This was the response of Farningham Parish Council to Sevenoaks district Council’s proposal for Farningham New Town.

Farningham Parish Council: Objection to Pedham Place site (ST2-28) in SDC’s Proposed Submission Version of their Local Plan

Farningham Parish Council raises the following concerns in justification of our view that the local plan is not sound, legally compliant or compliant under the Duty to Cooperate:
Sevenoaks District comprises 93% Green Belt land and is an Area of Outstanding Natural Beauty, within the ‘Garden of England’. Farningham Parish Council believes Sevenoaks District Council has not properly explored neighbouring districts’ ‘Duty to Co-operate’ to assist in meeting the impossible challenge of generating the governments’ housing targets. This Local Plan does not take into account any of the new housing developments in Thamesmead or future developments as a result of the new Thames Gateway which will alleviate housing concerns in this area of the Sevenoaks District.
Site ST2-28 continues to be incorrectly labelled as located in Swanley: “Land at Pedham Place, Swanley/Farningham/Eynsford”. The Pedham Place site is disconnected from Swanley by the M25 and the large junction 3 road infrastructure which includes access to the A20 towards London and the M20 towards Folkestone. This is not insignificant, the location of the site renders it inadmissible to the local plan as a suitable ‘broad location for growth’ for the following insurmountable reasons:
Traffic Congestion:
Swanley Town Council’s Traffic Study identified an ‘inability of existing junction to M25 to cope with current level of traffic.’
Limited opportunity for multiple access points to the site due to narrow rural roads, local covered reservoir and M25 carriageway on three sides of the site.
Kent Highways have yet to publish their road infrastructure report – the site is still without comment from Kent Highways and Highways England with regards to future impact on the current road infrastructure. Previous planning
applications submitted for development of this site have been refused on the basis of traffic congestion and insufficient road infrastructure.
Site access by foot is untenable:
Walking and cycling routes to Swanley are unsafe and unclear. Eynsford and Farningham Road stations are out of walking range.
Area topography does not make walking and cycling sustainable – Pedham Place is at the top of a very steep hill, next to the junction of two major motorways, cut off from town by the heavily congested motorway junction roundabout. The M25 carriageway travels over the junction, the M20 carriageway travels underneath. Creation of a safe route would require installation of a subway under the M25.
Public health:

Electricity pylons cross the site, there are known health concerns from living in close proximity to pylons.
The AQMA records unlawfully high levels of air pollution on the A20 between the A225 Dartford Road roundabout and Pedham Place and on the neighbouring M20 under Button Street and regularly breaks European safety standards.
The local plan has other inaccuracies with regards to this site:
White Oak Leisure Centre is identified as a contribution to Social and Community Infrastructure and was suggested to be a potential beneficiary of the ‘Swanley regeneration’ attributed to CIL monies from the Pedham Place proposal yet it is far outside of the scope of this site’s phasing and plans for its replacement/redevelopment are already underway and completely separate to this local plan.
The provision of a secondary school, a SEN school and two primary schools are promised without consultation with local education provision or local population estimates for anticipated numbers on roll forward of the proposed phasing. Dartford Borough Council have agreed a new secondary school at an alternative site; an existing secondary school was recently mothballed at Hextable. The location of the site is also not suitable for school children to travel
to on foot or by cycle.
The location of a primary care hub onsite has been changed from the original promise of a doctor’s surgery but again is without consultation with the local NHS Primary Care Trusts, the Clinical Commissioning Group has already ruled
out such a hub in this location.
The proposed park and ride service assumes the installation of a bus lane into Swanley is viable to appease traffic congestion caused by the additional vehicles associated with 2500 homes and to mitigate current levels of congestion. A bus lane is not viable without significant compulsory purchase of homes between the site and Swanley High Street.
The proposal is also dismissive of landscape sensitivity despite ST2-28 being both Green Belt and within an Area of Outstanding Natural Beauty, and contradicts the North Downs AONB Management Plan. Pedham Place is significant to the maintenance of the Green Belt in its original aim of protecting rural England from envelopment by urban sprawl: allowing development beyond the boundary created by the M25 will invite further erosion into this Area of
Outstanding Natural Beauty.
With regards to the development of the local plan, this site was submitted very late in the process, without proper due diligence on behalf of the developers.
Sevenoaks District Council appear to have given the site special status as a
‘Broad location for growth’ to give developers further time to develop their proposal, despite resounding objections from stakeholders and the local
community. Development of this site as a location for 2500 homes is not economically viable for all of the reasons stated.
Farningham Parish Council similarly objects to the inclusion of four further sites which were not included in the original draft plan and therefore not available for public consultation. These sites, by default of their late showing have been
given similar special status to that afforded ST2-28 such that they go forward ‘under the radar’ of proper public scrutiny.
Farningham Parish Council strongly urges Sevenoaks District Council to remove site ST2-28 (Land at Pedham Place) from the Local Plan: the site fails to meet any exceptional circumstances stated and fails to receive public support from
the locally elected representatives or local community