Summary Information
We are of the view that the site allocations in East Peckham should be removed. They are not justified or consistent with national, regional or local policy or guidance and are weighted in favour of housing provision There is no meaningful consideration given to the associated risks/threats. There has been no, or very little regard to balancing the provision of housing alongside:
Flood risk
Design
Loss of high quality
biodiversity and habitats
Highways
Geotechnical feasibility
Extend of any mitigation
measures
Settlement Strategy
Utilities Provision
Increased carbon
emissions
Social Infrastructure
Land Ownership
Increased private vehicle
use
The Parish Council questions the deliverability and sustainability of the proposed site allocations. Flooding and other constraints mean that the scale cannot be delivered safely and without unreasonable mitigation measures.
The draft Local Plan fails to adequately assess other more suitable sites with
- lower flood risk, or demonstrate that sequential testing has been undertaken
- with better transport connections and infrastructure
- which do not have a significant a negative impact on the natural environment,
- the worsening climate crisis with severe weather events increasing in severity and frequency,
- not all the proposed allocated land is offered by the owners for development, indicating a failure to identify suitable available land.
The key issues are considered in detail below. (Click the + symbol to expand each area.)
Key issues in detail:
Flooding
East Peckham site allocations fail to comply with the avoidance of flood risk areas. Development within East Peckham runs contrary to national policy and guidance. As East Peckham is an area of highest flood risk, TMBC should direct development away from such areas. East Peckham experiences the worst flooding of Parishes in the Borough. Flood risk translates to real risk to people’s safety, homes, livelihoods, the local economy and pollution threats. With the impact of climate change this position will worsen.
Please quote any of following policies if appropriate, to add weight to your submission:
National Planning Policy Framework (NPPF paragraph 170) | “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future)”. |
NPPF (paragraph 174) | “Within this context the aim of the sequential test is to steer new development to areas with the lowest risk of flooding from any source.” |
Site Specific Flood Risk Assessment Checklist (Practice Planning Guidance (PPG)) | “Safe access and egress will need to be demonstrated at all development sites. Emergency vehicular access should be possible during times of flood.“ “…. the LLFA would expect all efforts to have been made to place property outside of known areas of flood risk in line with the sequential approach.” |
The Sustainability Appraisal Scoping Report | notes at para 2.30 the requirements of the NPPF to avoid inappropriate development from areas at risk of flooding. |
Para 3.4 Sustainability Appraisal Scoping Report | “The consequences include predictions of warmer, drier summers and wetter winters with more severe weather events all year, as well as higher sea levels and increased river flooding.” |
TMBC Sustainability Appraisal objective 8 | To protect and enhance the water environment and reduce flood risk |
TMBC) draft Local Plan Policy CC7 and CC8 | require avoiding flood risk areas and using Sustainable Urban Drainage Systems (SuDS) for all developments |
Schools / Education
East Peckham Primary School is already full based on local records, with multiple cases of village children unable to secure places (2025/2026 intake) due to insufficient places. There is currently no provision for additional school provision for EP.
Please quote any of following policies if appropriate, to add weight to your submission:
CP25 | Infrastructure must be in place when needed |
TMBC Sustainability Appraisal 3 | To ensure access to educational facilities and support skills and training development for all age groups and all sectors of society |
Healthcare
East Peckham has no GP surgery or Dentists and is reliant on surrounding practices.
Please quote any of following policies if appropriate, to add weight to your submission:
NPPF paragraph 100-101 | Requires capacity assessment and community infrastructure planning.
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Traffic and Highways
East Peckham has limited connections to public transport. The nearest train station, Beltring is 2.4km from the site, and is not a commuter station and is unmanned. Public transport service from East Peckham is inadequate. East Peckham will become a “commuter town”.
Roads are already at capacity, raising concerns whether local road infrastructure can support the proposed growth. 586 new houses in an area without good public transport will encourage car dependency and increased traffic congestion. This is against TMBC’s policy of reducing private transport.
Please quote any of following policies if appropriate, to add weight to your submission:
| TMBC Sustainability Appraisal 13 | Promote Sustainable Transport and reduce the need to travel by car. |
Water and Sewerage
South East water does not perform well providing to existing numbers of residents.
Village Character
East Peckham is made up of nine distinct hamlets. The allocations will effectively merge Hale Street and Snoll Hatch with the main village. This risks losing the identity of the village and compromising the anti-coalescence that defines the design of the Parish.
Please quote any of following policies if appropriate, to add weight to your submission:
| TMBC Sustainability Appraisal 6 | Protect and enhance landscape character and quality |
Housing
There is no no clarity about how the housing requirement for East Peckham has been calculated or the assessment of local housing need in East Peckham
Please quote any of following policies if appropriate, to add weight to your submission:
TMBC Sustainability Appraisal 14 | To provide a suitable supply of high quality housing including an appropriate mix of sizes, types and tenures to meet local needs |
Sustainable Development
Site allocations for East Peckham do not deliver sustainable development; Traffic/highways, destruction of woodland, wildlife and habitat, climate change, and reducing greenhouse gases.
East Peckham has limited services and poor public transport. East Peckham is not a sustainable location for the quantity of growth allocated. The rural position of East Peckham limits the potential of any “active transport strategy” (i.e. cycling, walking) as proposed by TMBC. Reliance on private vehicles is increased and exacerbates climate change issues.
The proposed housing allocations adjacent to Coult Stream will introduce significant ecological pressures through chemical runoff, artificial lighting, and noise disturbance, harmful to riparian corridors and woodland strips.
The East Peckham proposed site allocations do not support TMBC’s stated environmental priorities, including climate neutrality, air and water quality protection, and biodiversity recovery.
Please quote any of following policies if appropriate, to add weight to your submission:
TMBC’s Plan incorporates Sustainability Appraisal (SA) Objective 10: Climate Change Mitigation | Aims to reduce and minimise greenhouse gas emissions, achieve carbon neutrality for TMBC and the borough by 2030, and promote sustainable modes of transport, such as walking, wheeling, and public transport, while reducing private car use. |
NPPF para 8 | Deliver sustainable development in key areas |
TMBC Sustainability Appraisal 5 | Requirement that growth strategies be sustainable and aligned with climate and biodiversity priorities. “protect and enhance biodiversity and geodiversity” |
Climate Change
The Government’s UK Climate Change Committee warned on 15/10/2025
“The need to strengthen the UK’s adaptation objectives is both essential and urgent. Objectives should, at a minimum, prepare the country for the weather extremes that will be experienced if global warming levels reach 2°C above preindustrial levels by 2050. Reaching 4°C above preindustrial levels by the end-of-century cannot yet be ruled out”.
The proposals for EP do not address the increased emissions associated with building in an area prone to flooding, increased car dependency in a rural area, and increased frequency and intensity of severe weather events.
Please quote any of following policies if appropriate, to add weight to your submission:
The UK Climate Change Committee warned the Government of 15/10/2025 | “The need to strengthen the UK’s adaptation objectives is both essential and urgent. Objectives should, at a minimum, prepare the country for the weather extremes that will be experienced if global warming levels reach 2°C above preindustrial levels by 2050. Reaching 4°C above preindustrial levels by the end-of-century cannot yet be ruled out and should be considered as part of effective adaptation planning”. |
UK Climate projections 2018 for Kent County | identified increased average winter precipitation of 10-20% by 2040 |
Climate Change Risk and Impact Assessment for Kent and Medway | It notes a 20-30% increase in winter rain fall by 2080 |
TMBC Sustainability Appraisal objective 8 | To protect and enhance the water environment and reduce flood risk |
TMBC Sustainability Appraisal objective 10 | To reduce greenhouse gas emissions to help tackle the climate emergency and contribute to becoming a net zero carbon borough |
TMBC Sustainability Appraisal objective 11 | To reduce vulnerability to the adverse effects of climate change through adaptation |
TMBC Sustainability Appraisal objective 13 | To protect material assets and minimise waste |
TMBC Sustainability Appraisal 12 | To reduce levels of and exposure to noise, light and air pollution |
Green Belt
Has all non-Green Belt land in the Borough been allocated for development, and has TMBC prioritised lower performing Green Belt land elsewhere in the Borough?
If sites are reclassified to Grey belt, 50% affordable housing will be required: Is this realistic and achievable? Too often some developers claim they cannot afford to deliver previously agreed levels of affordable housing.
Destroying established green space for new development is counterintuitive, because the reclassification of the land to grey belt would require new accessible green space contributions to be made).
There will be a massive detrimental impact on the biodiversity and wildlife in respect to the proposed site allocation EP2 (sites 68376, 58751 and 59789) contrary to the requirement for developments to generate a net 10% biodiversity gain (Environment Act 2021).
Please quote any of following policies if appropriate, to add weight to your submission:
NPPF Altering Green Belt boundaries | Requires exceptional circumstances and must not fundamentally undermine the purposes of the remaining Green Belt across the plan area. Greenfield sites should only be removed in sustainable locations to meet development need. |
The Natural Environment
Detrimental impact on the biodiversity and wildlife in respect to the proposed site allocation EP2 (sites 68376, 58751 and 59789).
Please quote any of following policies if appropriate, to add weight to your submission:
Natural Environment and Rural Communities (NERC) Act 2006 (as amended) | Section 40 places a duty on all public authorities to have regard to the purpose of conserving and enhancing biodiversity |
Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006 priority species. | Protection of key species including turtle doves and nightingales |
Policy NE1 | Recognises the value of the natural environment |
NPPF section 15 para 192 | (a) safeguard components of local wildlife-rich habitats and wider ecological networks… national and locally designated sites of importance for biodiversity; wildlife corridors…. and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation. (b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species |
NPPF section 8 para 96 | Emphasises the importance of the natural environment and green infrastructure for health, well being and quality of life |
KCC Tree Strategy | Aims to avoid loss of tree stock |
Green and Blue Infrastructure Strategy | Assesses site 58751 (Henham/Coult stream) as an accessible local green space, and part of the green infrastructure. |
TMBC Sustainability Appraisal 5 | To protect and enhance biodiversity and geodiversity |
TMBC Sustainability Appraisal 12 | To reduce levels of and exposure to noise, light and air pollution |
Draft Documents for Residents
Please Note:
These documents are in ‘Draft’
Last updated 3rd DEC 2025.