Parish Council Response to SDC Plan 2040
11th January 2024
In line with neighbouring Parish Councils, HK & SD have submitted their response with objections to the proposals at Pedham Place:
Horton Kirby & South Darenth Parish Council’s Response
to Sevenoaks District Council’s Local Plan 2040
Regulation 18 consultation January 2024
Whilst HK & SD Parish Council recognise the three principles that underpin the vision of Plan 2040; the creation of healthy communities, tackling climate change and seeking design excellence for all new developments, it does not support the extensive use of Green Belt and/or Natural Landscape (AONB) for housing and/or mixed-use development.
Proposals for Pedham Place do not show the necessary ‘exceptional circumstance’ for release of green belt land, and do not demonstrate minimum expectations for ‘Sustainable Development,’ that meets identified local need.
Therefore, HK & SD Parish Council wish to formally and strongly, object to the inclusion of site MX-15 Pedham Place to be included further in the ‘Plan 2040, A New Local Plan for Sevenoaks District’ proposals as a suitable site for mixed use development.
HK & SD Parish Council believe that any perceived benefits from development of site MX-15 cannot justify release from national Green Belt Policy, or damage to the Kent Down Natural Landscape (Area of outstanding national beauty). In contrast we believe that development as proposed is inappropriate and in contrary to the National Planning Policy Framework.
Because of the above, HK&SD PC wish to also formally object to the continued development and associated consultation of the ‘Plan 2040, A New Local Plan for Sevenoaks District’ currently, as it does not reflect relevant changes to National Planning Policy Framework (updated December 2023).
• NPPF reinforces clearer protection to the Green Belt, ‘once established, there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated. Authorities may choose to review or alter Green Belt boundaries where exceptional circumstances are fully evidenced and justified. NPPF para 145
• Inappropriate development is, by definition, harmful to the green Belt, and should not be approved except in very special circumstances.
HK & SD Parish Council do not agree that proposals as set out at Pedham Place will bring benefits to the wider community or infrastructure benefits based on identified current local need, nor do they outweigh the harm and destruction to the Green Belt and the Kent Downs National Landscape of the to consider inclusion in the Local Plan. Therefore, on behalf of Horton Kirby & South Darenth residents, we reject the inclusion of this proposal in the Local Plan for the following reasons:
Protecting GREEN BELT Land
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. HK&SD Parish Council, along with neighbouring Parish Councils, 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” .One of the purposes of the Green Belt is to prevent London sprawl. Pedham Place shares its immediate border with Swanley, which in turn abuts the London Borough of Bexley. Protecting the Green Belt at the edge of Swanley is vital to protecting the Sevenoaks District from London’s urban sprawl.
Purpose 2: “To prevent neighbouring towns from merging into one another.” Pedham Place has been described as Swanley, which is incorrect. It does, however, sit across the rural parishes of Farningham and Eynsford. The proposals are for a standalone settlement of up to 7,000 new residents, equivalent in scale to Edenbridge or Otford, making it potentially one of top 5 settlements in the Sevenoaks District. The location of Pedham Place is physically disconnected from Swanley and therefore cannot be seen as a sustainable urban extension, yet it is too close to Swanley (2.5KM) to be distinct. This 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. This would be severely damaged by the development of this site, as would views to and from Farningham Woods, which have been designated a Site of Special Scientific Interest. Development on the crest of the Darent Valley, at Pedham Place would negatively 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 sit within Farningham rural parish. Farningham contains an important and strongly performing conservation area, the first of such designated in the Sevenoaks District in 1969. Any development at Pedham Place would have a negative impact on the local conservation area, such as increased traffic congestion, worsening air pollution and higher risk of flooding, all of which are detailed further below.
Purpose 5: “To assist in urban regeneration by encouraging the recycling of derelict and other urban land.” A golf course is not “derelict” land, and it would not help in urban regeneration by encouraging the recycling of it. Pedham Place is also the site of the historic Fort Farningham, designated a Scheduled Monument by Historic England, who note that ‘Fort Farningham has remained largely free of alteration or renovation and survives comparatively well… including the tunnels beneath the rampart which are unique to Fort Farningham.’ This important local Heritage Asset, of national significance is now at threat of damage through inappropriate development at Pedham Place.
Environment - there is too much air pollution from the M25, affecting the Pedham Place and other proposed sites. Defra’s Air Quality Management Area records show unlawfully high levels of air pollution on the A20 between Pedham Place and the roundabout junction with the A225 Dartford Road. This regularly breaches European safety standards. This excessively high pollution is significantly worsened by regular congestion on the M25, north bound, with frequent queuing to the Dartford River Crossing, backing up towards Junction 4. The topography of the Darent Valley makes it difficult for the pollution to escape. This is dangerous to health for those living here and would be even worse for people living in, or visiting, the proposed development.
Hazards – the pylons represent a significant danger to public health since the high voltage power lines have Electro-magnetic Fields (EMF) and the development would be built next to them and that would cause health issues. Burying the pylons is not enough. They need to not produce an EMF.
The hazardous waste that may be contained from when the golf course was a landfill site requires investigation and remediation to fully ensure that this will not injure anyone or AONB, SSSI, chalk bed and local flora and fauna. There are wild orchids on the site and wildlife that needs to be protected.
Flooding - the golf course currently absorbs rainwater. Developing the land would involve hard surfaces leaving the water as surface water run-off, thus posing a serious risk of flooding downhill, from Farningham Hill to the River Darent with increased risks to the houses that already flood there. This also threatens the Darent Valley chalk bed river, one of the last 200 in the world and which needs to be protected.
Views – development is in an elevated location that would be visible from important viewpoints within the National Landscape, Green Belt and SSSI, particularly those associated with the Darent Valley and Historic Roman Villa.
Traffic - National Highways have published a series of route strategies in May 2023, including one focusing on ‘Kent Corridors to M25’ and the M25, London Orbital. The reports highlight that the M25 as it approaches the Dartford Crossing (A282) is amongst the locations where most people have been killed across the national network in road traffic accidents. Furthermore, the report highlights that M25 and sections of routes leading into London, have the highest rates of accidents for pedestrians, cyclists and horse riders in locations where local traffic interacts with strategic traffic.
Swanley Interchange 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.
Kent CC Highways recognise that the A20 between Pedham Place and Brands Hatch, is amongst the most dangerous in Kent, with many fatal collisions per year. Fatalities along this stretch of road are increasing, despite various traffic schemes which have been tried to reduce the dangers. Substantial development of Pedham Place will only worsen the situation, with the potential of making the A20 significantly more dangerous and more congested.
One Solar Farm has already been given planning permission to be built within the boundaries of HK & SD Parish. With a second application for a Solar Farm being received 22nd December 23 and it’s access being from the A20, West Kingsdown, KCC Highways have responded as follows:
‘There are also a cluster of Personal Injury Collisions (PIC) at the junction of A20/Scratchers Lane, with two nearby fatalities reported. Looking further along the A20 corridor there are increased PIC clusters and fatalities on the highway network - on the A20 between M25 J3 and M26 J2a’.
With the Pedham Place proposal being built exactly in this location it can only worsen the problem.
Residents of Horton Kirby & South Darenth have seen an increase in traffic using the roads through the villages as a rat run to join back at the Dartford Tunnel whenever there are delays with traffic jams backing up to the junction/roundabout of the A20 bottom of Farningham Hill and the A225 ‘Top Dartford Road’. The advent of Satnav has only served to make the situation worse.
Pollution – light, noise and sound pollution from the stadium would threaten wildlife and further erode the dark sky qualities of the National Landscape. Light pollution would also affect the local livestock on farmland negatively and there are lot of local businesses whose livelihoods depend on the wellbeing of their animals. As the WASPS have a small audience, HK& SD Parish Council understand the stadium would be used for entertainment also and that noise is highly likely to be very disturbing to the local community. It is bad enough when there are events held at Brands Hatch but at least they’re not at anti-social hours. Concerts would interrupt the peace and enjoyment of the area.