SEVENOAKS DISTRICT COUNCIL: ALLOCATIONS AND DEVELOPMENT MANAGEMENT PLAN (ADMP) – DRAFT FOR SUBMISSION (MARCH 2013)
CBRE Limited (‘CBRE’ hereafter) acts as property and planning advisors to Armstrong (Kent) LLP (‘AK LLP’ hereafter) in respect of their landholding at Fort Halstead. AK LLP is a Joint Venture led by RREEF Real Estate, the real estate investment division of Deutsche Asset Management. Other members of the Joint Venture include (inter alia) Hines UK and QinetiQ. CBRE is instructed to submit representations to the ‘Draft for Submission’ draft of the ADMP (March 2013). AK LLP welcomes the continued opportunity to engage with the District Council in respect of the emerging ADMP and other local planning policy documents which will hopefully ensure the successful delivery of the Fort Halstead site in terms of optimising its positive economic, environmental and heritage contribution to the district in a genuinely sustainable balance.
Sevenoaks District Council’s (‘the District Council’ hereafter) Core Strategy (February 2011) already recognises that Fort Halstead presents an important element in its future portfolio of sites to meet the District’s employment land requirements. The Core Strategy policy for Fort Halstead is focused on the opportunity and need for the District Council to retain and secure the existing and future employment potential of QinetiQ’s operations on the site (following the relocation of the Defence Science and Technology Laboratory (‘DSTL’ hereafter) to Porton Down and Portsdown West) as part of a regenerated, mixed use employment site. The clear goal is to maintain the economic contribution of Fort Halstead to the area by encouraging an employment-led, sustainable mixed use community which balances the need to preserve and enhance the site’s exceptional landscape, heritage and ecological value, in a sensitive location within the Kent Downs Area of Outstanding Natural Beauty (AONB) and the green belt, with the need to ensure a viable and deliverable development that optimises the economic, social, heritage and environmental value of the site for the District and the AONB.
The Core Strategy vision and policies for the Fort Halstead site has, in our view, been positively reinforced by the National Planning Policy Framework (NPPF) which was published in its final form by the Department for Communities and Local Government (DCLG) in March 2012 and this will be referred to later in our representations on the Submission Draft of the ADMP and particularly the specific issues which relate to Fort Halstead.
The achievement of this Core Strategy vision, which is fully supported by AK LLP and the whole of its project team, will require careful and effective planning under the framework of delivery and control to be provided by the Core Strategy and the ADMP, including taking viability and deliverability properly into account, so as to engender the investor confidence which will be vital to achieving the regeneration of the site in accordance with the District Council’s vision.
Site Description
The District Council is fully familiar with the nature and location of Fort Halstead. It is circa 300 acres (120 hectares) in extent and is located in the Kent Downs AONB and the green belt. It is bounded by the A224 / Polhill Road to the east, Star Hill and Lime Pit Lane to the south and west, and farm properties and Great Stockholme Wood to the north, and is in close proximity to the villages of Knockholt, Halstead, Badgers Mount, Dunton Green and Otford.
Originally constructed in 1892 as one of a ring of fortresses surrounding London, it now comprises an extensive number of buildings, workshops and laboratories constructed throughout the 20th century, a significant amount of hardstanding and large areas of open space and woodland. A large swath of open land provides long ranging views from Fort Halstead to Canary Wharf to the north and Sevenoaks to the south. The developed part of the site, which is largely encircled by a security fence, is set within a ring of woodland which screens the existing built development from external view, providing a secluded environment set within a high quality landscape. Outside of the secure fence, although wholly within Fort Halstead, are 65 existing
residential properties owned by AK LLP and let to third parties. A further 11 properties are located in close proximity, which are in the ownership of Annington Homes.
Primary vehicular access to Fort Halstead is via Crow Drive, to the northeast of the site, which provides access via the A224 to the wider strategic vehicular network. This access point is urban in nature, is located outside of the AONB and is used extensively by those who work at the site and live in the adjacent residential properties. Secondary access is provided at peak periods from Starhill Road, to the west of the site.
Background
The current uses at Fort Halstead were brought forward before the introduction of planning control. It was originally developed as a Ministry of Defence (MoD) research establishment and is still occupied by defence related industries. It remained in MoD ownership until 2004 and therefore was subject to Crown Exemption. In 2004, the District Council granted a Certificate of Lawfulness of Existing Use or Development (CLEUD) for the uses and development on site. The CLEUD approved the use of the site for business purposes, including storage and distribution, energetic material testing, a canteen and a social club. It is also identifies 82,168 sq m (GEA) of built footprint.
The two main current occupiers of the site are DSTL, which supplies sensitive and specialist science and technology services to the MoD and the wider Government, and QinetiQ. In June 2011, DSTL announced its intention to relocate from Fort Halstead. The relocation is expected to be completed by 2018.
In light of this announcement, AK LLP has appointed a multi-disciplinary team to plan positively for the future of Fort Halstead, so that it can continue to contribute to the economic vitality, heritage and ecology of the District in accordance with the Core Strategy vision. One of the principal aims is to ensure that QinetiQ remain onsite, as part of a sustainable and attractive mixed-use community which will respect the legal and policy implications of its position in the AONB and the green belt, as well as the important heritage assets it contains, whilst also preserving and enhancing the pleasant living environment for the existing residents who live in very close proximity to the site.
Fort Halstead is allocated in the Core Strategy as a Major Developed Site (MDS) in the green belt and a key employment site. The Core Strategy recognises that the MDSs within Sevenoaks form a significant part of the District’s employment land supply and that their retention and redevelopment as employment sites will, along with other commercial sites, be subject to the provisions of Core Strategy Policy SP8. The Core Strategy also acknowledges, at paragraph 4.5.21, that the main requirements of the current occupiers of Fort Halstead (i.e. DSTL and QinetiQ) may vary during the Plan period to 2026. The paragraph continues to note that ‘the implications of a future decline in occupancy of the site will be considered within the policy framework of the Core Strategy and the MDS guidance for Green Belts (PPG2) and the major developments guidance for AONB (PPS7)’. Both PPG2 and PPS7 were superseded by the NPPF following its publication and the effect of this is analysed later in this letter.
The District Council’s approach to economic development and land for business is set out in Core Strategy
Policy SP8. It states that (inter alia):
‘The sustainable development of the District’s economy will be supported by:
1. The retention, intensification and regeneration of existing business areas primarily at Sevenoaks, Swanley and Edenbridge and Major Developed Sites in rural areas, subject to Green Belt policy.
Sites used for business purposes will be retained in business use unless it can be demonstrated that there is no reasonable prospect of their take up or continued use for business purposes during the Core Strategy period. Redevelopment for mixed use of business sites in urban areas may exceptionally be permitted where such development would facilitate the regeneration of the site to more effectively meet the needs of modern businesses, where the employment capacity of the site, represented by the commercial floorspace, is maintained and where a mixed use development would represent a sustainable approach consistent with the general distribution of development’.
In accordance with Policy SP8, AK LLP commissioned a study of the employment prospects of the Fort Halstead site in the context of DSTL’s proposed departure. The initial findings set out in the report (April 2012), prepared by Regeneris Consulting, concluded that given market conditions and the availability of sites elsewhere, there was no deliverable prospect of the whole of the site remaining in employment use during the Plan period. The report did identify the opportunity to bring in some limited employment uses, including small scale serviced office facility to complement the ongoing core activities of QinetiQ, a hotel, a heritage centre, a care home for the elderly and site-specific retail provision. The initial findings were shared with the District Council and other local stakeholders.
Following the initial findings, AK LLP’s project team engaged in a thorough programme of stakeholder engagement. The programme included meetings with senior Officers and Members at the District Council and meetings with third party stakeholders, including the London Borough of Bromley, Kent County Council, the Kent Downs AONB Board and Kent Wildlife Trust. AK LLP also held initial public exhibitions in May 2012, which were attended by over 350 people, plus around 100 people working at Fort Halstead, and a Community Planning Weekend in July 2012, which was attended by around 100 people and was followed by a feedback session attended by approximately 70 people. AK LLP also instructed ‘Locate in Kent’, Kent and Medway’s investment promotion agency, to conduct a peer review of Regeneris Consulting’s report. Locate in Kent agreed with the general conclusions of the report. Locate in Kent’s findings were once again shared with the District Council and other local stakeholders.
During this period of engagement, stakeholders expressed a number of opinions on employment opportunities at Fort Halstead. The main points being that more office and workspace provision should be provided and that the preliminary thoughts for site-specific retail provision should be removed, as well as the proposed care home for the elderly pending further research. There was also strong support for a good quality hotel development. Regeneris Consulting revised their report (August 2012) in light of the period of engagement; the revised report was also shared with the District Council and other local stakeholders.
AK LLP is acutely aware that Fort Halstead is located not only within the green belt, but also within the Kent Downs AONB. As a result, any development proposals for the site need to consider the objectives set out in the Kent Downs AONB Management Plan, the key purpose of which is to conserve and enhance the natural beauty of the AONB. To assist the project team on this, AK LLP has recently instructed Professor Robert Tregay of LDA Design to advise on matters explicitly related to the Kent Downs AONB. Robert has been involved with many projects in, and concerning, AONBs and has prepared seven landscape assessments and management plans for AONBs throughout the country as part of the Countryside Agency’s national series. AK LLP is also mindful that Fort Halstead contains the Fort, a Scheduled Monument, and a number of listed buildings and other buildings and structures of heritage value. It also contains Ancient Woodland and environmentally sensitive land that is home to diverse valuable ecological habitats and species.
In light of the above, and in the context of planning policy, AK LLP’s multidisciplinary team is continuing to plan for DSTL’s departure and seeking to:
- create a viable, sustainable and vibrant long term future for Fort Halstead which recognises and protects its unique qualities, heritage and landscape;
- secure a development which conserve and enhance the Kent Downs AONB, and its rural setting more generally;
- provide a balance of uses comprising employment, including the retention of QinetiQ, a small scale office facility, and a hotel, and alternative uses, including residential development and a heritage centre, that will create a balanced modern English village with its own identity which complements the existing network of surrounding settlements and that can be enjoyed by the wider community.
AK LLP is in the process of preparing a Progress Report, which will outline the work undertaken to date and initial thoughts relating to the future development of the site. This document will be shared with the District Council, statutory and non-statuary consultees, local stakeholders and other interested parties shortly and will form the basis for further discussion.