Land at the former Broke Hill Golf Course (MX41)
Regulation 18 Representation
Draft Sevenoaks District Local Plan, July 2018
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 1
Introduction
This representation is made by Quinn Estates Limited pursuant to Regulation 18 of The Town and Country Planning (Local Planning) (England) Regulations 2012 and in response to the consultation papers published by Sevenoaks District Council on 16 July 2018. It has been prepared with the benefit of technical input from leading consultancies, including Montagu Evans, PBA, Lichfields, Aspect and Savills, and advice from Town Legal LLP.
The first part of this representation provides a factual description of Site MX41, the ‘Land at Broke Hill Golf Course, Sevenoaks Road, Halstead’ (Section 1.0). It then provides a brief overview of Quinn Estates’ proposals for the redevelopment of that site, known as Stonehouse Park, in Section 2.0, including the types of uses and character of the place we are seeking to deliver. Section 3.0 responds directly to the consultation’s nine site-specific questions, and we also provide further detail on the scheme’s deliverability, its potential phasing, and the compensatory on-site improvements that would be made to the environmental quality and permeability of retained areas of open space throughout the site. In Section 4.0 we then set out the wider ‘exceptional circumstances’ case for the managed release of this sustainable and discrete parcel of land from the Green Belt and how, through its allocation, the District can secure an unprecedented range of community facilities and new social infrastructure. We comment on the draft site-specific policy for Site MX41 inSection 5.0, before making our concluding remarks in Section 6.0.
Quinn Estates has participated at all stages of this plan-making process, and since the Council’s last round of formal consultation at the ‘Issues and Options’ stage, Quinn Estates has been finalising a contract of sale with Redrow PLC, and a formal agreement is now imminent. This development partnership would allow for rapid implementation to not only accelerate the delivery of high-quality new homes, but also assist with our early-phase build-out of the non-residential uses and community infrastructure that are proffered at this site – including the two major sports facilities, the new Local Centre, and the purpose-built serviced office space.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 4 Site MX41, Land at the former Broke Hill Golf Course
1.1 The site comprises former golf course land, including the former clubhouse, a large greenkeepers’ equipment shed and large areas of carpark hardstanding. A copy of the Site Location Plan can be found at Appendix 1. The site’s northern boundary is strongly-defined by London Road, and by the adjacent stretch of National Rail line (South Eastern Main Line) and Sevenoaks Road (A21). Junction 4 of the M25 is less than two kilometres from the site.
1.2 Knockholt National Rail station (Zone 6, Oyster Card) is located to the immediate north of the site and provides a regular Southeastern service, with direct trains to London Charing Cross operating on a half- hourly basis.
1.3 This public transport hub gives commuters easy and affordable access to Central London, with a season ticket (including London Travel Card) costing less than £2,500.00. In addition, passengers can make the short eight-minute train journey to Sevenoaks and change for one of the many ‘fast’ services to London and other destinations such as Tonbridge and Hastings, or onto the Thameslink line. Based on the Government’s Train Service Requirement from 2022 this station will continue to benefit from services stopping a minimum of twice per hour, regardless of the franchisee. That document also indicates the possibility of additional train paths which could be served if the franchisee chooses.
1.4 The site’s eastern boundary is defined by a linear arrangement of large residential dwellings (circa 40 detached houses off London Road and Watercroft Road). To the south of the site there are various cultivated plots of land, and to the west the boundary is formed by Stonehouse Lane.
1.5 The land is currently subject of designation as Green Belt. There are no other restrictive planning policy or landscape designations affecting the site (for example it is not in an Area of Outstanding Natural Beauty), however there is a small strip of Ancient Woodland that abuts the north-western boundary and there is an area of land subject of a TPO. The site lies wholly in Flood Zone 1 (low probability of flooding). Crucially, this site has not been in agricultural use for many decades, and it is therefore sequentially-preferable to develop this land ahead of other sites that are currently BMVL and cultivated (NPPF, paragraph 71).
1.6 There are several listed buildings near to the site boundary, the nearest being the Grade II listed Church of St Mary, which is located to the south (a list description of this designated heritage asset can be found at Appendix 2). Special regard will need to be paid to the potential effect of development on their setting, however setting effects can be mitigated so that effects are at most less-than-substantial.
1.7 The site is owned by a subsidiary company of Quinn Estates, which means that there are no legal impediments to delivery and there are no contractual obligations that have a bearing on the ‘end scheme’. In other words, this is a unique opportunity to bring forward a development centred around place-making, rather than just profit.
1 ww.southeasternrailway.co.uk 2 HM Government, South Eastern Train Service Requirement from December 2022, available at: https://www.gov.uk/government/uploads/system/ uploads/attachment_data/file/662871/sef-itt-attachment-a-train-service-specification.pdf
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 5
The Development Potential of Stonehouse Park
2.1 Quinn Estates is committed to building a new settlement of the very highest quality and character. As a Kent- based developer, we want to bring forward a mixed-use development that not only provides a reliable source of residential and non-residential land supply across the local plan period, but which also creates a highly-attractive built environment and landscaped setting where people aspire to live, work and socialise.
The Design Brief
2.2 The ‘baseline’ brief for our masterplan architects is to plan for circa 800 conventional dwellings, as this would achieve the necessary ‘critical mass’ for a self-contained and vibrant new community (NPPF, paragraph 72). It is also a quantum of growth that enables the delivery of genuinely-affordable homes in a parkland setting, albeit the site could comfortably accommodate an uplift on this figure in the region of 50 per cent (ie circa 1,200 dwellings) if the Local Planning Authority were minded to plan for additional growth at this sustainable location and to optimise housing delivery through this one-off development opportunity.
2.3 We have already engaged the services of Design South East and we are undertaking a series of workshop sessions with Panel members to refine the masterplan and the design principles of distinctive character areas. A copy of Design South East’s Report on Workshop Session 1, can be found at Appendix 3, in which it notes:
“[t]here is huge potential with this site to create something sustainable; the sports uses, passing traffic on London Road and the station make this site rich in terms of social assets and connectivity.”
The Emerging Masterplan Principles
2.4 The latest iteration of the Illustrative Masterplan can be found at Appendix 4. This plan has been updated by leading architects, Clagues, to reflect the workshop discussions and it will form a basis for further engagement with Design South East and Planning Officers at future design meetings.
2.5 In summary, the scheme has been designed to take advantage of the site’s physical attributes and very close proximity to Knockholt National Rail station. Working with Design South East, the design team has evolved a layout that is structured around the framework of existing mature trees and planting that connects extensive areas of attractive open space and the new sports pitches at the southern countryside boundary, through the development areas and to the Local Centre and northern parkland.
2.6 A Local Centre at the heart of the new community will provide for education facilities, community uses, shops and employment opportunities. A new station car park facility would be sited within convenient walking distance of Knockholt National Rail station, providing an opportunity to take on-street parked cars off London Road, and deliver compensatory improvements to the quality of this remaining part of currently-blighted Green Belt to the north of the site.
2.7 To the south and directly-adjacent to the new sports pitches are the Hockey Club Pavilion Clubhouse, the Rugby Club Clubhouse and the Primary School. The highest density of development is proposed around the Local Centre, offering the choice of smaller and affordable homes through areas closest to the Primary School and station. To the south and east, the density of development reduces, with the lowest density adjacent to the eastern boundary.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 8 The Development Potential of Stonehouse Park
2.8 The character of the development will be informed by varied density profiles and the various landscape settings. Along the green corridors, the development could have an arcadian character, whilst at the edges of the Local Centre and towards the west, the density of development could be more urban, and the green spaces more formal in nature.
2.9 A lattice of green corridors provide a highly-accessible and attractive network of footpaths and cycle paths, promoting sustainable travel through the development. The routes provide a permeable network that connect the open spaces, development areas, the station and, where possible, into the surrounding area.
2.10 The principal entranceways and approaches into the development are from two attractive and winding, tree lined avenues from London Road, that ascend the ridge through parkland towards the Local Centre and Sports Hubs. From the Local Centre a spine road connects tree-lined spaces and provides legible routes to access different parts of the new settlement. The access strategy is designed to discourage significant increases in traffic in nearby villages.
2.11 The landscape strategy proposes substantial areas of open space and sports pitches to the south, retaining a rural feel adjacent to the southern countryside boundary. The green corridors draw the landscape through the development towards the northern parkland, retaining areas of established trees and orchards where possible. The retained parkland forms part of the wider woodland that frames and contains the site.
Delivering a Genuinely Mixed-Use Scheme
2.12 National Government views the creation of new larger settlements as an appropriate mechanism for boosting significantly the number of new homes being built. This is reflected inparagraph 72 of recently-published revised NPPF. Rather than delivering new settlements via centrally-imposed development which occurred in the post-war period using the provisions of the New Towns Act (1946) and Town and Country Planning Act (1947), the onus is now on local communities and local planning authorities to bring forward their own vision for new settlements that are in the right location. In the case of Site MX41, the proposed development would create a sufficient number of new homes for the community to be broadly self-sustaining, and it would also accommodate the day-to-day facilities that new residents would need, without placing strain on existing local provision.
2.13 Moreover, the development would deliver a substantial amount of new employment and economic activity- generating floorspace and a host of community and leisure uses which cannot realistically be provided anywhere else in the District.
2.14 Thus, instead of placing reliance on the piecemeal and ad hoc development of urban periphery sites around the edges of existing settlements – adding to the already-significant pressure on infrastructure and entrenching car dependency because they are beyond reasonable walking distance from rail stations and local amenities – the allocation of Site MX41 would allow for a single, managed release of land which makes a critical contribution to the District’s social and economic needs. It would also make the land wholly accessible to members of the public, enabling them to make use of and enjoy what is currently private land serving no tangible planning benefit.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 9 The Development Potential of Stonehouse Park
2.15 The proposals for Site MX41 can deliver the following mix of uses, which would make this a highly- sustainable new settlement, and maximise the opportunities afforded by its proximity to a public transport hub. We would anticipate that this balance of uses could inform any future site-specific policy, and consider that this meets the Council’s requirement that Exceptional Circumstances sites should provide “social and community infrastructure which meets an evidenced need”:
• At least 750 conventional dwellings.
• A general boost in supply will ease affordability problems in one of the District’s least affordable wards. By delivering a genuine mix of new homes, in a range of sizes, types and tenure, this site would make it entirely possible for first-time buyers and young families to get a foot on the property ladder and remain in this District.
• As noted earlier in this Representation, we are finalising a contract of sale with Redrow PLC, one of the country’s leading housebuilders with a reputation for high-quality, to ensure that we have secured a pre-planning sales contract. This would enable any future planning application to include a detailed initial phase of housing (circa 250 homes in Phase 1), guaranteeing a significant level of supply very early in the plan period, and enabling the local planning authority to make a realistic assessment of likely rates of delivery. Based on discussions with Redrow’s Board, we are confident that this site will provide in the region of 75 - 100 new dwellings per annum.
• 40 per cent of these new homes would be affordable (a minimum of 320 dwellings), providing a secure supply and helping to meet an acute district-wide need for subsidised family accommodation in the new plan period. This would include new homes for affordable home ownership, in line with paragraph 64 of the NPPF. There would be a ‘double lock’ guarantee on the provision of affordable housing at this amount, given the prevailing policy requirement and our contractual agreement with Redrow. The precise tenure split can be agreed in discussion with the Council’s Housing Team and having regard to the Local Housing Needs Survey and corresponding SHMA.
• The general mix of proposed housing has been built around the needs identified in Sevenoaks District Council’s 2017 Local Housing Needs Study for the North West ‘Placemaking’ area. It can provide a balanced mix of bungalows, parish houses for individuals or families with a local connection, step-down accommodation for older persons, family-sized homes, one and two- bedroom homes for local first-time buyers, and affordable homes that are available for purchase as well as rent.
• At present, the density of the scheme would be in the region of 28 dwellings per hectare, which would reinforce the generally rural character of this part of the District, providing large areas of public open space and ensuring that each family home has a generous garden area. Providing a denser form of development on and adjacent to the Local Centre area, and having regard to draft Policy 12 of the emerging Local Plan, would enable Site MX41 to accommodate more new homes with no consequential planning, amenity or character disbenefits.
3 Sevenoaks District Local Housing Needs Study, 2017 4 As per paragraph 64 of the NPPF, at least 10% of the homes would be for affordable home ownership.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 10 The Development Potential of Stonehouse Park
• 100 self-build plots.
• Out of all the Kent authorities, Sevenoaks has the highest level of unfulfilled demand for self-build plots.
• Quinn Estates has delivered more self-build plots than any other developer in Kent, and with this unrivalled track record, we can ensure that from an early stage in the new plan period there is a valuable source of planned supply to help Sevenoaks District Council meet is statutory duties. Our schemes include Boughton Park, Hamill Park and Preston.
• A self-build scheme on this scale would make Sevenoaks one of the leading self-build plot providers in the country. It would mean that 100 self-build plots can be delivered in an 18-month period, offering new homes of exceptionally high design quality and providing a different source of supply. When combined with the conventional and extra care housing, this site alone can provide more than 300 completions in the first two years of construction, therebyaddressing the Government’s aspiration for accelerated housing delivery.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 11 The Development Potential of Stonehouse Park
• Extra Care and Warden-Supported Housing.
• By the end of the new plan period in Sevenoaks, there will be a 71 per cent increase in the number of residents aged 75+, and a 23.9 per cent increase in those aged 60-74. Unsurprisingly, the 2017 Local Housing Needs Study flags a requirement for more specialist accommodation for older people – a finding that echoes national studies into the need for carefully planned extra care and step-down accommodation.
• Sevenoaks’ existing stock of family-sized homes can be used far more efficiently if older people are given an attractive choice to downsize. This includes models of support which allow them to maintain independence, and it means an option to buy as well as rent.
• We have already secured multiple offers from market-leading providers of assisted and retirement living, which provides certainty of early delivery and it will also ensure that any planning application proposals can from the very outset reflect the optimum layout and configuration for this specialist housing. Based on detailed due diligence commissioned by these prospective providers, there is a very strong local requirement and demand for specialist housing on this site – particularly given its accessibility credentials and its ability to co-locate the specialist housing directly adjacent to shops, services and other community facilities.
• We are looking to provide a highly-attractive retirement village, with an area of four acres providing in the region of 70-beds’ worth of retirement accommodation (Class C3) and a 70-bed extra care / nursing care accommodation (Class C2), and spatially-disposed in a manner that helps to integrate the village with the wider scheme.
5 Self- build and Custom Housebuilding Act 2015 6 http://www.quinn-estates.com/residential-properties/boughton-park; http://www.quinn-estates.com/residential-properties/hammill-park 7 See, for example, LGA, Housing our ageing population, September 2017
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 12 The Development Potential of Stonehouse Park
• A Local Centre.
• Quinn Estates would retain a freehold interest in all of the non-residential land on this site to guarantee the delivery of buildings and infrastructure that might otherwise be less commercially- attractive to other developers. As we have done on large sites across Kent, we would build bespoke space for community facilities to ensure that: i. there is the guaranteed provision of social and community infrastructure so that future and existing residents can meet their day-to-day needs without having to travel off-site by unsustainable means (NPPF, paragraph 104); and ii. the buildings will be delivered to a very high specification and quality, with materials that ensure a consistency of character and appearance throughout the scheme.
• The Local Centre is likely to include a community hall, a café, a health club with a swimming pool, and small-scale retail units including a convenience store. We would look to provide around 25 apartments within the Local Centre area to ensure a mix of uses and activity. By locating these essential services at the heart of the new development, the number of car trips to nearby towns can be minimised.
• New medical facilities – including a purpose-built GP surgery and pharmacy – would be delivered to ensure that there is accessible, sustainable and high quality out-of-hospital care which aligns with the Commissioners’ strategy for local provision. Discussions with the CCG are ongoing to establish exactly what facility and model of operation is most appropriate on the site, however we would look to deliver a new on-site medical facility at no upfront capital cost to the taxpayer.
• Care will be taken to ensure that proposed uses do not pose a risk to the health and viability of services in nearby villages. Our focus will be to secure occupiers that complement - rather than compete - with the existing offer in and around Halstead, Badgers Mount and Pratt’s Bottom. We will also seek to encourage people traveling to the site to walk, cycle, travel by train, or take the bus.
• New Education Facilities, including Primary School, Early Years and SEN.
• At no cost to the taxpayer, this scheme would deliver new education facilities for the benefit of new and existing residents. It would also cater for latent demand for educational uses arising from other growth in this part of the District.
• Following discussions with KCC, we have planned for the delivery of a brand new Primary School. This would provide sufficient space for a 2FE facility. KCC has identified a need for this new provision; it would cater not only for internal demand generated by Stonehouse Park, but also for future population growth in the general vicinity / catchment of Site MX41.
• This facility would incorporate a ‘Specialist Resource Provisions’ to cater for KCC’s identified requirement for additional SEN resource in this part of the District. The facility would provide for 12 – 15 pupil places. This will create a highly-accessible education hub which delivers an integrated service for parents and children requiring specialist provision.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 13 The Development Potential of Stonehouse Park
• It would also accommodate a new Early Years nursery, which responds to an identified requirement by KCC.
• Given the general scarcity of development land across the district, we consider this to be a significant planning benefit.
• The scheme would provide s106 monies to fund planned expansion of secondary-level education provision at the Knole Academy, or a new facility to serve this catchment.
• As a complimentary use to be delivered alongside this educational hub, we can offer a supported housing scheme of around ten self-contained homes for vulnerable young people. This can provide purpose-built assisted-living accommodation for vulnerable and disadvantaged young people and their carers, immediately adjacent to the new Local Centre and the range of amenities that will be on offer. We would look to build these homes and transfer them to the competent authority with a virtual freehold.
House delivered on a Quinn Estates self-build site
8 Ian Watts, KCC Area Education Officer, North Kent Education Team; Nichols Abrahams, Strategic Programme Manager (Infrastructure)
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 14 The Development Potential of Stonehouse Park
• A Commercial Hub
• As highlighted in the Council’s latest Economic Needs Survey, there has been a lack of new-build office space over the past seven years. There is now a chronic under-supply of sites with development or extension potential, and existing employment areas are fully occupied.
• The Survey identifies the need for between 6.8 and 7.2 hectares of new B-Class land to meet future demand. The general analysis of market conditions also reveals “a strong level of latent demand for office floorspace” and the survey recommends the authority plan for sufficient new space to ensure choice for prospective occupiers and investors.
• Given the very constrained land supply position in this District, the study notes that the future requirement can only be met through new site allocations. These findings are reinforced by an Employment Demand Study that we commissioned Savills to undertake. This Report, which can be found at Appendix 5 notes, inter alia, that: “…there is a supply shortage and pent up demand from office occupiers (to include serviced office providers) for offices within the region and most notably within the Sevenoaks area. An office scheme in this location will be well sought after and will attract businesses from outside the district, who have dismissed the location in the past. This will bring additional employment to the region.”
• As part of our scheme, we are therefore proposing a cluster of employment-generating uses, with circa 2.1 hectares of employment land set-aside to ensure that this is a genuinely sustainable new settlement which generates economic benefits for the whole district. It will include shared office space in the region of 40,000 sq ft for start-up businesses, providing a unique environment which attracts local and inward investment into the Sevenoaks district (NPPF, paragraph 81). As noted earlier in this report, Quinn Estates is one of the leading providers of new commercial space in Kent, having delivered more than 2 million sq ft of commercial space through schemes such as Whitstable Road Business Park in Faversham, and Lakeview Park in Hersden. We have also completed the first phase of Ashford Commercial Quarter ‘Connect 38’, which will provide 80,000 sq ft of grade A space and kick-start the regeneration of this part of Ashford. This is Kent’s largest new office building to be built in the past decade.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 15 The Development Potential of Stonehouse Park
• There is an acute shortage of office floor space for local start-up businesses in the Sevenoaks district. Serviced offices that can accommodate smaller occupier requirements are particularly sought after, as demonstrated by the success of the nearby Polhill Business Centre which rarely has vacancies.
• Historically, Sevenoaks’ business growth has been relatively small, meaning that it has yet to take advantage of mechanisms like the business rate retention or participation in the Kent Pool. The District has also suffered from the loss of office stock through national permitted development rights allowing for a change of use from B1(a) to C3 Class. Although the absolute loss was small in the 2016/17 monitoring period , there are extant prior approvals that are likely to compound historic loses to further decline the district’s available office space. Development of new office space at this site would serve to address the current imbalance in B-class supply and boost the district’s tax base, with around £1.5m additional business rate revenues generated.
• This is the right location for modern business space and it meets the requirements set out in the Council’s Economic Needs Survey, and highlighted more recently by Savills, namely: i. it has unrivalled access to the District’s main arterial roads, including the A21 and the M25, meaning that accessibility to the highway network for business operations is quick; ii. it is within walking distance of a major public transport node (Knockholt National Rail station) with potential to link with existing bus services (such as the Arriva 402 service linking this part of the District with Bromley, Sevenoaks Town Centre, and Tunbridge Wells); iii. there would be car and secure cycle parking spaces for staff and customers unable to travel by public modes of transport; and iv. the commercial hub will be situated in the heart of a new mixed-community, providing a critical mass of employment uses and amenities, with no negative effect on the living conditions of future residents.
• Savills has been retained by Quinn Estates to provide ongoing advice on occupier demand for business space in this area. This will ensure that our scheme generates the new business space that the market requires, and that we secure significant pre-lets to create a genuinely sustainable mix of uses.
• In respect of the proposed business hub, we would be keen to explore with Sevenoaks District Council the option of a joint-venture delivery or ownership arrangement.
• A Gin Distillery / Cider Works.
• We have agreed terms with Chapel Down, the region’s premier wine and spirit-maker, to deliver a brand-new gin distillery / cider works. This will generate unique job and tourism opportunities, providing a boost to the District’s rural visitor economy (NPPF, paragraph 83(c)).
9 https://www.sevenoaks.gov.uk/downloads/file/1067/authority_monitoring_report_2017
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 16 The Development Potential of Stonehouse Park
• A Station Car Park.
• London Road is currently blighted by on-street parking that is unsightly and hazardous. Quinn Estates would build a new car park to take vehicles off the road and tidy this area up, creating betterment of retained Green Belt land in the vicinity of this site. It could provide the local authority with a valuable new asset and sustainable future income stream, to bolster its efforts to achieve financial self-sufficiency though its Property Investment Strategy. Our comprehensive package of off-site highways works would include a commitment to enhance the road with new surfacing, dedicated cycle lanes, and pedestrian crossing facilities to provide a seamless link with the station.
• Based on an all-day rate of £5.00, this asset could generate in the region of £400,000.00 per annum.
• A Sports Hub and Community Gymnasium.
• Quinn Estates would deliver purpose-built sports hubs for two of the District’s largest community clubs, providing unprecedented investment that aligns fully with the recently-adopted Council’s Playing Pitch Strategy and which delivers facilities benefiting the entire region. This would provide a major boost to the District’s sports offer, encouraging residents to get involved in leisure activities and improving their general health and wellbeing.
• An area of circa 7.7 hectares is currently set-aside in the masterplan to accommodate these sports pitches and associated club facilities. This will comprise purpose-built hockey and rugby complexes, and terms have been agreed with Sevenoaks Hockey Club and Sevenoaks Rugby Club.
• The facilities would be delivered by Quinn Estates and transferred to each Club on a 125-year lease for £1.00 (ie a virtual freehold). In both cases, we have committed to delivering the facilities for operational use before the occupation of the 75th dwelling, which would be reflected in a S106 Agreement. It is anticipated that this could be within 18 months of the grant of planning permission.
• Hockey Facilities
• We have signed Heads of Terms with Sevenoaks Hockey Club that, subject only to the grant of planning permission, commit us to delivering the following: • 3 England Hockey-standard Artificial Grass Pitches (‘AGPs’), including one ‘Category 1’ surface; • artificial lighting to serve the 3 AGPs; • a Clubhouse with external viewing balcony, changing facilities and lock-up facilities the minimum size of which will be 4,000 sq ft; • car parking adjacent to the clubhouse; and • boundary and safety fencing.
10 Sevenoaks District Council, Playing Pitch Strategy (April 2018), available at: https://www.sevenoaks.gov.uk/downloads/file/1145/playing_pitch_ strategy_-_april_2018
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 17 The Development Potential of Stonehouse Park
• The facilities meet the aspirations of the Club, they satisfy the evidenced-need set out in the authority’s Planning Pitch Strategy evidence-base, and they have the support of Sport England and England Hockey. This is one of England Hockey’s ‘big clubs’ owing to the size of its membership and its growth potential. Despite playing in the country’s highest leagues, the Club is being held back by inferior facilities which limit game and training time.
• This scheme therefore has the potential to deliver one of the best purpose-built hockey facilities in the South East, with a community user agreement ensuring that all local residents benefit from this major investment in Sevenoaks’ leisure offer.
• Rugby Facilities
• We have signed Heads of Terms with Sevenoaks Rugby Club that, subject to the grant of planning permission, commit us to delivering the following: • 2 RFU size-compliant pitches (1 will be a grass pitch and 1 will be an Artificial Grass Pitch suitable for rugby use); • rights to use 2 junior-sized grass pitches outside of school hours; • a 2,500 sq ft Clubhouse with changing facilities and lock-up facilities; • car parking adjacent to the clubhouse; and • boundary fencing.
• The junior pitches would be operated by the Club but reserved for use by the Primary School during school hours. This will ensure that the scheme is making the very best use of land possible (NPPF, paragraph 118), and it minimises the school’s exposure to ongoing maintenance costs.
• A new health club / gymnasium would also be provided on-site to encourage new residents – and those already living in the vicinity of the site – to participate in recreational activities, including swimming-based activity. It would include studio space to meet general undersupply across the District, and these would provide a versatile space for a range of activities such as fitness and dance classes, yoga, pilates, martial arts and boxing.
• It is possible that the new Primary School hall can provide additional indoor capacity to cater for these sports like gymnastics or trampolining, with the possible addition of basketball nets to provide additional capacity for the growth of the Sevenoaks Suns Basketball Club’s junior outreach programme.
• The masterplan accommodates the sports hub areas at the western and southern areas of the site. Accordingly, a significant proportion of this part of Site MX41 would remain in use as a definitionally ‘non-harmful’ Green Belt use, with any artificial lighting specified to minimise excessive spill or amenity concerns.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 18 The Development Potential of Stonehouse Park
• Open Space and Biodiversity
• The latest iteration of the Illustrative Masterplan retains a substantial arc of green open space which will define its northern boundary in perpetuity. We would be willing to gift this land to the Parish Council or else provide a legal covenant restricting any future development on this part of the site. This would safeguard against any perceived prospect of future coalescence with Greater London.
• Across the wider site, to maintain the open character and provide opportunities for biodiversity enhancement, the masterplan sets aside more than 15 hectares as formal and informal public greenspace. This is considerably in excess of the prevailing guidance and Fields in Trust recommendations and it will give the general public full access to land which is currently private, which cannot legally be enjoyed by local residents, and which serves a very limited public good. The open spaces will incorporate formal play areas for young people, with provision in full accordance with draft Policy 19 which requires LAPs, LEAPs and NEAPs.
• We would also set-aside an area for new allotments, to give residents the opportunity to grow their own produce.
• As set out in the Ecology Report prepared by Aspect Ecology, there are valuable opportunities to enhance the site’s biodiversity credentials, and we would look to achieve this via a masterplan that provides generous areas of natural greenspace and new fauna habitats. The prospect of improving biodiversity represents a planning benefit of significant positive weight given the site’s current use as a heavily-manicured and treated golf course (Appendix 6).
11 Phil Webb, Sevenoaks Suns Basketball Club 12 See Sevenoaks District Council’s Open space, sport and leisure study.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 19
Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
3.1 The consultation has posited nine topics where additional information is required in respect of Site MX41. The table at Appendix 1 of the draft Local Plan states:
• It needs to be demonstrated that the proposed social and community infrastructure meets an evidenced local need;
• Confirmation needed from Bromley CCG that the provision of health facilities in this location is supported;
• Confirmation needed from education providers that facilities in this location are supported;
• Confirmation needed from KCC Highways that the highway network has sufficient capacity to accommodate this scale of development, and whether any improvements are required as part of the proposed scheme;
• Confirmation needed from Network Rail whether the proposed improvements are reasonable and supported;
• Confirmation needed from Highways England that the proposed development will not have an adverse impact on the strategic road network;
• Ecology and landscape assessments required;
• Inclusion of site subject to agreement of Sport England with regard to proposed sports facilities; and
• The loss of the existing use needs to be addressed.
3.2 In this section of our representation, we provide a response to each of these questions. We are currently undertaking an iterative masterplanning process, and the spatial configuration of uses – and indeed the type of quantum of uses – is under constant review to ensure that the design takes full account of the feedback we are obtaining from statutory consultees, advisory bodies, and members of the general public.
It needs to be demonstrated that the proposed social and community infrastructure meets an evidenced local need
3.3 One of the most unique attributes of the Stonehouse Park proposal at Site MX41 is its ability to provide new social and community infrastructure at no upfront cost to the taxpayer. The site is owned by a subsidiary arm of Quinn Estates, meaning that an unprecedented amount of the ‘land value uplift’ is being re-invested in a genuinely mixed-use scheme that caters for the needs of new and existing residents of the District.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 22 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
3.4 The current components of the scheme are being promoted on the basis that there is either a current need for new facilities, or that the development of Site MX41 would in itself generate a demand for the new facilities. In other words, there are some elements of the proposed social and community infrastructure that are primarily geared-towards making this new settlement a very sustainable one. We summarise the needs case for the scheme’s non-residential infrastructure in Table 2.1 below, alongside an indication of the planned phasing. This phasing strategy, which can be reflected in site-specific policy or else secured by way of a s106 agreement obligation(s), is purposely-designed to ensure the timely delivery of non-residential uses so that this site is genuinely mixed-use from the very start of any build-out.
The Infrastructure The Need Phasing
Hockey Facilities Sevenoaks Hockey Club is one of the largest in the Country, Operational within with more than a thousand members, and 31 active teams, 18 months of comprising 11 men’s teams, 8 women’s teams and an commencement extensive junior section with boys’ and girls’ teams ranging from U10s to U18s. It is also a fast-growing club, with ambitions to expand significantly both its senior and junior sections.
It is likely that this Club alone will consume the calculated projection of significant future growth in hockey – estimated at an additional six teams.
For more than half a century, Sevenoaks Hockey Club has been seeking to secure a permanent home with facilities that are fit-for-purpose. It has undertaken exhaustive searches for additional land, because the historic and current arrangements for playing and training are not satisfactory given the Club’s size and the level to which it competes.
The Club is currently operating from six separate facilities – none of which it owns (Hollybush Lane, New Beacon School, Sevenoaks School, Trinity School, Whitgift School and Tonbirdge School). Amongst other limiting factors, this means that parents must drop-off their children at multiple pitches, leading to car ferrying that is both inconvenient and environmentally unsustainable. Its principal pitch as Hollybush Lane is at full capacity in terms of usage, and the changing facilities at the Vine Pavilion are limited and are not fit for purpose given the high playing ambitions of the Club.
13 Sevenoaks District Council, Playing Pitch Strategy, March 2018, P.120
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 23 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Hockey Facilities The pressing need for new facilities for the Club is set out Operational within in the Council’s Playing Pitch Strategy (2018), which states, 18 months of inter alia, that: commencement
“The quality of provision across the local authority for hockey is not sustainable, given the high and growing demand for hockey in Sevenoaks and Surrounds and the ageing stock of pitches. Sevenoaks Hockey Club represents the majority of demand for hockey in the District and continues to grow.
“There are not sufficient secured and available sites for community use hockey, with clubs being required to use a combination of sites to meet the demands of club members, some of which are unsecured for community use. Local clubs have identified an issue with securing suitable facilities at the times they are needed, especially for weekend matches and training when education facilities have restricted community use.
“…Projected growth indicates that unless the current situation changes, there is going to be a significant under supply of pitches in Sevenoaks, and in Sevenoaks and Surrounds in particular.”
“Due to the poor quality of existing provision, and the lack of floodlighting at certain key facilities, the current pitch stock will not meet future need. However, a programme of reinvestment to provide better, more versatile facilities (in terms of when they can be used) will help to address this need and help to provide an adequate supply of pitches in the medium term.…”
The relevant National Governing Body, England Hockey, has signalled its support for the proposed hockey facilities, and this can be found in the Sport England correspondence provided at Appendix 7.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 24 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Rugby Facilities Sevenoaks Rugby Club has identified an urgent need for Operational within new training space to develop its players – particularly 18 months of its youth players. The Club supports 170+ qualified commencement coaches and a total of 19 teams, including 14 youth teams comprising around 900 junior members. The Club currently operates from The Paddock, which is owned by Sevenoaks Town Council and therefore there is limited security of tenure and limitations on its ability to generate revenue or procure RFU funding.
At present, the Club’s popular Sunday morning training sessions are significantly oversubscribed relative to the pitch space available, often meaning that junior groups of 50+ have to train on a third of a pitch. This limits the Club’s ability to expand and recruit new members, and it also compromises coaching sessions. Moreover, the need to hire pitches ‘off-site’ incurs additional costs for the Club and it also causes logistical difficulties, with parents having to be informed of a training venue location at very short notice.
The Paddock would remain the Club’s principal match- playing facility, however the training pitches on Site MX41 would significantly reduce the wear-and-tear subjected on its game-day pitch. Th provision of a state-of-the-art rugby- specific 4G pitch would also enable year-round training including in adverse weather. At present, the option of an artificial pitch at The Paddock is currently not feasible, and even if one were to come forward, the Club would not have full control of the facility due to land ownership.
The Council’s Playing Pitch Strategy states that The Paddock is operating well beyond its operational capacity. It also concludes that there is an undersupply of rugby pitches in the District, and that there is a particular deficit in the provision of dedicated junior-sized pitches.
The relevant National Governing Body, the Rugby Football Union, has confirmed its full support for the new rugby facilities, and this can be found in the Sport England correspondence provided at Appendix 7.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 25 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Station Car Park As noted earlier in this representation, London Road is Operational within currently blighted by on-street parking that is unsightly and 18 months of hazardous. There is an opportunity through the allocation commencement of Site MX41 to secure new infrastructure that delivers much-needed improvements to this well-used road, as well as providing significant visual and environmental betterment to this adjacent area of Green Belt
By delivering a station car park in an early phase of development, a substantial amount of daily footfall can be channelled through the Local Centre area. This would instantly make it a commercially-buoyant area and bolster the prospects of new shops and community facilities coming forward earlier than if they were reliant principally on the trade and patronage of new residents.
The car park forms one part of a package of measures that we would look to implement to ensure that residential of – and visitors to – Site MX41 can make best use of Knockholt National Rail station.
Local Centre Site MX41 is undoubtedly a suitable and sustainable Buildings Small-scale Retail location for a new settlement, however a Local Centre operational / let Primary Care will ensure that it accommodates a sustainable form of within 18 months of centre development, which benefitsnew and existing residents. commencement Health Club In additional to the small-scale convenience retail units, the GP Practice café, community hall, and a health club with a swimming transferred to CCG pool, we would look to build a Primary Care health facility / NHS PS within to ensure that everyone at and in the vicinity of this site 24 months of has easy access to a GP. The pressing need for additional commencement healthcare capacity in this part of the District is set out in more detail later in this representation, and we are in dialogue with the local CCGs to ensure that they tight type of medical provision is made.
14 Sevenoaks District Council, Playing Pitch Strategy, March 2018, P.112
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 26 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Business Hub There is a clear and evidenced need for between 6.8 and Buildings available 7.2 hectares of new Class B1a/b employment land in the for pre-letting prior coming Local Plan period. This can only be realistically met to planning and through new site allocations. built in-line with occupier demand. Site MX41 is uniquely-positioned to accommodate a proportion of this requirement, and crucially it can provide new employment floorspace that is attractive to the market. As the report by Savills concludes:
“[MX41] is an appropriate location for modern business space and it meets the requirements set out in the Council’s Economic Needs Survey, namely:
• It has unrivalled access to the District’s main arterial roads, including the A21 and the M25;
• It is within walking distance of a major public transport node (Knockholt National Rail station) with potential to link with existing bus services (such as the Arriva 402 service linking this part of the District with Bromley, Sevenoaks Town Centre, and Tunbridge Wells);
• There would be car and secure cycle parking spaces for staff and customers unable to travel by public modes of transport; and;
• The commercial hub will be situated in the heart of a mixed-community, providing a critical mass of employment uses and amenities.”
We are proposing modern shared office space which will attract inward investment and generate economic growth. The buildings will be exceptionally high quality in terms of their aesthetic and their energy performance. They will also be serviced with the modern infrastructure that occupiers require – for example high-speed broadband – and workers will be able to enjoy the amenities of the surrounding area, including the Local Centre facilities and the parkland open spaces.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 27 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Primary School The Local Education Authority has confirmed that there is a Prior to occupation need for a 2FE Primary School at this site, to accommodate of the 150 dwelling demand generated by the scheme itself, and also to serve latent demand from general growth in this part of the District.
A letter from Kent County Council’s Children, Young People & Education division can be found at Appendix 8.
Early Years and The Local Education Authority has confirmed that an Early Prior to occupation SEN Years facility needs to be provided alongside the Primary of the 150 dwelling School to ensure that parents have convenient access to childcare. Officers have indicated that a larger facility than originally anticipated would be sought, and we would be willing to facilitate this through the provision of adequate land and capital cost contributions.
The authority has also requested that a maintained SEN facility be delivered on-site, alongside the new primary School. Again, given the very pressing need for high quality learning facilities for those with special educational needs, we would be keen to work with KCC to deliver a state-of the-art SEN facility on-site.
Care Home As set out earlier in this representation, it is imperative that Built within and Warden- the new Local Plan sets aside sufficient land for specialist 36 months of supported elderly care facilities, as well as maximising the delivery of commencement Accommodation accommodation that is suitable for older residents looking to downsize or maintain independence through step-down supported housing. These requirements permeate the draft Local Plan and its supporting evidence base.
At Site MX41, there is the potential to meet these needs. Given the mix of uses that would come forward at this site, we believe that there is an opportunity to ensure that older residents become an integral part of the scheme’s vision. For example, co-locating the care facilities near to the shops and community facilities will encourage older residents to remain active, maintain their independence and socialise. There will also be significant opportunities for interaction with the new sports hubs.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 28 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The Infrastructure The Need Phasing
Gin Distillery / This site can utilise land on its north-eastern corner to Within 36 months of Cidery deliver a world-class gin distillery or cidery for Chapel commencement Down. This firm is an award-wining drinks producer that can inject a unique boost in the area’s tourism and economic profile.
The facility would give a new settlement at Site MX41 a unique identity, whilst securing inward investment and new job opportunities.
Self-Build Plots In Sevenoaks District there is a very strong demand for self- Plots serviced and build homes, with more registered interest than any other available within authority in Kent. Within a 10-mile radius of this site, there 12 months of are more than 1,110 people registered with the Custom Build commencement Register and 2,762 registered with PlotSearch.
Quinn Estates has a proven track record delivering new Self-Build plots across Kent, and we therefore have the experience necessary to ensure that Sevenoaks’ residents are given the opportunity to build their own homes.
Parkland and The former golf course land is not crop-producing, it is Ongoing from Open Space largely inaccessible to the public, and it serves limited commencement public good.
The redevelopment of this site would allow for substantial investment in creating a highly-attractive parkland that is accessible and can be used for recreational and social purposes. This will include a strategy that carefully incorporates the existing mature trees within the masterplan design, whilst planning for a substantial programme of landscape enhancements within and around areas of built development.
A management trust would ensure the long-term stewardship of the parklands to safeguard the scheme’s appearance and the variety of ecological enhancements that will be implemented from the outset of any works.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 29 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
3.5 As set out earlier in this section, given that this site would accommodate a new settlement, it is not strictly a case where new social and community infrastructure meets an evidenced local need that is wholly existing. Instead, there will be facilities and services that cater for new demand arising from a growth in local population. The proposed Primary School, SEN and Early Years provision is a case in point; whilst it would provide a consolidated offer for existing and new education demand in this catchment, a need for around one-form of entry would arise from the new housing on this site. In other words, by promoting growth through the managed release of a new settlement, the Local Planning Authority can take comfort that new population growth will have minimal net impact of existing service provision or infrastructure capacity.
3.6 It is also important to note that new homes are in themselves a fundamental part of social and community infrastructure. Without an adequate and deliverable supply of new homes, the most basic of planning requirements cannot be met and this would have wide-ranging consequences for the District: families in need of a home will have less choice; local house prices will continue to rise unsustainably; unsustainable travel patterns will emerge; employers will be unable to attracted appropriately-located labour; young people will struggle to afford a home in the vicinity of their families; and first-time buyers will remain unfairly penalised and kept off the property ladder.
3.7 The allocation of Site MX41 can therefore achieve a multitude of planning benefits that meet the needs of Sevenoaks District. It guarantees the supply of new and affordable homes, it secures investment in local transport, educational and health infrastructure, it would deliver economic-generating space, and it will create a genuinely sustainable new community, with exceptional access to services, employment opportunities and leisure facilities.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 30 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Confirmation needed from Bromley CCG that the provision of health facilities in this location is supported
3.8 The Local Centre will accommodate new medical facilities – most notably a purpose-built GP surgery and pharmacy – to ensure that there is accessible, sustainable and high quality out-of-hospital care for new residents and those existing residents in the vicinity of the site which could utilise the new facility and thus ease pressure on existing practices.
3.9 Quinn Estates is currently in discussion with NHS Bromley Clinical Commissioning Group to agree the future operation of a new on-site Primary Care facility. A letter from the NHS Bromley Clinical Commissioning Group’s Programme Director is provided at Appendix 9. Given that Site MX41 is located on the very edge of the administrative boundaries of NHS Bromley Clinical Commissioning Group and NHS West Kent Clinical Commissioning Group, it is likely that both organisations will need to be consulted in relation to any proposed redevelopment at this location. We are therefore in discussion with the NHS West Kent Clinical Commissioning Group, too, and a letter from the Programme Director can be found at Appendix 10.
3.10 Mirroring the delivery model of the Estuary View and Chestfield medical centres in East Kent which we built in partnership with George Wilson, we intend to build a ‘turn-key’ facility, which would then be transferred at nil cost to be owned and managed by the appropriate public health providers. The exact type and size of facility will be agreed in consultation with NHS Bromley Clinical Commissioning Group, following a review of exiting capacity of the surrounding GP practices, and the ability of these facilities to cope with additional growth from this potential development. At this stage, we have made an allowance for a medical building of up to 10,000 sq ft, with associated staff and patient parking. This would provide for purpose-built consulting and examination rooms, a comfortable waiting area, office and amenity space for staff. At detailed-design stage, we would look to site the facility in such a way that there is an ability to expand the facility in future years, should the need arise.
3.11 In order to assess for ourselves existing local demand for a new facility, we have been in discussion with the Senior Partner of the nearest Primary Care practice at the Green Street Green Medical Practice, in Orpington. Although the Practice is unable to ‘close’ the patient list, they consider it to be operating beyond full capacity with no space or facilities to accommodate any further increase in the list. In respect of future expansion options, the practice’s conclusion is that:
“In our case it is not a question of recruiting more doctors because we simply do not have the space. From talking to colleagues locally I am aware that they too consider their lists to be ‘full’.”
3.12 Thus, whilst it is not possible at this stage to confirm the full support of NHS Bromley Clinical Commissioning Group, there is an irrefutable need for new medical facilities in this location, and there is no reasonable prospect for expanding the relevant Orpington practices. By incorporating new and purpose-built D1 space in the local centre, we can privately-fund capital investment in a brand-new GP practice, and make the facility easily accessible to new residents of Stonehouse Park and also those patients travelling to the practice from further afield.
15 http://www.gsgmc.co.uk/
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 31 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Confirmation needed from education providers that facilities in this location are supported
3.13 We have maintained a close dialogue with Kent County Council’s Children Young People & Education division and met on several occasions with the North Kent Education team. This has enabled us to determine and agree with Education Officers the appropriate type of education facilities that need to be accommodated on-site.
3.14 On the basis of these discussions, the education offer would comprise the following: • circa 1.7 hectares of land would be set-aside for a new Primary School; • the Primary School would have capacity for two forms of entry – the equivalent of 1FE would be generated through the new on-site residential dwellings, and a further 1FE would serve to bolster local supply so that the infrastructure can cope with latent demand arising in the vicinity of the site; • the Primary School would integrate specialist-built space for SEN provision for 12 – 15 pupils, catering for existing demand in the local catchment, and any new demand that may arise from the scheme itself; • the Primary School would also incorporate space for Early Years provision for at least 26 places – again, this would cater for existing demand in the local catchment, although we envisage that it would principally consume demand arising from the scheme; and • the siting of the Primary School land would be adjacent to the junior rugby pitches, to facilitate a pitch-sharing arrangement that maximises the efficient use of land, and minimises an ongoing revenue expense in terms of playing field upkeep.
3.15 Given the scarcity of development land across the District, the prospect of land for a new school is supported by the Local Education Authority, as evidenced by the letter found at Appendix 8 of this representation.
3.16 Kent County Council is willing, in principle, for the Primary School to be built by or on behalf of Quinn Estates. This would allow for a bespoke and high-quality building that mirrors the design vernacular of the wider scheme. However, in the event that a land transfer is the preferred delivery method of choice, Quinn Estates would ensure that a regular-shaped parcel of sufficient size is transferred to the Local Education Authority in a manner that complies with the ‘General Site Transfer Terms’ found at Appendix 11, and serviced in accordance with the ‘Service Requirements’, found at Appendix 12.
3.17 As agreed with the North Kent Education team, in the event that KCC elect to procure the new Primary School, a monetary contribution towards the capital costs would be phased as follows to guarantee its early delivery: • £150,000.00 payable on commencement of development (to cover design costs); • 50 per cent upon 50 occupations or within 1 year of commencement (whichever is sooner); and • balance upon 100 occupations or 2 years after commencement (whichever is sooner).
3.18 The Primary School would be built and operational as a 1FE facility prior to the occupation of the 150th dwelling, meaning that this essential new infrastructure will be in situ form a very early stage in the build programme and available to new families moving in.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 32 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
3.19 Any future development at Broke Hill would be required to make an appropriate contribution towards off-site Secondary School provision. The amount would be calculated on the basis of the prevailing tariff, and payments made as follows: 50 per cent upon 25 per cent occupation and the remaining 50 per cent upon 50 per cent occupation. These monies would bolster provision at Knole Academy or else be pooled to fund a new facility to serve this catchment of the District. The principle of an appropriate contribution towards off-site provision has been agreed with the Local Education Authority, and we would look to work with the schools to implement an effective and sustainable means of transporting students to and from these institutions.
House delivered on a Quinn Estates self-build site
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 33 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Confirmation needed from KCC Highways that the highway network has sufficient capacity to accommodate this scale of development, and whether any improvements are required as part of the proposed scheme AND Confirmation needed from Highways England that the proposed development will not have an adverse impact on the strategic road network
3.20 PBA has been retained to provide expert advice on highways capacity and the package of works that must be proffered to mitigate the effects of traffic that could be generated by the allocation and subsequent redevelopment Site MX41. It is also advising on ways to minimise the use of cars, by encouraging new residents, workers and visitors to walk or cycle in and around the site (NPPF, Chapter 9).
3.21 The site is located in a part of the District that is not generally constrained by a lack of highways capacity at the local or strategic network level. A detailed Technical Note by PBA has been prepared to assess the potential effects of the scheme, and this can be found at Appendix 13. The note has been informed by detailed surveys and modelling work, the scope of which have been agreed in dialogue with Sevenoaks District Council, Kent County Council, Highways England, TfL and LB Bromley.
3.22 In short, based upon the evidence assembled to inform a full Transport Assessment for Site MX41, there are no highway capacity issues that could not be mitigated, and transport infrastructure would not in any way impede the timely delivery of a new settlement at this location. For a site of this size, there are surprisingly few highways impediments and therefore we are looking at additional opportunities to invest in sustainable highways transport infrastructure serving the site and surrounding area.
3.23 A letter from KCC Highways can be found at Appendix 14 and it states that the Highways Authority would have no objection to the principle of the allocation of Site MX41, subject to further technical work that would be incorporated into a full Transport Assessment..
3.24 A letter from Highways England can be found at Appendix 15, which confirms that the site is unlikely to have a material effect on the operation of the Strategic Road Network. This contrasts with other parts of the District where the adjacent trunk roads suffer from congestion.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 34 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Confirmation needed from Network Rail whether the proposed improvements are reasonable and supported
3.25 The proximity of Site MX41 to Knockholt National Rail station makes Stonehouse Park a unique proposition at a unique location. This station falls within Transport for London’s zonal fare system (Zone 6), meaning that members of the public can use this station to gain direct travel across London’s public transport network using Oyster or a zonal travelcard. This gives future residents easy and affordable access to Central London, with a season ticket (including London Travel Card) costing less than £2,500.00.
3.26 In addition, travellers can make the short eight-minute journey to Sevenoaks and change for one of the many ‘fast’ services to London and other destinations such as Tonbridge and Hastings, or onto the Thameslink line. Based on the Government’s Train Service Requirement from 2022 this station will continue to benefit from services stopping a minimum of twice per hour, regardless of the franchisee. That document also indicates the possibility of additional train paths which could be served if the franchisee chooses.
3.27 In accordance with paragraph 138 of the National Planning Policy Framework, the managed release of this land would facilitate a highly-sustainable pattern of development through the re-development of land that is very well-served by public transport. Focusing a significant quantum of the District’s future growth requirements at a new settlement in an inherently-sustainable location is a far more effective means of guaranteeing not only delivery, but also a balanced and well-planned scheme. Unlike the ad hoc approach of piecemeal growth to existing settlements across the District, the Stonehouse Park proposals for Site MX41 can be designed from the outset to create a place where occupiers travel in and around their community by sustainable means of travel. This would require the delivery of genuine opportunities to live, be educated, shop and work on the site, with routes that are purpose-built for walking and cycling as the primary mode. This was a major focus of the initial Design South East workshop, and the masterplan will continue to evolve to maximise the site’s accessibility and permeability.
3.28 As part of a comprehensive package of off-site works to make this site function as a successful new place, and to encourage travel across the District by train instead of car, we envisage providing enhance linkages with Knockholt National Rail station, including through a new pedestrian / cycle crossing.
3.29 Given the potential for increased patronage for the adjacent station, we are in detailed discussion with Network Rail’s South East Asset Protection Team to agree a funding package for improvements to the station’s aesthetic and facilities. We have signed a ‘Basic Service Agreement’ with Network Rail to facilitate this dialogue, and any future planning application would set out in detail the proposed access arrangement between the site and the station, as well as the station improvements that will be delivered by Network Rail and the relevant Train Operating Company. An email from Kent Asset Protection Team Manager can be found at Appendix 16.
16 HM Government, South Eastern Train Service Requirement from December 2022, available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/662871/sef-itt-attachment-a-train-servicespecification.pdf
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 35 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Ecology and landscape assessments required
3.30 Any planning application for the redevelopment of this land would be accompanied by a full Environmental Impact Assessment, which would incorporate an Ecological Impact Assessment and a Landscape and Visual Impact Assessment (‘LVIA’).
3.31 To demonstrate that the comprehensive redevelopment of Site MX41 is likely to be satisfactory in both regards, this Representation is accompanied by an Interim Baseline Ecological Assessment, prepared by Aspect Ecology, and a draft Landscape and Visual Appraisal Issues Report, prepared by DWLC. These Reports are found at Appendix 6, alongside an additional technical note by PBA, which deals with matters such as drainage and ground conditions.
3.32 The scope of the ecological assessment is in accordance with relevant guidance (namely BS 42020:2013) and will be agreed with Kent County Council’s Ecological Advice Service through their formal pre-application service. Although Aspect Ecology has not formally approached Natural England in respect of scoping, there is unlikely to be a locus for its involvement given that the nearest SSSI is 2km from the site, and there are no European-designated site within a 15km radius.
3.33 We envisage that the final LVIA would be progressed in dialogue with the appropriate planning officer, and that meetings during at the pre-application stage would enable both parties to agree methodology, a schedule of viewpoints, and the basis for an effective landscaping strategy.
3.34 As is evident from the latest masterplan, we are looking to retain mature trees and provide exceptionally high-quality open parkland spaces for people to enjoy and for wildlife to flourish. In the region of 15 hectares of land will remain entirely free from any built development, and fully accessible to the public.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 36 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Inclusion of site subject to agreement of Sport England with regard to proposed sports facilities
3.35 Quinn Estates has been in regular discussion with Sport England about the redevelopment of this site (Appendix 18). The proposed leisure offer has been informed by a careful analysis of the District’s existing sports offer. An area of circa 7.7 hectares is set-aside in the currently masterplan to accommodate sports pitches and associated club facilities. This will comprise purpose-built hockey and rugby complexes. In other words, more than 10 per cent of the site is reserved for outdoor sporting uses which are definitionally- appropriate in Green Belt policy terms (NPPF, paragraph 145).
3.36 The facilities would be delivered by or on behalf of Quinn Estates and transferred to each club on a 125- year lease (ie virtual freehold) for £1.00. This would give both clubs security of tenure and they can use these assets to generate a sustainable flow of revenue. In both cases, we have committed to delivering the facilities for operational use before the occupation of the 75th dwelling, which would be reflected in a S106 Agreement. It is anticipated that this will be within 18 months of the grant of planning permission. This represents an unprecedented level of capital investment in the District’s sporting offer, which would boost the regional standing and growth-potential of these very popular clubs.
3.37 The facilities proposed for Sevenoaks Hockey Club are supported by the relevant National Governing Body, England Hockey. The facilities proposed for Sevenoaks Rugby Club are supported by its relevant National Governing Body, the Rugby Football Union. Accordingly, Sport England has agreed to the proposed sporting facilities that are being promoted at site MX41.
3.38 The sporting offer would be augmented through the on-site provision of a modern gymnasium, and the Primary School is also highly-likely to provide an additional source of leisure space that is accessible to the local community.
3.39 In additional to traditional pitch-based sports, it is important to note that the layout and configuration of this scheme is being informed by a desire to foster healthy and active lifestyles. This is increasingly becoming recognised as a vitally-important component of successful town planning. In particular, through the design process we are looking to site day-to-day services to encourage residents and workers to walk or cycle, instead of relying on short car trips. This will include trim trails and an extensive network of quality cycle and walking routes to increase levels of outdoor exercises.
17 https://www.england.nhs.uk/ourwork/innovation/healthy-new-towns/
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 37 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
The loss of the existing use needs to be addressed
3.40 The previous golf club operation on this site was terminated because the business was unviable and operating at a year-on-year loss. The Audited Financial Statements of Broke Hill Golf Club Limited for the financial years 2013-14, 2014-15, 2015-16 and 2016-17 are available on request. These show that the former golf course was operating with significant annual losses, with modest membership levels unable to sustain the business.
3.41 According to England Golf, participation in this sport has decreased significantly over recent years due to increased competition, declining loyalty, peoples’ time constraints, and the perception that golf does not offer value for money. Golf Club memberships have fallen by nearly 30 per cent since 2004, and it is only in the 65+ age category that participation rates have remained stable – indicating that golf remains a difficult sport to participate in for those seeking to balance leisure and work. Junior and woman participation rates also remain poor in absolute and relative percentage terms, too. Broke Hill has been no exception to this trend, and it experienced dwindling membership which rendered its operation unviable; consequently, although this site’s established use is as a sports facility, the sports provision is not used to the extent that is desired and viable. Accordingly, England Golf and Sport England is not objecting to the loss of the existing use of the site.
3.42 In this particular part of the District, there is a general oversupply of golf courses relative to current participation levels and the total amount of expenditure available. This is acknowledged by England Golf in its formal response to Sport England, which comments on the two golf courses in this District subject of a potential draft allocation (Appendix 17). To illustrate this point, we have listed below and show in Figure 3.1 that there are 16 conventional golf courses operating within a 10km radius of Site MX41:
• Chelsfield Lakes Golf Course (0.32 km); • Bromley Golf Centre and Driving Range (8.04 km); • Chislehurst Golf Club (9.6 km); • High Elms Golf Course (4.8 km); • West Kent Golf Course (6.4 km); • Cherry Lodge Golf Club (6.4 km); • Park Wood Golf Club (9.6 km); • Westerham Golf Club (8.04 km); • Knole Park Golf Course (9.6 km); • Wildernesse Golf Course (9.6 km); • Darenth Valley (4.8 km); • Woodlands Manor Golf Course (8.04 km); • Lullingstone Park Golf Course (3.2 km); • Pedham Golf Centre (6.4 km); • Cray Valley Golf Club (6.4 km); and • Birchwood Park Golf and Country Club (8.04 km).
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 38 Further Information on MX41, Land at Broke Hill Golf Course, Sevenoaks Road, Halstead
Figure 3.1 – Location of golf course within 10km radius
3.43 In the interests of transparency, the Audited Financial Statements of Broke Hill Golf Club Limited for the financial years 2013-14, 2014-15, 2015-16 and 2016-17 can be found atAppendix 19.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 39 The Exceptional Circumstances Case for Site MX41
4.1 Sevenoaks is located in the Metropolitan Green Belt and, together with AONB, SSSIs and Ancient Woodland, Green Belt covers about 93% of the District and wraps tightly around the outer edge of many of the District’s towns and villages. All of these designations disengage the NPPF’s presumption in favour of sustainable development.
4.2 Whilst the NPPF places a very strong emphasis on the development of brownfield land, Sevenoaks’ urban areas are mature with few obvious development opportunities. The local planning authority also needs to take care to ensure that other land uses that are essential to the sustainability of urban life, for example retail and employment, are not sacrificed to meet the immediate imperative of delivering a significant number of much-needed homes.
4.3 The Metropolitan Green Belt was first formally proposed by the Greater London Regional Planning Committee in 1935, “to provide a reserve supply of public open spaces and of recreational areas and to establish a green belt or girdle of open space”. However, it was not until 1947 when the Town and Country Planning Act allowed the local authorities to include green belts in their town plans. It was a Conservative Minister of Housing, Duncan Sandys, who finally implemented them in 1955. This was not as a relatively narrow band of park land around London to provide public open space and recreation, as per the original vision, but rather as a barrier to London’s expansion. The Minister “indicated that even if…neither green nor particularly attractive scenically, the major function of the Greenbelt was…to stop further urban development”. It was also intended to promote urban renewal, ie the redevelopment of inner-city slums by cutting off the supply of greenfield sites.
4.4 Over the 1950s and 1960s London’s Green Belt expanded so that it now extends to well over three times the area of the GLA boundary, covering most of Surrey and Hertfordshire, extending up to Aylesbury to the west and encircling Southend to the east.
4.5 Since the war the terrible slum conditions in London have been eradicated but despite the continued focus on brownfield development, there remains a pressing and unmet need for new homes, not least because England’s population has increased by 40 per cent since 1951. That pressing need extends far beyond London’s boundary, principally because of good and quick train services to the capital. However, such has been the ‘sprawl’ of the Green Belt itself that many surrounding districts find themselves unable to meet their own housing needs without amending Green Belt boundaries – even where the Duty to Cooperate has been exhaustively worked through.
Establishing ‘Exceptional Circumstances’
4.6 It has never been the case that the Green Belt was an ‘untouchable’ entity. Planning policy and guidance (for example in PPG2 and PPS2, as well as in the 2012 version of the NPPF) has always included provisions for Green Belt boundaries to be altered and the consistent requirement has been that this is done through the development plan preparation process.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 40 The Exceptional Circumstances Case for Site MX41
4.7 In a similar vein to the NPPF, PPG2 noted at paragraph 2.6 that:
“Once the general extent of a Green Belt has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt.” (our emphasis)
4.8 A more detailed set of tests has made its way into the recently-adopted revised NPPF. This document says (paragraph 136) that “…Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans…”. It then says (paragraph 137) that before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic plan-making authority should have examined fully all other reasonable options for meeting its identified need for development. This will take into account whether the strategy;
a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
4.9 The evidence we have presented to Sevenoaks District Council demonstrates that this site provides a unique opportunity to take land that is next to a transport hub, that is part-brownfield and which currently serves no public-beneficial use, and through its managed release, deliver a substantial proportion of the district’s objectively-assessed growth requirement, and also generate very significant benefits through new facilities that will be used by thousands of residents.
The Selection of Green Belt Land for Release to Meet Identified Needs
4.10 The principal test when examining candidate sites for release is at paragraph 138 where it says that first consideration to land which has been previously-developed and/or is well-served by public transport.
4.11 It also notes that local planning authorities should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.
4.12 The revised NPPF also says, in terms, that where Green Belt is released the benefits of doing so ought to be maximised such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land (paragraph 141).
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 41
The Exceptional Circumstances Case for Site MX41
4.13 Almost needless to say, opportunities to address the three over-arching objectives of the planning system (social, economic and environmental; paragraph 8) also need to be maximised and, in pursuing the most appropriate strategy, a local planning authority should in essence pursue the option(s) that cause(s) the least harm and yield(s) the greatest benefits.
A Location that is Uniquely Well-served by Public Transport
4.14 As noted earlier in this and previous representations, Site MX41 is uniquely located adjacent to, and within walking distance of, a Zone 6 (Oyster Card) National Rail station. It is therefore uniquely-placed to accommodate growth and provide new residents with the opportunity to utilise rail travel for work or social purposes.
4.15 The site is also located in a part of the District which does not suffer from highways capacity issues or air quality problems. It is therefore sequentially-preferable to channel growth towards this location to bolster sustainable patters of growth and to ensure that the District’s spatial strategy is deliverable. Moreover, the absence of these constraints means that the vast majority of s106 monies channelled towards transport infrastructure can be used to enhance the station or upgrade the local highways network and make it safer for cyclists and pedestrians.
A Location and a Proposal that Maximises Social, Environmental and Economic Gains
4.16 As noted earlier in this report, the proposed mix of uses at this site can deliver a range of very significant planning benefits, which fulfil the three inter-dependent strands of sustainable development.
Social
• The site’s allocation for development can ensure the accelerated delivery of new homes and the supporting community facilities necessary to make it a sustainable location.
• This site could provide a very significant and reliable source of market and affordable housing supply for the district, with early delivery guaranteed and backed by a Kent-based developer with an exceptionally-strong track record for delivery in the County. The managed release of this site would reduce the need to consider developing in less suitable and sustainable locations, which is a major consideration in a District in which 60 per cent of land falls in the Kent Downs or High Weald Areas of Outstanding Natural Beauty (‘AONB’).
• Rather than proposing a standard form of profit-maximising residential development, we are proposing to deliver a type and mix of new homes that is tailored towards local needs, consistent with the emerging local plan evidence base, and which reflects the prevailing rural and low-density character of this part of the district. We are also placing a strong emphasis on design quality and character, so that the scheme delivers bespoke and highly-attractive new dwellings and non-residential buildings.
• A shortfall in housing land supply can amount to an exceptional circumstance, in combination with other factors. In the context of this site, however, although the prospect of housing is clearly a significant benefit, it is delivery of non- residential uses through cross-subsidy which makes this a truly exceptional circumstances case.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 44 Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 45 The Exceptional Circumstances Case for Site MX41
• We want to create masterplanning proposals that can deliver a truly self-sufficient settlement, so as not to add pressure to existing local services. For example, a doctors’ surgery is proposed as is a new primary school. The provision of small-scale shops will enable people’s day-to-day needs to be met close to home, including on foot.
• There will be new education provision that will serve not only residents of this development but also existing communities and people who come to live in other new developments. Given the cost and scarcity of land for such facilities, this ought to be given very significant positive weight in considering the merits of a draft site allocation.
• There will be state-of-the-art sports facilities, including a new health club with a swimming pool, and Artificial Grass Pitches. This would provide a permanent home for Sevenoaks Hockey Club – one of the District’s largest and most important clubs – giving them facilities that are fit for the future and which can accommodate an increase in use as the club expands, again adding to the sustainability of the local community. We are also going to deliver modern training facilities for Sevenoaks Rugby Club, providing a direct benefit to its 1,600+ members. Theprovision of modern sports facilities will encourage greater levels of recreational and competitive participation, which is proven to increase the health and wellbeing of the local community.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 46 The Exceptional Circumstances Case for Site MX41
Economic
• The site’s allocation for development can provide the certainty required to secure significant pre-letting of commercial space. It would direct growth and inward investment to a part of the District that is adjacent to some of the region’s largest arterial roads, and it would offer the market a very attractive location with easy accessibility, modern accommodation, and a highly-attractive environment.
• Our masterplan will need to make allowance for a new business campus with a large amount of employment-generating floorspace. This can also accommodate a significant amount of the District’s objectively-assessed need for B-Class space in the coming plan period, and it would provide a shared office space product which meets an identified gap in the market at this location. This has the potential to generate significant additional rates revenue for the Council and create new job opportunities for local residents.
• The increase in local population would in itself provide a further stream of tax revenue in excess of £1.75m per annum, which will sustain local services provision and provide a spending boost for the local economy.
• This scheme would represent a major construction project, with a delivery timeframe in the region of 8 - 10 years. It would therefore sustain a large number of construction- related jobs, with local firms relied upon for the provision of materials and machinery.
• The estimated direct and indirect GVA arising through the construction-related activity would be in the region of £160m. The non-residential uses could also generate and sustain in excess of 500 FTE jobs.
• Unlike many of the other candidate sites for allocation in the draft Local Plan, MX41 is not crop-producing and therefore its redevelopment would in no way reduce current agricultural and BMVL-related activity in the District.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 47 The Exceptional Circumstances Case for Site MX41
Environmental
• There are minimal environmental or landscape designation constraints to impede development, for example the land is not in the AONB or subject of a lower-order landscape designation, and it is not at risk of flooding. Moreover, the site’s location and extent mean that there isno prospect of the proposed development enveloping nearby villages.
• The proposals have been informed by detailed technical survey work prepared by Aspect, a specialist landscape consultant, and PBA. This background evidence is provided in the form of technical notes appended to this representation (see Appendix 6).
• Full ecological surveys have and continue to be undertaken, including a detailed habitat survey and specific surveys for bats, badger, dormouse, breeding birds, reptiles and great crested newts. These surveys have found that the majority of the site is of low ecological value, dominated by species- poor grassland and young tree planting. The layout seeks to retain and protect features of wildlife interest - including woodland and mature trees – and we are committed to creating substantial new areas of wildlife habitat and green corridors within the generous areas of retained open space that would provide an attractive ‘green grid’ through the new settlement.
4.17 All of the benefits identified above can be delivered at nil cost to the public purse. We will remain in discussion with KCC Highways, Highways England and other key stakeholders to agree the scope of highways and infrastructure upgrades, and we will also remain in close dialogue with Sport England, England Hockey, the Rugby Football Union and National Rail to ensure that the infrastructure we are proffering on and in the vicinity of Site MX41 is aligned with their corporate strategies and forecasted requirements for this part of the District.
Development that makes the most of released land
4.18 The redevelopment of this land provides an opportunity to bring private land into publicly- beneficial use. This site would not only accommodate a significant amount of new market and affordable housing to meeting district-wide need, it would also deliver new facilities that are readily-accessible to the wider community and which provide new opportunities for recreational activity. In particular, we are proposing major sport hubs that would create some of the country’s best hockey and rugby facilities, capable of hosting the highest-level training and competition play.
4.19 We have retained leading ecological, arboricultural and landscape consultants to provide detailed input into the masterplan and advise on how the scheme can sensibly mitigate any visual harm arising from the new development and provide a betterment in terms of biodiversity and new planting. Given the strong physical and visual containment of this site, the unique opportunity exists to facilitate unprecedented planning benefits, through the a discrete and managed release of Green Belt land, with boundary features reinforced as necessary to safeguard against future incursion onto adjacent land.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 48
Comments on Site MX41 and Appendix 1 (‘New Housing and Mixed-Use Sites for Consultation’)
5.1 In this section of our representation we propose a few minor modifications to the site plan and policy text associated with site MX41. These do not substantively alter the potential policy expectations of this site, but they would make it a more effective framework within which a high-quality scheme could be delivered early in the plan period.
Site Plan
5.2 We consider that the land identified atAppendix 1 of this representation should form the extent of Site MX41. Albeit slightly in excess of the line encompassing the site in the draft Local Plan, it must be noted that the emerging masterplan continues to incorporate a very clear and defensible ‘green buffer’ along the site’s northern boundary, forming an attractive, open and green entranceway to the new settlement.
5.3 The land also includes an additional area of land for which we have secured an option. This land is to be used wholly for outdoor sports and will accommodate pitches and a pavilion clubhouse for Sevenoaks Hockey Club.
Appendix 1 Site-Specific Text
5.4 In the table below, we set out the updated site facts that should be incorporated into the ‘Appendix 1’ commentary on Site MX41.
SDC Design Guidance Our Response
- Development of this site will only be permitted Agree – we intend to agree all triggers upfront with where it is linked to the timely provision of SDC, KCC and other competent bodies prior to evidenced infrastructure, supported by the submission of the application, to ensure transparency relevant infrastructure provider(s). and to aid the drafting of a s106 agreement.
- Development should be locally distinctive Agree – We will work with Design South East and SDC to reflect the identity of the surrounding area officers to refine a masterplan and the detailed design and take into account any relevant design for Phase 1, including the first tranche of housing, the guidance. sports facilities, the station car park and the Local Centre. Redrow PLC has Board approval to design and implement a bespoke range of house-types.
- The specifics of any scheme should Agree – we would like to work with the Parish Council be developed in conjunction with the and local residents to ensure that the scheme is local community including through the delivering the facilities they want and achieves a Neighbourhood Plan process where applicable. quality of design which gains support.
- The size and location of the site make it Agree – the Council’s policy and Quinn Estates’ suitable for a variety of housing types and contract with Redrow will provide a ‘double lock’ sizes, both market and affordable, to meet guarantee that the scheme will comprise 40% identified needs within the local affordable housing. There will be delivered through a community. This should include housing range of different house types, sizes and tenures to suitable for older people. provide choice and variety.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 50 Comments on Site MX41 and Appendix 1 (‘New Housing and Mixed-Use Sites for Consultation’)
SDC Design Guidance Our Response
- Careful design and layout to minimise impact Agree – the masterplan has very careful regard for on the amenity of neighbouring properties and the properties neighbouring the site edges, including to ensure the amenity of future occupiers of the extensive green edges. new development.
- Careful design and layout to reflect the edge Agree – We will work with Design South East and of settlement location and existing topography SDC officers, using detailed survey work to inform and landscape features, and to ensure net biodiversity improvements. Please refer to effective integration of the mix of uses. Appendices 3 and 6.
- Retain existing trees, hedges and habitats Agree – We will work with Design South East and SDC and incorporate high quality blue green officers to agree a robust and comprehensive strategy infrastructure and SuDS as an integral part of for on-site landscaping and open spaces. This will the scheme to reflect the greenfield nature of include opportunities for the on-site management of the site. surface water.
- Opportunities for biodiversity enhancement Agree – We will work with Design South East and will be sought. SDC officers, using detailed survey work to inform net biodiversity improvements. Please refer to Appendices 3 and 5.
- Landscaping and planting should be Agree – the masterplan will have very careful regard for integrated into the development and will be the prevailing character of the surrounding area and required to provide a buffer and defensible also the properties neighbouring the site edges. boundary in order to blend the development into the countryside in a natural and sensitive way.
- Multiple access points will be required to Agree – the technical work on highways is already at a serve the development. Any scheme will need very advanced stage, as set out in the Technical Note to be supported by a transport assessment. at Appendix 13.
- Retain and improve existing pedestrian Agree – we will work with Kent County Council and and cycle paths and create new connections Network Rail to deliver an effective package of through and beyond the site, including to the improvements to maximise the benefits arising from train station and local centres. the site’s very close proximity to Knockholt National Rail station. Further enhancements to the local road network is set out in the PBA Technical Note, found at Appendix 13.
- Provision of public open space will be Agree – the provision of attractive and functional open required to support the development. The spaces is central to our vision for a successful and type and layout of open space will be a matter vibrant new settlement. for consultation with the local community but should include amenity greenspace and children’s playspace.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 51 Conclusions
6.1 By any measure, this site is uniquely-placed to accommodate a substantial proportion of Sevenoaks’ future growth requirements in a manner that is entirely consistent with national policy and which does not compromise the strategic purpose of the District’s Green Belt.
6.2 It is a highly-enclosed and discrete parcel of land, it is a very accessible and quintessential ‘transport hub’ location, and by bringing this redundant land back into active use, we can generate unprecedented public benefits through balanced growth that secures major investment in local services through land value capture instead of taxpayer-generated resource. No other ‘Exceptional Circumstances’ site can provide such a diverse and meaningful range of economic, social and environmental benefits.
6.3 Moreover, the land is not crop-producing BMVL, it is not in an Area of Outstanding Natural Beauty, and it is not subject of other planning designations or physical constraints that would prevent delivery (ecology, flood risk, landscape and so forth).In legal terms, it is therefore sequentially-preferable to develop this site ahead of other land currently in agricultural use and / or of landscape value, which are features of alternative development sites around the edges of existing settlements like Edenbridge, Swanley or Westerham.
6.4 Given the absence of development and infrastructure constraints, a new development allocation policy for this site as set out for MX41 can include the requirement to deliver a range of very beneficial community and non-residential uses that will benefit existing as well as future residents of the Ward.
6.5 In the coming months, we will continue to engage with the local community and their local representatives through further public exhibition events. We will also progress detailed technical work in close dialogue with relevant statutory and advisory bodies.
6.6 We are committed to delivering a new and sustainable settlement of the highest quality, and we trust this this duly-made representation has set out why the site’s redevelopment potential, with its unrivalled sustainability and public-transport credentials, warrants first consideration by Sevenoaks District Council, in accordance with the NPPF.
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 52 Appendicies
Appendix 1 – Site Location Plan
Appendix 2 – List Description, Church of St Mary, Historic England
Appendix 3 – Design South East, Report on Stonehouse Park, Sevenoaks
Appendix 4 – Illustrative Masterplan
Appendix 5 – Employment Demand Study, Savills
Appendix 6 – Ecology Report, Aspect; Landscape and Visual Impact Issues Report, DWLC; Technical Note, PBA
Appendix 7 – Correspondence from Sport England
Appendix 8 – Letter from Kent County Council, Children, Young People & Education
Appendix 9 – Letter from NHS Bromley Clinical Commissioning Group
Appendix 10 - Letter from NHS West Kent Clinical Commissioning Group
Appendix 11 – Kent County Council, General Site Transfer Terms
Appendix 12 - Kent County Council, Service Requirements
Appendix 13 – PBA Highways Technical Note
Appendix 14 – Letter from Kent County Council, Highways
Appendix 15 - Letter from Highways England
Appendix 16 – Correspondence from Network Rail, Kent Asset Protection Team
Appendix 17 – Correspondence from England Golf
Land at the former Broke Hill Golf Course (‘MX41’) Reg 18 Representation, Draft Sevenoaks District Local Plan, July 2018 53