SDC LOCAL PLAN 2
KNOCKHOLT PARISH COUNCIL'S RESPONSE TO SDC DRAFT LOCAL PLAN
1. A Balanced Strategy for Growth in a Constrained District.
KPC do not agree that this is a balanced strategy for growth. The sites proposed for development are predominantly in the north of SDC. A constrained district has been further constrained with this bias and the pressure on existing inadequate infrastructure will be to detriment of northern parishes. The proximity of motorways and railway stations should not be used as justification for urban sprawl and erosion of the Green Belt. SDC should seek a definition of ‘exception circumstances’ before developers use their imagination and persuasion to encourage sports clubs and charitable organisations to canvas for large developments when most of the users of these facilities will not have to deal with the site’s construction and the eventual destruction of rural living. No parishes should be expected to deal with more than one large (over 350 homes) in or adjacent to their village. There needs to be a spread across the entirety of SDC.
The plan repeatedly refers to housing in response to LOCAL demands, but there is no proof of this. With the prospect of less inward migration from Europe following Brexit, the declining birth rate and an aging population which needs smaller homes, is SDC being pushed to over provide for local needs to help national targets?
2. Housing and Mixed-Use Site Allocations
KPC disagree with SDC’s broader definition of PDL and would seek that only PDL as defined within the NPPF is future policy. There are several leisure sites and public amenities included in the listing. KPC are against the loss of these essential sites to residential use. There is an ageing population and to increase distances travelled for leisure or medical visits further burdens the roads and public transport and reduces local employment opportunities these sites currently fulfill.
3. Landscape and AONB
KPC would prefer this wording.
‘The landscape character of the District and the countryside, including areas of tranquility MUST BE conserved and the distinctive features that contribute to the special character MUST BE protected and enhanced where possible.
Rural businesses if set up must remain so and not be a stepping stone to future conversion into residential units by ‘alleged’ redundancy.
4. Development in Green Belt.
KPC object to any development in the Green Belt.
There is no reference to large developments in Green Belt. KPC feel that any such developments granted permission through ‘exceptional circumstances’ should retain a rural feel in keeping with surrounding areas and all Permitted Development rights are removed to retain a lower density on site.
KPC strongly supports the policy prohibiting the extension of dwellings built as Rural Exceptions.
5. Ashdown Forest
KPC have no comments on this policy.
6. Safeguarding Place for Wildlife and Nature.
KPC strongly supports this policy. Any new planting to extend existing habitats and create green corridors should be with indigenous plants.
7. Transport and Infrastructure
Large developments mainly in the north of the district may have ready access to motorways and trunk roads, however for local journeys the pressure on narrow rural roads and single-track lanes will increase the probability of accidents where there are no pavements and also damage hedgerows. There are already inadequate rural bus services, and KCC and commercial operators will continue to cut unviable routes. Cycling routes are of little use for those unable to cycle, or who live at the top of the many steep hills in the district.
KPC would prefer the wording ‘This MUST mean ensuring adequate provision…’
SDC should insist on far higher parking provision on new developments as the current KCC specification is inadequate for multi car households. Off road parking eases pressure on roads.
Although electric cars reduce emissions they do not reduce traffic loads, and charging points require further electricity infrastructure.
Preferred wording-‘When new development creates a requirement for new or improved infrastructure beyond existing provisions, developers MUST provide…’
Installation of high quality telecoms and broadband connections must be prior to any building on site.
8. Market and Affordable Housing Mix
KPC support this policy.
9. Provision of Affordable Housing
For developments over 11 units the provision of on-site affordable housing should be non-negotiable. It is unfair to expect other parishes to bear the brunt of affordable and social housing. The percentage of affordable housing should be increased in areas where previous requirements agreed at the granting of planning permission have not been fulfilled.
10. Housing in Rural Areas
KPC strongly support this policy.
11. Provision for the Gypsy and Traveller Community
KPC support this policy.
12. Housing Density.
KPC would seek that any developments in Green Belt under exceptional circumstance are built using rural, not urban densities.
13. Supporting a Vibrant and Balanced Economy
KPC agree with this policy and feel employment opportunities and housing should go hand in hand. Sites designated for employment should not at some later date be found to be unviable. Developers should ensure that employment sites are attractive enough for businesses to take up. Any residential scheme to replace an employment generating use that has been granted planning permission, should not be permitted.
14. Town and Local Centres
SDC should encourage and support town centre businesses. Car parking charges should not be so high that it means shoppers go ‘on line’ and not to the High Street.
15. Design Principles.
These all seem worthy objectives but in practice may be impractical or unworkable.
16. Historic Environment
KPC strongly support this policy.
17. Heritage Assets
KPC strongly support this policy
18. Health and Wellbeing, Air Quality, Climate Change and Flooding
Flood risk assessment should include localized flooding knowledge. ‘Good’ BREAM standards should be adequate and lessen the financial burden on new businesses.
19. Open Space, Sport and Leisure.
KPC support this policy.