We are pleased to announce that our second-hand bookshop will be re-opening on Friday 19th June, with strict social distancing measures in place. We will be open only on Fridays and Saturdays (10am - 3.30pm) for the timebeing. We look forward to welcoming you back safely.

Dear Madam Mayor

The Faversham Society has consistently supported the proposal to create a town-wide 20mph speed limit on the streets of Faversham. We continue to do so under the latest proposal to implement the 20’s Plenty project through an experimental traffic order. The benefits to the town in terms of safety, air quality and physical health are key to the future resilience of the town, as well as to the conservation and enhanced appreciation of its built heritage.

We encourage the Town Council to resolve to advance the project at its meeting on 1st June.

Yours sincerely

We are extremely disappointed by the Secretary of State’s decision yesterday to permit the development of the Cleve Hill Solar Power station. The Society supports renewable energy and solar power in particular. Renewable energy should be mandatory for all new houses being built in and around Faversham, indeed nationwide, but successive governments have failed to require this.

The Faversham Society’s objections clearly stated in our final letter to the Secretary of State stand. We are opposed to any development project that will detract from, not enhance, our community. We shall now review the documents, consult our members and others, and consider what steps to take in the wake of today’s decision.

This decision will have a major impact on our community as a market town set in a rural coastal environment. The industrialisation of Graveney Marsh will also affect the entrance to the Creek and plans for its regeneration.

We shall have more to say when we have had time to digest the reasons for the Secretary of State’s decision and more importantly the Development Consent Order.

The Secretary of State's explanation for his decision
Examining Authority’s Recommendation Report

The key document is the Development Consent Order, this gives the developer permission to proceed and the powers to do so. Before work can commence the developer need to get detailed consent for Swale Borough Council. However, Swale can only attempt to ensure compliance with the DCO.

Development Consent Order as Made

The Daily Mail summed up the examination process accurately:
"An extensive examination was held last year to iron out controversial topics with locals such as wildlife, traffic, visual impacts and battery safety."

The Mail's description of the process is much more accurate that the Planning Inspectorate's

The Planning Inspectorate’s Chief Executive, Sarah Richards said:

“The Planning Inspectorate is committed to giving local communities the opportunity of being involved in the examination of projects that may affect them. Local people, the local authority and other interested parties were able to participate in a 6-month long examination. The Examining Authority listened and gave full consideration to local views before making their recommendation.”

That is not our experience of the process, we spent hours raising our concerns to no avail. The CHCP team of highly paid consultants and lawyers were so disrespectful that on one occasion the Chair of the Examining Authority required that they apologise. Probably fearing that the behaviour might be part of a Judicial Review.

Our representations made no discernible difference to the outcome.

Coverage on KMTV

Faversham Society reported in Aberdeen

The Ecologist

Dear Gareth

Application by Cleve Hill Solar Park Ltd

In response to your Request for Information dated 3 April 2020, The Faversham Society as an interested party would like to make the following response about the inadequacy of the Project Definition in the draft Development Consent Order (DCO). Namely paragraphs 10-13 of your letter:

1. Whilst we remain implacably opposed to the whole project for the reasons made clear throughout the Examination, we are pleased that these matters are requiring a response from the applicant. Our reason is that we have serious concerns that the parameters outlined in the DCO by the applicant are too widely drawn and that they provide too much opportunity to go beyond the parameters of the project which was the subject of the Examination.

• Further, as you will be aware, planning conditions are expensive to enforce, and Swale Borough Council (SBC) lacks the resources, expertise and experience to manage the oversight of a project of this scale, complexity and novelty. This highlights a flaw common to all complex NSIPs whereby, despite the rigour of the NSIP Examination process, enforcement of the DCO is left to the Local Authority. Our experience locally and elsewhere is that the simplest of conditions such as, for example, permitted transport movements, turn out to be unenforceable due to a lack of resources. Particularly worrying in this case, is that many of the requirements placed on the developer are costly and therefore any enforcement attempts by SBC will be subject to appeal. In these circumstances, SBC is unlikely to be able to match the applicant’s legal firepower and deep pockets.        

• Besides requiring the tightening of the design parameters, additional safeguards should be put in place in the DCO to strengthen enforcement. This should be done by attaching conditions and requiring review by the Health and Safety Executive, Kent Police and Kent Fire & Rescue Service before the application is sent to Swale. Kent Police are included here since there is a clear security/terrorism risk associated with what will be the world’s largest BESS with an explosive energy of 602 tons of TNT- the size of a small nuclear bomb. (Reference: See the Arizona Regulator’s determination described in 4. below)

• The proposals above in relation to health and safety as well as terrorism threats apply particularly to the proposed Battery Energy Storage System (BESS).  The recent determination by the Arizona Regulator following two Li-ion BESS fires which was admitted to the Enquiry in the Addendum to our Deadline 7 submission lays out the safeguards under which Li-ion BESS should be controlled in future. In the absence of any National Planning Statements(NPS) on BESS these, or equivalent, safeguards must be included in the DCO along with the appropriate authorities to be part of the enforcement procedures.
  
• A further area of major concern is the way in which the Rochdale Envelope is invoked in relation to the proposed BESS. This leads to the provision of very little detail and it became clear during the Examination that neither the applicants nor their advisors understood the possible technical, safety and security implications of their proposals. The Rochdale envelope is a principle designed to enable modifications to existing (safe) technology, not to be a Trojan Horse for technology proven to be unsafe on an unprecedented scale in the absence of any NPS. It is essential to keep in mind that what is proposed is five times bigger than anything previously built when there is clear experience and official review of life-threatening failure in an installation 350 times smaller.

• We, therefore, support the EA’s attempt to ensure a Requirement that secures the parameters of the project and deplore the applicants’ attempt to avoid this as laid out in your points 11.-13. It is essential that this Requirement includes the need for the exact specification of the BESS and a requirement that this specification is subject to approval by the appropriate authorities as outlined above.

• We also wish to extend our comments above to the decommissioning of the plant and the reinstatement of the land in 40+ year’s time. Besides the need to remove hundreds of tons of equipment and many thousands of tons of concrete, it is almost certain that the land will be polluted to a greater or lesser extent due to the leak of toxic Lithium compounds onto the marsh and potentially into water supplies and fisheries. This area will then be required by the EA for flooding, but if it is beyond remediation, it will have to be protected from rising sea levels on the same timescale. Given the likelihood that the plant may have been bought and sold several times by that time, it is essential that the DCO secures a lifetime indemnity for these significant potential costs so that they do not fall on the public purse.

• In conclusion, we note that given the provision for appeals, we foresee the danger of threats of legal action becoming a regular feature of efforts by SBC to enforce a weak DCO in order to protect the public interest.  We, therefore, request that the Secretary of State ensures that the DCO is both clear and robust in order to provide an effective basis to secure the public interest.

• This response is without prejudice to the Faversham Society’s clearly expressed opposition to the CHSP proposal on the grounds expressed in our many documented submissions to the Examination. Nothing in this response is to be taken to weaken or modify our views or our resolve in this matter.

Due to the current health crisis please note that the Fleur Hall and Chart Mills will be closed with effect from Wednesday 18th March 2020.

UPDATE: 1400H 18/03/20

In light of Government advice and prevailing good practice it has been decided that ALL Faversham Society facilities will be closed with immediate effect and until further notice, including Fleur Hall, Fleur Gallery, Fleur Museum, Visitor Information Centre, Gatefield Lane Bookshop and Chart Gunpowder Mill.

A group of residents along The Mall wrote to the Society seeking our support for a zebra crossing point to enable primary and secondary school children and others to safely cross at this busy road junction. With further housing development south of Watling Street (the A2) there will be a marked increase in the numbers crossing the road there. We are aware that traffic moves swiftly around the corner and rarely stops for pedestrians. The junction is complex with traffic coming from three directions.

The Society strongly supports efforts to improve pedestrian safety and to make Faversham more walkable. We support the aims of 20's Plenty to slow traffic and make the town more pedestrian and cycle-friendly. We support the 200 who signed a petition to KCC to install an appropriate crossing and urge KCC to install a zebra crossing before someone is injured or killed.

The Society hopes that the proposed Neighbourhood Plan will address some of these issues, and produce guidelines for how residents can engage to develop solutions and have them implemented. The Society broadly supports all community initiatives to develop solutions; residents are generally those most knowledgable about the issues and most likely to be impacted by proposed changes.    

Tim Stonor has assisted the group in putting together a design of what a potential crossing might look like.

The Society wishes to congratulate SBC for this strategy which has been correctly identified as a priority.  We welcome the additional resources allocated (£250,000) and the new “positive management” approach and commitment.  We particularly welcome the much needed, additional staffing.

Enforcement
The Society has long been critical of the lack of enforcement by Swale, and we are pleased that this has been recognised and that there are proposed remedies.  Article 4 Directions have been largely ignored, so allowing the degrading of vulnerable parts of the Faversham Conservation Area. There needs to be enforcement and a campaign to raise public awareness. We welcome the intent to introduce Special Advertising Control areas: these would be very useful in conserving the heritage of Faversham.
Radfield House is a prominent and embarrassing eyesore on the Watling Street and its condition clearly suggests a lack of concern for heritage in Swale. The conservation of this signature building probably now requires that SBC uses its compulsory purchase powers before the building lost and application is made for commercial or housing use of the land.

Pett Dane 15th century is a Grade II listed building. Needs to be on the heritage at risk register, SBC has not successfully protected this heritage asset for many years.

Our Common Heritage
As is pointed out in the strategy Swale has a remarkable richness of built heritage. This clearly is an asset. However, it also makes the presentation and communication of that heritage within and beyond Swale more difficult.

We would suggest that each year Swale has an annual tourism focus or theme in order to produce an experience of depth and quality. The defence of the UK is one such theme; it could be followed by brickmaking, barges, the railway and the Watling Street. The Watling Street provides a link to Canterbury and London, and in our view Swale needs to do a great more to connect its heritage nationally and to link with national and regional heritage centres.

Natural Heritage
Swale is defined by its shared natural heritage of chalk downs, fertile soils and marsh and the Swale. It would be desirable to see more linkage in the strategy between the built heritage and the natural heritage as is evidenced at the Oare Gunpowder site now also a country park. The Westbrook in Faversham made the development of the gunpowder industry possible and provides an excellent potential educational resource if interpreted from its source and down to the Swale. KWT’s ambition to re-wild Faversham has great heritage importance for the significance of our natural heritage and the part it has played in our history has been a neglected subject.,

Youth & Education
The Society is only too well aware of the importance of encouraging young people to appreciate and connect with our town’s heritage. The efforts of so many over the last 60 years will come to nought unless we instil in future generations. Appreciation of our built and cultural heritage Inheritance has to be an active and engaged process. We would urge SBC to include the creation and implementation of an educational outreach programme in its strategy

Community Celebration
The Society is very aware of the importance of connecting peoples contemporary lives with our heritage and that festivals are an important way of achieving this. We are working with the Hop Festival to introduce more heritage and heritage appreciation into that festival.

After 50 years of the pioneering Open Houses programme we are evolving it into two linked festival weekends in July each year. Plans for 2020 are to focus first on the coming of the railway and Victorian Faversham and on the second-weekend on gunpowder. We are seeking to engage as many community groups – music, dance, drama, food - as possible with us in these new annual heritage festivals.
We are working with HRGS through Historic Swale to mark and celebrate Beckett and Dunkirk.

Research
Although a great deal of research has been done on Faversham’s history and much has been published by the Society, there is a great deal more to be done. The relocation of the Doddington Library into the Reading Room in the Town Hall at 12 Market Place has created a space where academics, students and others from Canterbury and elsewhere can work on the archives not only of the Faversham Society but also the other 14 or so heritage assets in Faversham, organised through Faversham Museums Together.

Creek Basin and Upper Creek
Swan Quay, The Faversham Creek Hotel (previously the Coal Exchange, the former pumping station (currently used by the Boxing Club), TS Hazard and the green quay) form a cluster of considerable heritage interest and about which there is currently public concern in Faversham. These buildings, along with the upper basin provide an excellent opportunity for a combined heritage and economic regeneration initiative.

TS Hazard
TS Hazard is a signature building for Swale, as it is for Faversham, and it is currently in use as the base for the Sea Cadets. A use for which it is in the C21st inappropriate and Illsuited. The Society wishes to see the building restored and used for a more appropriate purpose combining conservation, regeneration and tourism. If a maritime museum were to be developed there it would provide an entry point to the Cinque Ports and enable Swale and Faversham to develop a link with Chatham and the Historic Dockyard and the National Maritime Museum. In recent years Kent’s maritime and defence heritage has been largely ignored for tourism development and yet it is one of our county’s and Borough’s best assets.

Conservation Areas
The Faversham Society enthusiastically supports community engagement in the designation, appraisal and maintenance of Conservation Areas and is interested in remaining involved in this process including working with Swale BC on the Faversham Conservation Area Conservation Statements when Swale is ready to move on to these in 2021-2 as suggested. However, we are concerned about the proposed timescale which we believe is a). starting too late and b). is too short, given the processes involved.”
As part of the new Neighbourhood Plan process now commenced in Faversham the Society is likely to propose and press for some revision and significant extension of the conservation area in order to strengthen protection of the very varied town core at a time when it is facing considerable development pressures.” is likely to press for some revision and extension of the conservation areas in the parish. We are concerned that unless the CA appraisal has been updated issues may arise when the NP is passed to Heritage England for comment and problems may develop. The Society would like to see the Conservation Area Appraisal brought forward in the implementation plan and remains keen to assist in this process.

Local listing

§4.5 discusses the possibility of local listing. The Council commits itself to developing a local listing policy and the document discusses how they would work with owners to ensure that this is understood. We welcome this proposal and regret that its implementation is not seen as a higher priority

In the NP process the Post Office is emerging as a candidate for national listing as a heritage asset representing some of the best of sixties architecture and a rarity in Faversham

Areas of high townscape value.
The Society is pleased to see the references to the use of –“area of high townscape value”. Early thinking around the Faversham NP suggests that there are some areas we would like to suggest for this designation. We understand that this is not an immediate priority for SBC but we would like to be able to use this designation in the near future.

Abbey Fields
The Society has objected to the housing proposal on Abbey Fields because it will remove the last remaining view of Faversham for the marsh and from the creek. This iconic view is fundamental to Faversham’s sense of place and an understanding of its evolution as a rural market town and port on the edge of the marsh.”

Old Gate, Old Gate Road
This is a listed heritage asset of uncertain ownership and which some local residents are concerned may be in a dangerous condition.

Addition

§ 3.5 discusses the local brick industry in Sittingbourne and Faversham.

 ‘Excavation of brickearth made its mark on the townscape in Sittingbourne and Faversham which can still be read today. In Faversham, the height of the footpath through Dorset Place above the houses and gardens in Roman Road is evidence that the land to the west was excavated before it was developed.’

Suggestion: At the end of para 4 of the maritime section insert

‘At Faversham, there was also steel shipbuilding on the west side of the creek from 1917-1973 by James Pollock[1], Sons and Co Ltd building a range of tugs, coasters and lighters and vessels for WWII, and then by Southern Shipbuilders building trip boats for the Thames. The site is now partly occupied by housing and partly by a business area

The subsection on pilgrimages mentions Tonge and Sittingbourne but there is no mention of Ospringe which was a very important stopping place on the pilgrim route from London and beyond to Canterbury.

Suggestion: After the last para about Tonge (para 3 on page 38) add:

‘Ospringe was also important on the pilgrimage route from London and beyond to Canterbury and subsequently as a stopping off point for royalty. On both sides of the road was the Maison Dieu, a pilgrim ‘hospice’ with facilities for travellers of high rank. Part of this still exists as the Maison Dieu museum while the larger part has been excavated and lies under Waterstone Place on the north side of Ospringe Street.’

There is no mention of the Faversham Creek branch line built 1866 which served the industry at Faversham Creek including quays at Iron Wharf.

Suggestion: At the end of the first para on page 40 add:

‘Faversham also had an industrial branch line railway branching off the mainline close to the engine shed and carriage shed. This was built in 1866 and extended via a bridge over Whitstable Road and down Abbey Fields to Iron Wharf and then along Standard Quay to Belvedere Road. The steep bank alongside Faversham Recreation Ground is a reminder and there is other evidence in remaining tracks at Standard Quay and the line of the route through Iron Wharf boatyard.’ We understand that there is a turntable in this group of buildings.

Suggestion: Priority 2 about using heritage as part of regeneration is not included in any of the section introductions. It fits best here.

On page 68 there is no reference to the Maison Dieu museum at Ospringe. This is now run by a separate trust and has a museum containing finds from archaeological digs in and around the village.

Is it possible to add to the buildings at risk at this stage? Examples such as the complex itself and about local excavations on some brickmaking sites. Also 114 West Street, Faversham which is in a very poor state of repair?

On the items taken off the list since 2009 on pages 9-10, is it possible to complete the set of photos and also to say a little more about what happened to the buildings, perhaps with links to the relevant implemented planning applications/other works carried out.

We ‘wonder’ whether we might insert a mention of the agriculture-based businesses which flourished in the town from the mid-19th Century until the 1970’s and which arrived here because of the port.

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[1] The Faversham Society is included in a National Maritime Museum application for funding to create a catalogued archive of the Pollock papers.

The Faversham Society writes to object to JB Planning Associates Article 13 Application for Planning Permission to develop 180 dwellings, “internal access roads, footpaths, cycleways, open space and landscaping, drainage, utilities and service infrastructure works.”
We have the following major concerns
• Access
The developer’s notice in the newspaper says that “All detailed matters are reserved for subsequent approval except for access to Abbey Fields”. Has this access already been agreed?
Access is difficult through Abbey Fields or requiring a new bridge over the railway line. Abbey Fields is narrow and in poor condition and exits on to Whitstable Road at an already dangerous junction with poor sightlines.
• The setting of the town.
Faversham is a traditional market town set within an agricultural landscape. This setting has been lost to the south and west of the town through housing developments. FM7 lies to the north-east, from the Saxon Shore Way there are views of Faversham in its creek setting. The views across Abbey Fields to St Mary’s of Charity are important to Faversham’s sense of place.
• Flood Risk
This area is reported to have flooded in 1953 with climate change and the plans for managed realignment the risk of flooding is heightened. The developer should not be permitted to develop housing leaving the costs of flood defences and post-flood restoration to the public purse or other householders through increased insurance changes
• Conservation.
The site is adjacent to the Conservation Area, listed buildings and part of the site is within the locally designated Abbey Fields Local Wildlife Site. It lies within the Goodnestone Grasslands landscape character are and is adjacent to the AHLV – Kent Level within the Swale and surrounding marshes, a status re-confirmed in the 2019 study.
• Landscape Sensitivity.
We dissent from the assessment of the site as “moderate-high overall sensitivity to future change from residential and employment development.” In our view, the site is highly sensitive and important to Faversham’s identity as a historic market town at the heart of a high-value agricultural area.
• Development Constraints
In the unfortunate event that that permission is granted then all of the Guidance on page 342 of the Landscape Sensitivity Assessment on the agenda of the Local Plan Panel Meeting of 27 November, 2019 should be applied.

The Board of the Faversham Society on 26^th November discussed the three conditions for which EKR have made submissions and which are currently the subject of public consultation.

The Faversham Society does not have any comments in respect of the following:

KCC/SW/0249/2019 Condition 53 Complaints procedure

KCC/SW/0248/2019 Condition 47 Landscaping.

However, the Society has concerns about the submission on condition 28 as below:

KCC/SW/0237/2019  Condition 28  Noise management

Condition 28 requires that the monitoring locations of noise generated by the plant reflect the nearest noise sensitive receptors to where the site operations will be carried out. The monitoring period shall be a minimum of two non-consecutive measurements of 15 minutes duration at each location. Noise monitoring shall take place during normal working periods and checked to confirm that the measurements were taken during normal working periods. There is a requirement in the condition to provide written reports to the Waste Protection Authority within one month of the date of each monitoring visit. If noise exceeds the permitted limits, there is a need to set out and implement the steps required to reduce the levels to those set out in condition 27.

There is also a condition about making sure the plant operates at the correct noise levels when it is in operation.

The sensitive sites for monitoring identified by the applicant include Pheasant Farm on Church Road, Oare and the Oare Lakes residential development. At present, the monitoring site for the Oare Lakes development is shown on Ham Road next to the nearest part of Goldfinch Close. There is a process set out for what needs to happen if the noise exceeds the required level involving working with KCC.

These are reasonable locations at present. It is stated that the applicant will move the Oare Lakes monitoring station when the site is completed and occupied. There is no indication where this will be moved to but the nearest houses to the active parts of EKR will be in phase 2 of the Oare Lakes development. The houses in phase 1 which are being built are a lot closer to the EKR plant than the initial location for the sound monitor in Ham Road and some of these houses are likely to be occupied within the next six months or so. It is recommended that KCC should ask for the location of the relevant noise monitor to be moved towards the further end of the present Evers Road as soon as phase 1 starts to be occupied and then again when the houses in phase 2 are built in the extension to Evers Road (or any closes which are nearer to the plant).

Prepared by
Anne Salmon BA  MCD  MRTPI