1         The proposal in its local context

Ordnance Wharf sits within the Faversham Conservation Area. The view of Davington Priory from the creekside footpath would be destroyed by the building proposed.

This image of the Priory taken 18th July from the public footpath on Morrison's Quay reveals that the proposed development would block this iconic view of Davington Priory and the remains of the walls which surrounded the gunpowder factory with a permanent obstruction. The trees currently block some of the view but a) they are impermanent and b) seasonal.  The autumnal view below demonstrates this.

This was the view in November 2018

This view was taken in September 2018. It reveals the richness of the flora before the developer tore up the land. It was the developer who despoiled the site with rubble.

 This is a view of the same land taken in April 2019 on the left and another part of it very recently on the right.

There is also the question of what the development would look like from Stonebridge Pond. It will tower above the trees. This is the view across Stonebridge Pond towards the creek and Ordnance Wharf.

2         The proposal is incomplete

The developer should provide accurate scale drawings, and photo montages, showing how the proposed development relates to the Purifier Building, the Priory, the walls of the gunpowder works on Flood Lane and the impact of the view across Stonebridge Pond. Calculations demonstrate that the developer’s sketches significantly misrepresent the height of the buildings which will tower over the adjacent Purifier building. This is the sole remaining building of the gas works and is put to excellent use by the Faversham Creek Trust for community boat building, maritime employment and education.  The application is of four storeys in contravention of the planning policy for the site.

A detailed Heritage Statement should form part of this application since the Wharf was identified as an undesignated heritage asset under the Creek Neighbourhood Plan, and it also stands within the designated heritage asset of the Faversham Conservation Area. Works that alter it will, therefore, have an effect for better or worse on its architectural/historic character and also on the character of the Conservation Area. A Heritage Statement should be required before the application is considered.

There is very little detail in the submission about the foundations necessary to support the proposed buildings. The walls of the Wharf are crumbling, and significant works will be required to stabilise the Wharf. Ordnance Wharf has previously never borne substantial buildings. Some of the masonry in the wharf retaining wall appears to be archaeologically significant, with bricks supported on timber, and should be restored rather than obscured by piling. We submit that a schedule of works is required for the repair and strengthening of the historic wharf walls. Piling is likely to further damage the revetment and may put at risk the stability of  the adjacent Purifier building.

The small tongue of land on which Ordnance Wharf is built was formed by the scour of the two channels on either side, stirring up silt, and the slack water between the two channels causing the deposition of this silt. Ordnance Wharf is, in short, a mud bank. In Jacob's 1774 map of Faversham, it is a simple, roughly triangular spit. The 1822 map shows the natural form of a mud bank. By 1842, however, according to the well-surveyed tithe map of 1842, it has a regular squared- off shape implying the building of a revetment, and it is named Island Wharf, which implies usage by vessels.  The 1867 map (below) shows this artificial form very clearly.  The revetting is brick, and a great deal of hardcore must have been deposited inside the brick walls to create a flat and firm surface.

3         The proposal is inaccurate

The Council should ensure that accurate ownership details of the site are provided by the applicant as the site is understood to be in multiple ownership.

The development is described as three-storey. In fact, it is four storeys with parking on the ground floor. [A storey describes any level part of a building with a floor that could be used by people (for living, work, storage, recreation, et cetera).  The Ordnance Wharf Site Specific Policies in the local plan [OW2] specifies "no new building shall be more than three storeys in height."

The accommodation is very large and much larger than an average three-bedroom house. The proposal is not warehouse in style it is rather similar in kind to the housing which has been built all along the creek undermining the town's gateway sense of place.

The description of the area as "industrial and commercial" is inaccurate as is evident from a cursory look at a street map or at the comments on the application there is a large number of homes local to the site.

The flood risk is greater than acknowledged in the application.  Spring tides regularly overtop the banks on the east side of Faversham Creek as well as the nearby sluices between the Creek and Stonebridge Pond.  The site is in an area already designated as High Risk by the Environment Agency, which means that it may be difficult to insure properties built there, and the risk will only increase as a result of the continued rise in sea levels that is projected in coming decades.  KCC[1] currently estimates that that rise will be 0.8m by 2080.

No mention is made of the plans for the regeneration of the creek by creating employment opportunities through maritime heritage, boat building and restoration, and tourism. 

4         Creek Regeneration

This housing development is incompatible with the development of the basin for maritime regeneration, a purpose for which a considerable public investment is imminent. KCC is preparing to install a moveable bridge to permit the movement of barges and other craft in and out of the basin providing access to the Purifier Building.  Councils are preparing to spend millions of pounds installing an opening bridge to facilitate regeneration through marine and other associated employment. Local people raised £125,000 for maritime regeneration of the creek basin. If the land around the basin is used for housing development, then there will be resentment in town that the principle beneficiaries will be a property developer and the occupants of a small number of expensive dwellings.

Housing is not sustainable development.  Construction briefly creates jobs but housing does not create employment or economic regeneration. With very large numbers of new houses being built around Faversham and more expected, 7 expensive dwellings makes no significant contribution to meeting housing targets set by central government and will certainly not meet local housing need.

Plans for the installation of an opening bridge to permit large craft to enter the basin are at an advanced stage. The public subscription of £125,000 was raised in a few months on the promise that a swing bridge would bring maritime regeneration. KCC, Swale and Faversham Town Council all supported this regeneration plan and agreed to fund it.

Just this week our MP secured the backing of Transport Ministry Kelly Tolhurst for the scheme for creek regeneration. The regeneration plans are backed by three layers of local government and by national government. If this application is approved, the creek regeneration plan cannot be realised. We do not think that it is the responsibility of the planning system to enable developers to profit from unwise speculative investments in land. Public money, both from taxation and public subscription, should be used for public benefit. If this planning application is approved and the swing bridge is installed the public value will have been transferred to the developer.

5         Biodiversity

In March 2020, Faversham community groups working with the Environment Agency (EA) installed eel passes on the sluices that feed the two branches of Faversham Creek 20-30m upstream of Ordnance Wharf.  The European eel (Anguilla anguilla) is a Critically Endangered species. The EA has identified improved passibility of sluices and other barriers to be the biggest contribution that the UK can make to eel conservation, and the Kent Nature Partnership has identified improved access to freshwater habitat for eels as one of its immediate priorities. Nothing should be done at Ordnance Wharf that has a negative impact on eel movements, including in particular the annual arrival of migrating elvers seeking access to the freshwater habitat in Stonebridge Pond and beyond.  That should include assessing the impact that artificial lighting from any new development on Ordnance Wharf might have on arriving elvers (which navigate by the moon) or on mature silver eels as they leave Stonebridge Pond at the start of their marathon journey to the Sargasso Sea.

Given its location and the fact that the land has been undisturbed for several decades, a comprehensive biodiversity assessment of the site should be conducted before planning permission is considered.

6         The proposal is deficient

Ordnance Wharf is a prominent Creekside site at the edge of the historic core and any development should either have a minimalist, unobtrusive style or reflect the varied vernacular architecture of the town as analysed/established by the Duchy for their potential development.  Faversham Creek is not a street but some of its banks have unfortunately been developed with brick and weather boarded housing of a standard design that has contributed nothing to Faversham’s sense of place.  To permit more such housing on the Creek is to compound the errors of the recent past and cause further harm to Faversham’s individuality.

There is limited street parking, and the use of car parking spaces for dinghies cannot be permitted if Swale parking standards are to be complied with.  For properties of this value two car parking spaces per property and some visitor parking should be required. There is very limited on-street parking available locally. KCC points out that there is not the 6m reversing space.

The FCNP OW4 requires public moorings.  The proposal does not include public moorings. Nor could any be included due to the fact that moorings are prohibited by covenant on the Purifier side of OW and access to other sides is restricted by the proposed housing.

Vehicular access on to Brent Road/Hill will be problematic particularly given the proposed shared use of Flood Lane for vehicles and pedestrians. Flood Lane provides essential access for residents from the Upper Brent estate to Morrisons and provides a smooth and safe route for pushchairs, prams and wheelchairs. The tarmac should not be removed and no obstruction of the PROW should be permitted during the construction period or subsequently. .

Particular attention needs to be paid to the evacuation of sewage and wastewater from the site.  It goes without saying that there should be no releases of any sort into the Tidal Basin.

Is there sufficient access for fire engines in the event of a fire on Ordnance Wharf?

Bollards prevent through vehicular traffic along Flood Lane and for safety and amenity reasons they must be retained.

Is the bridge on Flood Lane closest to Brent Road strong enough to carry the construction traffic that would need to cross it to access the site?

Ordnance Wharf was part of the town's gunpowder industry; the clue is in the name. The Wharf lies between the two outflows from Stonebridge Pond that powered the watermills which ground gunpowder. The proposed development makes no contribution to maintaining and interpreting this important part of our heritage.  FCNP OW8 requires that "the development should be designed to preserve or enhance evidence of the site's historic role as part of the Home Works as wharfs" and "provision for the conservation of the 18th Century wharf walls and stone crane base with a wharf-edge space and revealing identified archaeological remains and publicly accessible space." The proposed development will obliterate that heritage.

On pages 7 & 14  of their report ,Ground and Environmental Services Ltd recommend further intrusive  investigation  of the site for ground contamination.  It seems there was limited investigation below the former oil tanks; there must surely be a risk of leakage into the creek, and possibly groundwater as works are undertaken 

This 1952 diagram of the Wharf suggests that there is good reason for concern

Professor Ian Grant in his objection notes that the EA requires more detail on flood risk and Groundwater Protection. We agree.

The site is not suitable for a dingy sailing club as is explained in Eldon Hinchcliffe's objection and in conclusive detail in the Faversham Creek Trust's submission.  We regard this part of the proposal to be no more than an inappropriate and impractical gesture. It is likely that the club would fail and be repurposed for the benefit only of the residents.

There are no details of the community use nor ownership of the café and meeting room. More detail is required to demonstrate that this is a serious intent and can be achieved. Or is it the case that the community use is to be restricted to residents and their guests?

7         If planning permission is granted……..

The Faversham Society is implacably opposed to this development for all the reasons cited above.

Before permission is granted there needs to be a thorough assessment made of contamination risk given that part of the Purifier for the gas works was sited on Ordnance Wharf.

If the development is permitted SBC needs to ensure that the public rights of way be legally protected. SBC holds legal title [K708886] over some of the land included in the development. Legal title [74625] included a covenant guaranteeing: "A right of way at all times and for all purposes over and along " Flood Lane.

Legal title K549889 included a covenant protecting free access to the creek. If planning permission is granted then this right needs to be protected in the permission to ensure access rights for the Faversham Creek Trust at the Purifier Building and for barges to moor beside the Purifier Building once the opening bridge is installed.

The proposed walkway on both sides of the development and the under croft passage should be legally defined as unrestricted, public rights of way. The development is almost a gated community which will deter people from entering as has occurred in the developer's properties on Belvedere Rd.

A covenant is required to safeguard the current uses as per the planning conditions for the Purifier. Otherwise, there is a risk that residents in the accommodation will seek to remove industrial use. The planning consent for the Purifier permits heavy metalwork.

There is apparently no §106 gain despite the fact that the developer will secure substantial benefits from the local councils’ and residents’ funding for the moveable bridge. As the principal beneficiary of the opening bridge, the developer should be required to make a substantial contribution to the cost of the bridge, sluices and dredging of the basin.

[1]  https://www.kent.gov.uk/about-the-council/strategies-and-policies/environment-waste-and-planning-policies/environmental-policies/kents-changing-climate