted effort and opportunity of the type which occured at Dunton Green, when developers agreed to fund a heath centre, but the NHS refused to run it.
Recreation and Green Spaces
The policies proposed on leisure and recreation do not explicitly mention allotments, although these are an important focus for exercise and for community activity. The open spaces associated with the policies do include allotments. Allotments must receive the same degree of protection in the local plan as other recreation space, in addition to their statutory protection.
Delivery
All those involved in the local planning process know only too well that zoning land or granting planning permission is no guarantee of homes provided. There are currently several major sites in Sevenoaks where substantial numbers of homes could have been built over the last ten years, but which are still empty, because it is more profitable for site owners to hold them empty and wait for values to rise than it is to build . Unless this basic flaw in incentives is fixed, by taxing value of land for which permission is given, the whole Local Plan exercise will not achieve its objectives. It will create more financial assets, but not necessarily more homes.
Sevenoaks & Swanley Liberal Democrats, September 2018