Planning process response

The Kings Hill phase 3 planning application is currently lodged with Tonbridge & Malling Borough Council and is open for public consultation. Our two clergy, Pat and David, have drafted their own response to the proposals and sent it to TMBC as well as circulating widely amongst interested stakeholders. It is reproduced here in full for the community’s wider interest.

1 July 2013

Public Consultation on Planning Application TM/13/01535/OA

Thank you for the invitation to comment as part of the Public Consultation period now underway concerning the remaining land use on Kings Hill. This document constitutes our official response as the local Church of England clergy who minister on Kings Hill.

The Church of England is committed to ecumenical partnership wherever possible and we work with a whole host of other denominations and faith groups nationwide. However, the Church of England also has a duty under Canon Law to provide a priestly presence and place of worship for the whole community. Uniquely, in this country, the Church of England is the Established church which gives a role in civic and social life that is not the privilege of other faith groups. As a result, we see our ministry to encompass everyone who lives in a particular place; not just those who worship on a Sunday. As a result of a Joint Working Group between the Church Commissioners, Department for the Environment and the Dioceses, it has been accepted that these duties may be a material planning consideration.

Provision of a Primary School and worship space

Should this Planning Application go ahead, we think it is absolutely vital that the provision of 1,000 additional homes must be accompanied by plans for a new Primary School and we welcome that particular proposal from the Applicants. Given the demographics of Kings Hill1 and the increase in population from the development of even more homes, it will be imperative that a third school is provided.

We note that within the Statement of Community Involvement from the Applicants, there were a number of responses seeking additional community facilities including four responses requesting the provision of a space that could be used for church worship and community use.2

It is a shame that, within the Applicants’ response to Consultation Feedback3, no response is specifically made to this proposal for worship space. But, as the document makes clear, the Diocese of Rochester has already submitted a proposal to the Local Authority to provide a Voluntary Aided Church school at Kings Hill in line with the proposals made by this Planning Application.

In that submission, the Diocese of Rochester has proposed that the Church would provide a building as part of the new school that would provide worship and community facilities (an additional area requirement of 500m2) to include hall/worship space, flexible meeting rooms, office, kitchen, toilets and storage. It remains our hope that this additional facility for the school would provide a visible, iconic church structure for the whole community of Kings Hill to enjoy and utilise.

In one sense, such community use of sacred space is a welcome return to our historic past. In our contemporary setting, a further community space in such a place of worship might enable everything from toddler groups to care for the elderly, a bookable space for everything from birthday parties to community meetings. Such widespread community use would sit square with the Church of England’s understanding of its own mission. We exist not just for those who choose to worship with us Sunday by Sunday but for the entire community. We are wholehearted in our belief that community development is important to a full understanding of what it is to be human.

In regard to the proposal for the new School, we are very much aware that the Local Authority are free to either put forward a proposal for a VA Church school without the consent of the Secretary of State or run a competition process for an Academy or Free School proposal. In either scenario, we stand ready to work alongside the Diocese to make a compelling bid for the right to provide the new school being envisaged within these planning documents.

Section 106 land in Area 308

In the original designs for Kings Hill, a large portion of what is now termed Area 308 was designated at Section 106 land with the potential for a place of worship. This designation has now lapsed and no faith community has been in a position to respond to the offer of land because of the prohibitive costs that were involved in building a place of worship for (what, at that point, was) an embryonic community. Up until now, while the designation has officially lapsed the area has remained available and open for development and we believed there was a sense in which the Applicants (Liberty Property Trust) were open to offers.

In regard to this Planning Application, we simply take note that Area 308 is being designated as ‘Strategic Open Space and Landscape’ and, therefore, we presume that any last chance this land had to be used for a place of worship will be lost. Should our proposal for a Church School move forward with the Local Authority (including its proposal for worship space), the re-designation of Area 308 may be immaterial.

However, it is our understanding that the intent of designating land under Section 106 is to ensure that the community is properly served, including making provision for their spiritual needs. If the Church School doesn’t happen and the Section 106 land is put to other uses, it would mark a significant loss of potential to Kings Hill as a whole and say something quite specific and negative regarding the importance of faith communities to the overall social cohesion of the community and its contribution to social capital… let alone the potential for such family and community events like christenings, weddings and funerals to take place locally on Kings Hill.

Location of the proposed school

Allowing for the fact that we support the provision of a third primary school, we have a number of concerns about the proposed location. Unlike an earlier version of these proposals which envisaged the school in a different space, the proposed site is extremely close to the boundary edge of the development, close to the existing Kings Hill Primary School and quite some distance from all of the residential property envisaged by this proposal. Those properties would also be on the other side of the extremely busy main artery road of Tower View thus creating a need for some sort of pedestrian crossing suitable for small children. In addition, the potential concentration of traffic at the beginning and the end of the school day with two schools in such close proximity (let alone the throughput of commuter traffic in and out of Kings Hill on Gibson Drive) feels problematic.

Should the existing site go ahead and should the Diocese be successful in its bid to run a Church School on the site with additional iconic worship/community space, we are also concerned about the orientation and visibility of the site. The Planning documents propose that ‘the existing tree belt which currently screens the development will be predominantly retained except where removal is required to facilitate the creation of a new vehicular access.’4 To use a Scriptural phrase, there is no point hiding the light under a bushel. If the school and an iconic worship/community space was to go ahead, we would be concerned to ensure the visible orientation of the school and annexed worship space was towards Tower View. That direction offers a far more open space and greater visibility than Gibson Drive and would ensure that such a worship/community space/school and any potential iconic design was clearly visible and accessible. We recognise that the facilities at the site and, depending upon how the site is organised and orientated may ameliorate our concerns and give it a greater “visibility” in the community’s thinking and awareness.

Burial ground

As the local Church of England clergy, we control four open Churchyards between us (West Malling, Offham, Mereworth and West Peckham). There are no civic cemeteries in the nearby area and so we are the two controllers of the only available local burial grounds for Kings Hill.

In our original submission to the public consultation in September 2012, we urged the Applicants to consider the question of burial ground as part of the third phase of development.5 We were deeply disappointed to see that this request was not even mentioned in the Statement of Community Involvement document. It seems to have been airbrushed out of the consultation.

We are acutely aware of the pressure on our available grave space and we are deeply concerned about the proposals from the point of view of the increase in population and what that will mean for the long-term future of our Churchyards. The closure of the Churchyards to new burials will be hastened without further provision of a public cemetery on or near Kings Hill. Their closure will subsequently create a long-term problem for the Local Authority and the local community. We would urge the Local Authority to work with the Applicants to consider this problem.


Unlike the rest of our document, our ‘vested interest’ in the subject of traffic comes purely as ordinary users of the roads of Kings Hill rather than with any form of relevant expertise. Nevertheless, we are not at all convinced by the Applicants’ reassurance in regard to traffic and we regularly experience the clogged access roads in and out of Kings Hill at the beginning and end of the working day. We cannot see how this Planning Application is viable without further consideration of a third arterial route into Kings Hill from East Malling or the north. We do not believe Gibson Drive, in particular, is capable of handling the increase in traffic (if a third school was sited just off the road) and we have concerns about Tower View and pedestrian safety reaching a school from the new residential areas proposed.

In Conclusion

We are grateful for your time and attention to this submission. We look forward to the planning consultation this coming Monday.

With all good wishes

Yours sincerely
Rev. Pat Dickin and Rev. David Green


1 made very clear by the Applicant in CREATING_PROSPERITY_AND_WELLBEING_REPORT-561179
4 SUPPORTING_PLANNING_STATEMENT-561190.pdf, p17, paragraph 4.7
5 Letter to Andrew Blevins, Liberty Property Trust dated 19 September 2012 and circulated widely to KCC, Kings Hill Parish Council, the Diocese of Rochester and other stakeholders.

1 Comment

  1. Very good submission. Completely agree with proposals made.
    The Mission Audit that consulted every household on Kings Hill was overwhelmingly in support in the development of a place of worship and a new primary school.
    There has always seemed to be a reluctance to face the need for a burial ground in or near Kings Hill. It is a vital ingredient to give a new community a sense of belonging and history, that Kings Hill desperately needs.
    Good luck with your proposals. Keep up the pressure.
    Fr Peter Barnett – former priest of Kings Hill.

Leave a Reply

Your email address will not be published. Required fields are marked *