The Faversham News (June 22) led its front page with a photograph of the “eyesore waterfront” and presented an uncritical report on the latest plans to “overhaul ‘ugly wasteland.” The front page was headlined “New creek vision” and “Creekside redevelopment to transform ugly wasteland.”

We beg to differ.  This latest submission is remarkably similar to the one denied planning permission in 2020

Many of you will recall what the site looked like in 2020 before it was turned ugly by the landowner/developer. Perhaps he thought that this would make it easier to get planning permission next time. By allowing trees to establish themselves on the wharf, damage has likely been caused to the historic wharf,

The Society has submitted on flood risk, but there is more work to be done on a wide range of other issues.

If you agree with our critique, please object on the website https://pa.midkent.gov.uk/online-applications/ Search for No: 23/502647/FULL OR write to Swale Planning Mr W Allwood, Swale Borough Council, Planning Department, Swale House, East St, Sittingbourne ME10 3HT

The Faversham Society’s objection in 2020 ran to some 2,500 words and it likely will again. Many of the grounds for objection raised by us in 2020 remain valid.

Contrary to the report in Faversham News, there are no derelict buildings on Ordnance Wharf, the photograph shows the Purifier Building occupied and fully used by the Faversham Creek Trust and the back of Morrisons supermarket.

The site occupies a key position in the Faversham Creek basin and is with the Faversham Conservation Area. In the emerging Neighbourhood Plan, it is identified as a key site for the regeneration of the creek and for a mixed-use development. As is clear from the responses at Reg 14 there is strong public support for the policies on Ordnance Wharf.

Site Policy FAV20 is explicit

1. On Mixed Use
   a. offices and workshops (Use Class E);
   b. residential development (Use Class C3);
   c. A community hall or other community uses (Use Class F2
2. The layout, form and design of development should:
3. enhance the setting of listed buildings around the site, including the Purifier;
4. preserve or enhance the character or appearance of the Faversham Conservation Area,
5. retain features that contribute to special architectural or historic interest, including the early 19th Century wharf walls and stone crane base;
6. take account of the site line towards Saint Mary Magdalene Church, Davington Priory.
7. Development should avoid the loss of archaeological remains in its design and layout and through use of appropriate construction techniques.
8. Development should include a public walkway along the Creek edge, meeting the requirements of FAV15.
9. Development must take account of the high risk of flooding and include appropriate mitigation and avoid putting uses vulnerable to flood damage, including habitable rooms, at ground floor level.

During the Neighbourhood planning process, a number of specific issues were raised which fundamentally affect what is possible on the site.

1. the Environment Agency sets requirements for development to be set back from the water’s edge to allow for maintenance
2. Southern Water has indicated that the layout of the development must ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.
3. The AECOM SEA identified potential land contamination, which would need to be addressed.

The Faversham Society has many concerns about the current application – here presented in no particular order. If you know of other issues that we should take into account in making our representations, please email chair@favershamsociety.org

1. Over Development
   As with the 2020 proposal, this is “overdevelopment”/ The description by the developer is inaccurate. It is not a  “part three storey,  part two storey building”. The applicant is proposing a four-storey building, in an area where three storeys would be in keeping.  the proposed four-storeys will cause significant harm to the Conservation Area and destroy the view from the creekside public footpath on the south bank of the creek to St Mary Magdalene, Davington.
   Piling will destroy the remains of the historical wharfage and risk polluting the aquifer essential to Shepherd Neame Brewery.
   The application asserts that high-density development is required to cover the costs of stabilising the land for building. We submit that the land is not suitable for housing development and that development risks polluting the creak and groundwater aquifers. Not all can or should be developed if it can only be done through overdevelopment.

2. Contamination
   We strongly support the submission from the Environmental Protection Team MIDKENT Environmental Health “There exists an area of localised contamination which may be mobilised during construction and potentially pollute the creek.”
3. Road Access
   Flood Lane is in multiple ownership and unsuitable as an access road and the junction with Brent Hill/Brent Road is dangerous.  
4. Parking
   Parking provision is inadequate the more so because it is planned that some of the car parking be use for boats.
5. Dinghy Sailing Club
   We strongly support Eldon Hinchlffe’s analysis: “A dinghy sailing club requires a waterside site looking over a large enough body of water to stage dinghy racing. It needs plenty of space to store the dinghies on land, and the officer of the day needs to be able to supervise the racing, rescue boats, launching arrangements, etc from the clubhouse. There needs to be space for shower rooms and locker rooms, and of course a bar, bar store, kitchen and club lounge are all needed, so they are sited in places like Seasalter, Whitstable, or on the shores of largish lakes.”
   We fear that the Sailing Club will either not be opened or fail and the space be converted to housing
6. Impact on the Conservation Area
   The views from the public footpath behind Morrisons across Stonebridge Pond and the duckpond to St Mary Magdalene, Davington
7. The Wharf
   We submitted in 2020: “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.

8. Heritage Statement
   The Heritage Statement does not adequately take account of the site’s position in the heart of the Conservation Area, it will negatively impact for almost 360° around the site.
9. Road Access
   There appear to be inadequate turning circles for delivery and refuse vehicles with safety consequences for pedestrian access
10. Building Height
    The applicant is proposing a four-storey building, in an area where three storeys would be in keeping. It appears that the proposed four-storey will significantly  harm the Conservation Area and destroy the view from the public footpath to St Mary Magdalene, Davington
11. Access to the Creekside
    “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.
12. Safeguarding the current use of the Purifier Building
    “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.”
13. Sustainable Design
    Given its location on the creek, one would reasonably expect the green agenda to be addressed, decarbonisation,  solar etc
14. Contribution to the Opening 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.
15. The site is particularly vulnerable to tidal flooding as has now seriously impacted new houses on Standard Quay, recent flooding resulted in them being taken off the market.