SDC Local Plan including Pedham Place Development

Background

Sevenoaks District Council Local Plan says what can be built and where and what should be protected up to 2040. The new Local Plan, called ‘Plan 2040’, is currently open for consultation and proposes more business space for jobs, new homes, retail, leisure and community facilities.

The last Local Plan consultation (November 2022 to January 2023) focused on making the best use of land within the urban areas in the Sevenoaks district (i.e. outside of the Green Belt), including building at higher densities and on brownfield sites.

The Local Plan 2040 consultation, called ‘Regulation 18 (Part 2)’ considers Green Belt land, on the edge of existing settlements. Sevenoaks are consulting on three different options:

What does this mean for Farningham?

Included in the Sevenoaks Local Plan is a development to build 2,500 houses, a 28,000 seat stadium and hotel on and around the site of Pedham Place golf course split between the parishes of Farningham and Eynsford, with a significant impact on Crockenhill.

Farningham Parish Council will be objecting to the proposed development at Pedham Place, reference MX-15.

There are two important dates coming up.

This Thursday January 4th from 4:30pm until 7:30pm in Farningham Village Hall there is the opportunity to talk to staff from Sevenoaks District Council about these plans. You are strongly encouraged to attend.

On January 11th the consultation period for this proposal closes and you can no longer comment.

 The key things to note about commenting on the local plan are:

• Comments are per-person not per-household. Having every adult in your house comment individually is critical.
• Non-public comments (where you ask for your name to be withheld if you write in with a response rather than commenting online) are not counted. You must explicitly state that you're happy for your details to be published.
• Comments must reference material planning concerns. Put plainly not wanting it is not a valid planning concern.

It may be useful to refer to the response, appendix 1, below when formulating a response.

When submitting comments to Sevenoaks it is important to:

• select Option 1.
• refer to Pedham Place in the comments box using the identifier "MX-15".
• demonstrate the failure of the development to meet the standards for exceptional circumstances and sustainable development.

The community has crowd-funded a legal report, bullet points of which are available here. These points can be referenced in your own words in the comments box also.

You can read the full local plan by clicking on this link.

You can read a summary of and comment on the local plan by clicking on this link.

If you need help using the Internet then community-run sessions where somebody can help you complete the online form are being held on Saturday 6th January at:

• Eynsford Parish Council offices (9am - 11am)
• Farningham Shand Hall (right-hand side of the church) (10am - 3pm)

Other ways in which you can help:

• Write to your MP: https://www.lauratrott.org.uk/contact
• Write to your local councillor: https://cds.sevenoaks.gov.uk/mgMemberIndex.aspx?bcr=1
• A team of volunteers have delivered over 6,500 posters and leaflets across the area. Display yours in your road-facing window.
• The community has raised almost 50% of the cost of a legal report with which to challenge this proposal. Please donate to our crowd-funding page to support this and future campaigns.

Speaking of community a recent tractor run in Crockenhill organised by Cllr Rachel Waterton in support of this campaign made the news! The event raised a huge amount of money.

Appendix 1

Proposed response to site MX 15, Pedham Place:

I wish to strongly object to the inclusion of site MX-15 Pedham Place in any future options for housing or mixed-use development within Plan 2040, A New Local Plan for Sevenoaks District.

My reasons for objection to the inclusion of site MX-15 Pedham Place in Plan 2040 Regulation 18 Consultation include:

• Perceived benefits from development of site MX-15 cannot justify ‘exceptional circumstances’ to be considered for release from national Green Belt Policy, or damage to the Kent Downs National Landscape (Area of Outstanding Natural Beauty). Pedham Place performs strongly against the 5 purposes for the retention of Green Belt as set out in the National Planning Policy Framework (revised December 2023).
• Development as proposed is inappropriate, does not meet local need, and does not meet the minimum expectation for sustainable development as set out in the National Planning Policy Framework.
• In contrast, proposals as set out by Sevenoaks District Council are contrary to their policies H2 (Provision of Affordable Housing), H3 (Housing in Rural Areas), EMP2 (Delivering New Employment Land), EMP5 (The Rural Economy), TLC1 (Town and Local Centres), CC1 (Mitigating and Adapting to the Impacts of Climate Change), W1 (Flood Risk), W2 (Sustainable Drainage), AQ1 (Air Quality), HW2 Noise, HEN1 (Protecting and Enhancing the Historic Environment), NE1 (Landscape and Areas of Outstanding Natural Beauty), BW1 (Safeguarding Places for Wildlife and Nature), BW2 (Biodiversity in New Development), OS1 (Open Space and Recreation), ED1 (Education), and SL1 (Sports and Leisure Facilities) as set out in their Plan 2040 Regulation 18 consultation.

I believe that Sevenoaks DC must review Plan 2040 in line with the current requirements of the National Planning Policy Framework, and reconsult with compliant options. Pedham Place should be considered an ‘inappropriate development’ location due to its location in the Green Belt, the Kent Downs National Landscape (AONB), and recognising that no justification of ‘exceptional circumstances’ have been evidenced.

In addition, responders may like to choose from the following issues which are of most concern to them.

Protecting GREEN BELT Land

The inclusion of Pedham Place would require that Sevenoaks DC seek to release the site from the national Green Belt Policy. Pedham Place continues to strongly serve the original purposes for which the Green Belt policy was established ‘to prevent urban sprawl by keeping land permanently open: the essential characteristic of Green Belts are their openness and their permanence’ NPPF para 142.

The NPPF (revised December 2023), confirms that the Government attaches great importance to Green Belts. I strongly believe that Pedham Place clearly meets the 5 Purposes of Green Belt as set out in the NPPF, and that proposed development is contrary to NPPF in the following ways:

Purpose 1: “To check the unrestricted sprawl of large built-up areas.”. Protecting the Green Belt at the edge of Swanley is vital to protecting the Sevenoaks District from London’s urban sprawl. Pedham Place proposals for a new settlement of 7,000 residents will engulf the adjoining villages of Farningham, and Eynsford, and merge with Swanley, extending London sprawl to the Darent Valley.

Purpose 2: “To prevent neighbouring towns from merging into one another.” Pedham Place would effectively join Farningham with Swanley, undoubtedly threatening the separate identity of each. In addition, the development of this area also threatens the border with Eynsford and Crockenhill and could lead to the disintegration of separation between all four communities.

Purpose 3 “To assist in safeguarding the countryside from encroachment.” Pedham Place is within the Kent Downs National Landscape (Area of Outstanding Natural Beauty) and part of a distinct North Darent, Darent Valley Character Zone. Development of Pedham Place would have a significantly damaging impact on the National Landscape, the Green Belt, the setting of the open countryside, and the views and setting of the SSSI at Farningham Woods.

Purpose 4 “To preserve the setting and special character of historic towns.” Pedham Place proposals will have a negative impact on the Farningham and Eynsford rural parishes, and their strongly performing Conservation Areas.

Purpose 5: “To assist in urban regeneration by encouraging the recycling of derelict and other urban land.” Pedham Place golf course and associated facilities provides an accessible and affordable service to the local community.

Demonstrating ‘Sustainable Development,’

I believe that proposals for Pedham Place contradict or fail to meet the following proposed policies as set out in Plan 2040, A new Local Plan for Sevenoaks District.

I fundamentally disagree that the benefits proposed by the promoter of Pedham Place under the ‘exceptional circumstances’ would benefit Farningham or its residents, and/or reflect or meet locally defined need.

I understand that the purpose of the National Planning Policy Framework is to contribute to the achievement of sustainable development; ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’. However proposed development at Pedham Place will have a devastating impact on surrounding communities today and for the future of our children who hope to benefit from living in this wonderful location.

I have the following concerns with proposals for Pedham Place, which I believe are contrary to my understanding of sustainable development and seem to contradict other policies outlined in the Plan 2040 consultation, including:

Meeting local Housing Needs: through a proposed Garden Community to provide 2500 homes, including 1000 ‘truly affordable homes’ in a 20-minute, net zero neighbourhood.

It is unclear how Pedham Place is a proposed Garden Community? Pedham Place is not included within the 43 proposals across England for Garden Towns and Garden Villages supported by Government. The site promoters are unlikely to the developers of the site, and therefore no commitments to higher qualities, or approaches to stewardship and management can be guaranteed. The proposed new homes at Pedham Place do not reflect need identified in Farningham or in neighbouring villages. The proposed scale of new homes is disproportionate to local need.

Contributing toward required Sports Facilities and amenities

It is unclear what relevance the proposed WASPS Rugby Stadium and associated facilities have that identify local needs or contribute toward achieve the wellbeing of residents locally. Farningham residents are well served by nearby leisure facilities in Brands Hatch, Sevenoaks, Hextable, and Dartford, with the refurbished White Oaks Leisure Centre in Swanley being recently completed. Farningham benefits from its existing cricket club. There is also no identified need for additional community space within existing villages who are well served by village halls and outdoor spaces.

Delivering additional Healthcare Facilities

Farningham already has a GP practice and dental surgery, with a further physiotherapy practice all on Farningham High Street. Braeside Surgery, Farningham and Devon Road Surgery in South Darenth are currently consulting on proposals to merge to achieve greater effectiveness.

It is unlikely that a new facility at Pedham Place will be funded within the Local Plan period., and therefore new development at Pedham Place would place an additional burden on the existing facilities in the local area. Capacity at Darent Valley Hospital is also full, and so new development is likely to need to make a financial contribution to both primary and secondary healthcare in the local area.

Providing additional Schools places to meet local need.

Proposals for Pedham Place include two new, two-form entry primary schools, with a total capacity of 840 pupils, and one new six-form entry, secondary school with capacity for 1170 pupils, which is greatly more than need generated within the site and does not reflect existing local need.

Orchards Academy, Swanley as the nearest secondary school is currently working at only 65% capacity. Furthermore, it is unclear why the site at Pedham Place is fundamental or appropriate to Kent County Council education plans, as Oasis Academy, Hextable, (4 KM from Pedham Place) was closed in 2016 due to falling student numbers. At that time, Kent CC stated that ‘they would retain the site for future use as demand for secondary school places increased again.’ Proposals for education at Pedham Place therefore are not justified and do not support existing need.

Improving Employment opportunities

Shops in Farningham High Street have been closing, including Farningham Butcher which has closed in the past year, and Farningham Village Store which was granted change of use by Sevenoaks DC to a house because of the lack of demand for retail provision. I therefore reject the proposition that there is a requirement for retail provision to meet existing rural need. Local communities are already well served by the shopping hubs in Bluewater, Dartford, Sevenoaks and Swanley. Proposals for up to twenty shops in Pedham Place together with suggestions of a supermarket will detract from the viability of Swanley Town Centre and Eynsford and Farningham Village Centres

Provision of Open spaces for the benefit of the community

Proposed Policy OS1 (Open Space and Recreation) states that the districts designated open spaces will be retained for their current use and type of open space’ providing ‘green lungs’ for and between settlements. I disagree with the suggestion that the developers of Pedham Place, will create net new open spaces and biodiversity net gain, when so much of the Green Belt and the current open spaces will be destroyed. It is also unclear how concreting over so much of the National Landscape with hard surfacing will affect surface water run-off, and potentially lead to flooding of the settlement in the Darent Valley, specifically at Farningham and Eynsford where the river Darent flows adjacent to many homes. The river Darent is an important chalk stream, and the environmental impacts of proposals on the valley must be carefully understood before development considered.

Proposed improvements to Sustainable Movement Network.

Proposed Policy T1 (Sustainable Movement Network) aims to encourage residents away from car usage toward more sustainable forms of transport by promoting and supporting improvements to the transport network. In contrast, proposals for Pedham Place are further concentrating vehicle movements in close to the Swanley Interchange and on the A20 where traffic problems from congestion, poor air quality and noise are already amongst the worst in the district. Proposals will exacerbate existing problems rather than improve them. The plans for a park and ride scheme, additionally will add to the congestion on the roads. There are no fast lanes or bus lanes currently, and the ability to create one along the B1273 is unviable. Therefore, proposals for these facilities would bring no local benefit, however, have the potential to add significantly to local congestion and worsen air quality for residents of surrounding communities.

Proposed improvements to Public Transport

Proposed Policy T2 (Sustainable Movement) prioritises journeys by walking, wheeling, cycling, and public transport, with private vehicles as a last resort. I disagree with the suggestion that the development of Pedham Place will enhance public transport connectivity, as the site is effectively in an unsustainable. There is no possibility of a rail station to directly serve Pedham Place, and therefore it is dependent on cars. Connections to Swanley Station will be problematic and dependant on the Swanley Interchange and the capacity of the existing B2173, which are already beyond capacity. Cycling and walking are restricted by both topography and the need to cross the busy Swanley Interchange making it potentially dangerous and only suitably for able body persons.

Impact of Site Access on local traffic congestion and safety.

Access to the Pedham Place site is very restricted, with viable only from the A20 to the north of the site. Proposals will therefore be overly dependent on access to and flow along the A20, close to its juncture with the Swanley Interchange. These access points could bring many thousands more car movements at peak times, where the existing infrastructure is often already stressed.

As a local resident we are already concerned by statistics that show road traffic fatalities are amongst the worst nationally, both for car passengers and for pedestrians, cyclists and horse riders in locations where local traffic interacts with strategic traffic. Substantial development of Pedham Place will only exacerbate the situation, with the potential of making the A20 significantly more dangerous and more congested.

Continued delays to the proposed Lower Thames Crossing, planned east of Gravesend, which would help alleviate congestion tailing back from the Dartford Crossing up to Swanley Interchange, means that improvements are unlikely in the area until the early 2030’s, at best midway through the Plan 2040 period.

Negative IMPACT ON AIR QUALITY.

Farningham already suffers from elevated levels of air pollution due to existing traffic congestion and nearby M25 and M20 motorway roads. Both NOx emissions and CO₂ emissions are incredibly high, which affects health (physical and mental), wellbeing and life expectancy of residents. Air quality in Farningham is already at dangerous levels, more vehicles using the A20 will only add to the air quality issues. Pedham Place is not a safe location for new residential development due to both noise and air quality pollution.

The London Air Quality Map highlights the rates of N02 air pollution along the M25 corridor, along the stretch from Dartford to Swanley Interchange is amongst the most polluted nationally and fails requirements for acceptable air quality. Sevenoaks DC must have a duty of care to ensure that location for development that it supports will be safe for residents who will live there. Future residents of Pedham Place will live adjacent to Swanley Interchange, which is an unsafe location for air quality.

Negative impact on VERY HIGH-RISK FLOOD ZONE.

Farningham village lying in the Darent Valley is within a very high-risk flood zone (Flood Zone 3) with the existing community prone to all of river, ground, and surface water flooding. The surrounding hills, trees, and countryside currently function as a natural absorber of rainwater. Settlements in the Darent Valley, including Farningham, are located at the base of steep valleys. Proposals for Pedham Place would create significant peak surface water run off which would exacerbate the potential for flooding in the villages and could pose a significant risk to existing homes and businesses located on or near the river Darent.

According to the Kent County Council “Flood Risk to Communities: Sevenoaks,” 121 dwellings in Eynsford, thirty-three in Farningham, and 207 in Horton Kirby and South Darenth are at overall risk of flooding - and building on Pedham Place would exacerbate the threat. The development of this site does not “provide wider sustainability benefits to the community that outweigh flood risk” (Sevenoaks District Council, Level 1 Strategic Flood Risk Assessment of 2017).

Negative impacts on wildlife and nature

The Plan 2040 consultation document includes a case study on the Darent Valley Landscape Recovery, which is an important collaboration to create and enhance 1500 hectares of biodiverse habitats and to restore the natural function of the river Darent.

Proposed Policy BW1 (Safeguarding places for Wildlife and Nature) reinforces the importance of protecting, retaining, and enhancing the Blue Green Infrastructure Network locally.

Proposed Policy BW2 requires a 20% enhancement in Biodiversity Net Gain across new development.

It is unclear from proposals how the above requirements to protect and enhance local wildlife and nature can be achieved through the proposals for Pedham Place. In contrast, I believe that including Site MX-15 Pedham Place within site options for development through the Plan 2040 consultation is opening the potential for a significant reduction in the wildlife, and natural character of the Darent Valley with the potential to significantly reduce local biodiversity value.