Survey completion information
The consultation is open until 11th December. There are two consultation surveys:
One survey is called “Sites” and looks at Plan policies ST1 – A Balance Strategy for Growth and ST2 – Sites proposed for housing allocation.
The other looks at all other Policies and Evidence Base documents.
Fawkham Parish Council will publish its full response in due course, soon after our December meeting.
Meanwhile, below are some key points on the Local Plan policies ST1 – A Balance Strategy for Growth and ST2 – Sites proposed for housing allocation. You may find the information below useful when making your comments on these two policies.
The link here will take you to the consultation survey called “Sites” which only looks at these two policies: https://engagement.sevenoaks.gov.uk/strategic-planning/11e3b063/consultation/subpage.2025-10-07.0271518461/
Once you have filled in your details and any comments on ST1, select “suitable sites”, then “Hartley” (as SDC has labelled these HART), then select the site you wish you comment on and complete the survey with your thoughts. You can then select further sites to comment on before submitting your response.
A download to print a paper copy of this survey can be found here:https://engagement.sevenoaks.gov.uk/strategic-planning/b96ad0e6/user_uploads/paper-response-form-2025.pdf
Introduction to the Local Plan
Sevenoaks District Council’s housing target, set by the Government, is 17,175 by 2042. This is an increase of 63% on the previous target, and represents around a 33% increase in the current number of houses.
Over 500 sites were put forward by landowners in the last two “call for sites”. SDC has assessed these to see if they are suitable.
The development strategy focuses on:
- Urban sites ie within existing settlement confines
- Previously developed land (PDL) or Brownfield land, either within or adjacent to a settlement
- “Grey Belt” land adjacent to a higher tier settlement or a train station
Settlement Hierarchy
The development strategy is that towns at the top of the settlement hierarchy are the focus of growth.
“There will be small-scale limited development and infilling in villages and hamlets.”
“There will be a particular focus on sites that are close to services and facilities and/or well-connected by public transport, walking and cycling.”
The settlement hierarchy was reassessed in 2025 using a new methodology.
Hartley and New Ash Green are now classed as Primary Service Settlements, the next tier down from towns. Hartley has the 4th highest score of all settlements, as many of the facilities within Longfield have been counted as being within walking distance.
Fawkham remains a hamlet. Fawkham has now been given points for Longfield station as it is deemed to be within cycling distance. FPC will challenge this as the cycling route – along Valley Road – is not safe and does not meet the criteria.
The Settlement Hierarchy says sillages, hamlets and clusters are “considered to be in unsustainable locations” which “significantly constrain the ability of these settlements to support growth in a way that aligns with the principle of sustainable development”.
Grey Belt
The concept of “grey belt” was introduced through the NPPF (National Planning Policy Framework) at the end of 2024.
It is land in the Green Belt that is either previously developed or which does not contribute to any of the Green Belt purposes (a), (b) or (d)*. Generally, land in National Landscapes (formerly AONBs) is not grey belt.
A further Green Belt assessment has been undertaken by SDC to identify grey belt. As settlements in the District are dispersed with many small villages and hamlets, much of the Green Belt can now be identified as grey belt.
214 sub areas of Green Belt were assessed – only 8 were not grey belt: between Swanley and Hextable, at the edge of Greater London near Pratt’s Bottom/Knockholt and in Otford. While some sub areas assessed around Hartley are assessed as strongly performing green belt, this is in relation to purpose (c ) – preventing encroachment into the countryside, which is not taken into account when identifying grey belt.
However, for grey belt to be developed, it needs to be in a sustainable location, with particular reference to public transport. SDC states sites within 250m of an urban boundary – Hartley’s or NAG’s in our case – are in sustainable locations.
Where a grey belt site is identified in a sustainable location, it then needs to meet the “golden rules” set out in the NPPF:
- 50% affordable homes on major greenfield sites (SDC: 80% social rent and 20% shared ownership),
- Necessary improvement to local or national infrastructure and
- Provision of new or improved publicly accessible green spaces
*(a) to check unrestricted sprawl of large built up areas
(b) to prevent neighbouring towns (not villages) merging into one another
(d) to preserve the setting and special character of historic towns
Purpose (c ) to prevent encroachment into the countryside is not relevant to the assessment of grey belt – and most of the Green Belt around here serves that purpose.
The Local Plan sets out two options for development
Option 1 – baseline suitable sites
Option 2 – baseline suitable sites plus Pedham Place as a standalone settlement in the Green Belt and National Landscape (AONB)
Option 1 “suitable sites” Option2 “suitable sites + Pedham Place
Dwellings 11,443 14,022
Existing planning permissions 3,978 3,978
Windfall/small sites allowance. 900 900
Total 16,321 18,900
Excess/shortfall modest shortfall of 854 excess of 1,725, meets need with a small buffer
Pedham Place
Features in option 2 only.
2,500 homes in a standalone settlement, providing a range of services and facilities which could potentially include education, leisure, recreation, employment and community uses. Pedham Place is both in the Green Belt and the National Landscape (formerly AONB) and so does not fit with SDC’s development strategy. It has previously received mixed support/objection with concerns focusing on impact on local infrastructure, particularly traffic congestion and visual impact.
The first question within the consultation survey asks your preference between Option 1 and Option 2, with a further selection of “none of the above” also available. There is a comments box in which you can note that you do not support specific sites within Option 1 or 2.
Suitable sites in/adjacent to Fawkham
These are in both option 1 and 2. The sites were put forward by their landowners under the “call for sites”. Many other sites were also put forward by landowners and have been assessed by SDC as unsuitable or contrary to the development strategy or were subsequently withdrawn[1]*.
HART3: Fawkham Business Park – 31 units
HART5: Orchard Farm – 40 units (currently)[2]
HART6: Banckside and Downs Valley (adjacent to the Parish boundary) – 114 units
HART3 and HART5 are shown as being in Hartley, although they are in Fawkham. FPC will be asking SDC to amend this and ask residents to also include this in their responses. These sites are geographically and physically separate from Hartley’s core facilities and in planning terms relate more to the hamlet of Fawkham than Hartley.
A Development Brief will be prepared by SDC for each site, giving detailed guidance on how a site should be developed. This will include housing numbers, types and mix, design requirements[3], key Local Plan policies[4] for each site and infrastructure requirements[5].
HART3: Fawkham Business Park – 31 units: 50% affordable (of which 80% social rent, 20% shared ownership)
FPC will strongly oppose this site being allocated.
Previously developed land in current business use. “Unsuitable” in 2023 but now assessed as grey belt.
Fawkham’s adopted Neighbourhood Plan identifies this site as being used for business purposes. Policy FNP9 of the Neighbourhood Plan says such sites will be retained unless it can be demonstrated that there is no reasonable prospect of their take up or continued use for business purposes. The site appears to be fully let, with some long term tenants. FPC is keen that Fawkham retains a thriving local economy rather than become a dormitory area.
There is a strong demand in the District and in the Parish for commercial premises and the Sevenoaks Economic Needs Study 2025 Update recommends such premises be retained. A need for a further 40,400sq m of employment floorspace has also been identified in that Study– the loss of 1702sq m at this site would mean more floorspace would be required elsewhere to replace it.
The spatial vision for the District includes objective OB16: Safeguard and optimise the use of existing employment land – redeveloping this site for housing would be contrary to that. It would also be contrary to Policy EMP1 which says that existing employment land will be safeguarded.
Although fairly close to Longfield’s station and facilities, there is no pavement/footway from the site under the railway bridge, making it unsafe to walk there. It is not within walking distance of Hartley’s facilities.
Issues are identified on SDC’s SHELAA assessment with transport network capacity.
This site is shown as being in Hartley, although it is in Fawkham. The site is geographically and physically separate from Hartley’s core facilities and in planning terms relates more to the hamlet of Fawkham than Hartley. This should be amended to be shown as being within the hamlet of Fawkham.
HART5: Orchard Farm – 40 units: 50% affordable (of which 80% social rent, 20% shared ownership)
FPC will strongly oppose this site being allocated.
It was “Unsuitable” in 2023 but now assessed as grey belt.
In two parts: the western part has already been developed with 8 bungalows. The eastern part sits between Orchard Farm house and Fawkham Road, and is a greenfield site. It is partly wooded along the boundary to the railway line, and shown on KCC mapping as “traditional orchard BAP priority habitat”.
SDC needs to update the description of this site to reflect this, recalculate the number of houses for just the eastern part (and reflecting the existing trees and woodland and overshadowing of the railway embankment) and reconfirm the site’s availability with the landowners.
Although fairly close to Longfield’s station and facilities, there is no pavement/footway from the site under the railway bridge, making it unsafe to walk there. It is not within walking distance of Hartley’s facilities, which are some distance away and via a steep hill.
Development here would breach the readily-recognisable, permanent Green Belt boundary of the railway line. Without such a clearly defined physical boundary, development could creep into the open countryside of the Lower Fawkham Valley which contributes to the landscape character, views and sense of place as set out in the Neighbourhood Plan.
The SHELAA assessment states “new/additional access required” – it is not clear what/where that would be.
Issues are identified on SHELAA assessment with transport network capacity for Fawkham Business Park sited next door, but not for this site. This should be questioned.
This site is shown as being in Hartley, although it is in Fawkham. The site is geographically and physically separate from Hartley’s core facilities and in planning terms relates more to the hamlet of Fawkham than Hartley. This should be amended to be shown as being within the hamlet of Fawkham.
HART6: Land adjacent to Banckside and Down Valley, Hartley – 114 units: 50% affordable (of which 80% social rent, 20% shared ownership)
FPC will strongly oppose this site being allocated.
A flat plateau at the top of the ridgeline, abutting the Parish boundary. Greenfield Green Belt site, “unsuitable” in 2023 but now assessed as grey belt. Identified as strongly performing Green Belt in the latest GB Assessment (sub area HA -4) due to its strong role in preventing encroachment into the countryside.
If this site is developed, it would need to be released from the Green Belt. There is no strong readily recognisable physical feature which would define the proposed new edge of the Green Belt that would be likely to be permanent. The Sustainability Appraisal, 2025 records that there are clear concerns regarding securing a new Green Belt boundary in relation to this site. The proposed allocation would therefore not be consistent with national policy.
It is in agricultural use (incorrectly stated as ‘no existing use’ by SDC on SHELAA assessment). Also incorrectly identified by SDC as an open space (land in agricultural use cannot be designated as open space).
Adjacent to Rectory Meadow Local Nature Reserve and to Ancient Woodland. Around 400m from Baldwins Green Conservation Area, including the Grade 1 listed St Mary’s church – which is not acknowledged in the SHELAA assessment.
Considered by SDC as a sustainable location, within walking distance of Longfield station and Hartley’s facilities.
Additional access would be required and there is already limited capacity on the transport network (and 1,600+ more houses are proposed in Hartley and NAG, all using the Ash Road).
Concern development will be visible from the valley sides and potentially from the valley floor. That would be contrary to the Fawkham Neighbourhood Plan’s FNP Policy 1c, would adversely affect the strongly-rural character of the Lower Fawkham Valley Local Landscape Character Assessment (LLCA), and create visual intrusion of development on an undeveloped horizon.
Development will also adversely affect some valued views, contrary to Fawkham Neighbourhood Plan Policy 1(g): these are Important Public Views 1, 3 and 4.
SDC’s Landscape Sensitivity Assessment 2017 says that while the area in which this site is situated has an overall sensitivity assessment of low-medium for residential development, “The dramatic steeper slopes of the dry valley… have higher sensitivity” and that “the slopes in the west of the area are more visually prominent and thus more sensitive”. It further goes on to provide guidance to “ensure any new built development is well integrated into the landscape” and “protect the setting of valued heritage assets including the Conservation Area at Baldwins Green.”
Development will be visible from the Conservation Area at Baldwins Green less than 400m distant, and its setting. Both the Local Plan and the Neighbourhood Plan have policies to protect heritage assets and their setting.
SDC’s Sustainability Assessment says the development is not of a sufficient scale to deliver new community infrastructure to the benefit of Hartley.
If taken forward to Reg 19 consultation, FPC would expect the development brief for this site to take into consideration the LLCAs for Fawkham and Hartley, the effect on valued views outlined above, and the effect on Baldwins Green Conservation Area and its setting. FPC would expect to see some buffer land left undeveloped along the western boundary to mitigate the effects, ie the developable area to be reduced in size to reflect the topography.
Infrastructure Delivery Plan
Infrastructure requirements are emerging, which for our local area are:
- GP impact – not yet assessed
- Hospitals – Darent Valley is not mentioned – this needs to be flagged with SDC
- Education – need has been identified for a Primary School in Hartley/New Ash Green and a Secondary School for Swanley/the rural north
- Highways – “need further work to identify transport impacts”. M25 Junction 3 is a key focus
- Waste – Household Waste and Recycling Centre at Swanley to be expanded
- Rail – nothing identified for Longfield Station
- Water – South East water (supply) has not yet commented
Requirements will be further identified and developed by the Regulation 19 consultation, due next summer. Development will be expected to contribute to these identified infrastructure requirements.
Other Policies
The Local Plan also proposes policies on issues covering Design, Housing Choice for All (housing mix, density, affordable housing, smaller sites, etc), Employment, Climate Change. Health & Wellbeing, Historic Environment, Natural Environment, Infrastructre & Community and Transport.
FPC will add further information regarding our comments on the other policies in the Local Plan once available. These policies can be commented upon in SDC’s Policies and Evidence Base documents survey here: https://engagement.sevenoaks.gov.uk/strategic-planning/b96ad0e6/.
SDC are running a number of drop in sessions, which must be booked in advance. The remaining sessions are:
- Otford– Otford Village Memorial Hall (Players Hall) – Tuesday 25 November 2025
- New Ash Green – New Ash Green Youth Centre (Main Hall) – Thursday 27 November 2025
- Sevenoaks – Sevenoaks District Council offices – Monday 8 December 2025
And can be booked here: https://www.eventbrite.com/o/sevenoaks-district-council-119522554991.
[1] see SHELAA appendices E, F and G for details of these – you may also comment on these sites via the survey
[2] but see further information on Orchard Farm below
[3] Neighbourhood Plan policies and Local Landscape Character Assessments are not mentioned and this needs to be flagged up with SDC during this consultation
[4] Ditto 3
[5] See notes on infrastructure below