FAO Piers Mason Tel No: 01732 227000 Chief Planning Officer Ask for: Planning Policy Council Email: planning.policy@.gov.uk

By Email Only Date: 21st December 2016

Dear Piers,

RE: SEVENOAKS DISTRICT COUNCIL RESPONSE TO TANDRIDGE DISTRICT COUNCIL’S LOCAL PLAN - SITES CONSULTATION (REGULATION 18)

Sevenoaks District Council (SDC) welcomes the opportunity to comment on Tandridge District Council’s (TDC) Local Plan – Sites Consultation (Regulation 18). Please note that this is an officer level response.

SDC and TDC share a number of key constraints including Green Belt, High Weald Area of Outstanding Natural Beauty and Sites of Special Scientific Interest (SSSI). Also, it has been set out in the supporting ‘Duty to Cooperate Statement Update’ document that the Tandridge District shares similar strategic issues with the Sevenoaks District in terms of housing for both the settlement population and for the Gypsy & Traveller community, employment, flooding, health, transport and education.

SDC would like to make the following comments:

Duty to Co-operate

As an adjoining Local Planning Authority, it is important that SDC works with TDC to address strategic, cross boundary issues such as housing, infrastructure, employment, transport etc. to ensure that development can be enabled over the respective plan period. In this case, we note that TDC’s new Local Plan will set out a new development strategy for the district up to 2033.

Following the recent adoption of the Allocations and Development Management Plan (February 2015), SDC has recently embarked on producing a new Local Plan, which will cover the period 2015-2035. We have started to gather the necessary evidence to produce a new Local Plan, as well as working with neighbouring authorities under the Duty to Co- operate.

Recent Local Plan examinations have placed significant emphasis on the Duty to Co- operate, and how successful an exercise it has been when preparing the Local Plan. Therefore, SDC welcomes the ongoing, useful Duty to Co-operate discussions with TDC to address key cross boundary issues. SDC has a number of working groups with its other neighbouring authorities under Duty to Co-operate (i.e. West , North Kent, London Boroughs etc.) and these wider meetings are working well.

Meeting the District’s Objectively Assessed Need (OAN)

The Strategic Housing Market Assessment (SHMA) for the TDC states that there is an OAN requirement of 470 units to be built annually over the plan period 2013-2033. This equates to a total of 9,400 units being built over the 20 year period.

The Strategic Housing Market Assessment (SHMA) for the SDC identifies an OAN requirement of 620 units to be built annually over the plan period 2013-33. This equates to a total of 12,400 units being built over the 20 year period. However it should be noted that a refresh of this document has recently been commissioned to update the OAN taking account of the 2014 population projections and to reflect the updated plan period 2015- 35.

Sevenoaks District sits in a ‘West Kent’ housing market area with Tunbridge Wells Borough and the ‘’ part of Borough (Sevenoaks and Tunbridge Wells SHMA, 2015). Whilst it is recognised that there are cross-boundary interactions between Sevenoaks and Tandridge, the links from Tandridge are stronger to other authorities in and .

The emerging Sevenoaks District Local Plan is currently at the early evidence gathering stage of preparation. Options for responding to development needs will undergo public consultation during summer 2017 and it is likely to be during late 2017/early 2018 when the District Council will be clearer about its ability, or not, to progress sustainable development that meets identified needs in either its own area or housing market area. This is due to the high level of Green Belt (93%) and AONB (60%) within Sevenoaks District. As it may not be possible to meet our own OAN in full for the District, SDC will continue to engage with its neighbouring authorities within the identified housing market area, and also wider neighbours including TDC, under Duty to Co-operate for further discussions on how this issue can be resolved.

For information, SDC has a Memorandum of Understanding with Borough Council, with regards to the ability to meet the OAN requirement, and this can be provided to TDC upon request.

With regard to comments on specific sites, Appendix N “Tatsfield” outlines the two amber Green Belt sites within an Area for Further Investigation - TAT005 and ENA08 – that are approaching the boundary of SDC and TDC. TAT005 has an estimated yield of 10 units and is located in the Tatsfield and Titsey ward within a village that would be considered for insetting. EN08 has an estimated yield that is yet to be determined and lies within the Tatsfield & Titsey and Limpsfield ward. However, this site is located within an area that would be considered for exceptional circumstances and further evidence will be needed to support this site.

Distribution of Development

The Sites Consultation outlines that the broad distribution of proposed development falls broadly across the District’s main settlements of Oxted, South Godstone, Blindley Heath and Caterham. The proposed locations do not have a significant impact on Sevenoaks District. However, should significant development be brought forward in Oxted, considerations should be given to the impact on highways, especially along the A25 and M25 Junction 6 as there might be increased usage as a result.

SDC recognises that the proposed new and extended settlement options will be subject to further evidence regarding sensitivity testing and the deliverability of sites once allocated within the Local Plan.

Conclusion

In summary, SDC believes that TDC’s approach to the Site Consultations for the new Local Plan is positive and proactive in light of current national planning policy. SDC will continue to positively engage with TDC under the Duty to Co-operate, as both authorities progress their Local Plans and try to meet their requirements over the Plan period.

Yours sincerely,

Lily Mahoney Planning Officer (Planning Policy)