Regulation 19 Walk Through
Our countryside.
Our future.
Our evidence.
Why BeesNotWasps is asking for Pedham Place to be removed from the Local Plan allocation — and why we believe the Inspector should test the evidence carefully.
The Council's Regulation 19 Plan proposes Pedham Place as a standalone settlement of approximately 2,600 homes, with employment, education and community facilities. The site is within the Green Belt and Kent Downs National Landscape.
The central question
The question is not simply whether the site can be designed attractively. At Regulation 19, the issue is whether the Local Plan has demonstrated that this allocation is justified, effective, positively prepared and consistent with national policy — and whether the evidence supports the scale and location proposed.
A new settlement in protected landscape
Pedham Place is proposed within the Green Belt and Kent Downs National Landscape. The Council accepts that the site does not fit the normal development strategy and says the case for including it rests on meeting housing need and securing strategic infrastructure.
2,600 homes is strategic-scale growth
This is not a small village extension. It is a new settlement-scale allocation with schools, employment, a local centre, open space, transport measures and other infrastructure. The evidence therefore needs to demonstrate that the whole package is deliverable and sustainable.
Junction 3 and the wider network matter
The site's relationship with M25 Junction 3 is central. BeesNotWasps believes the Inspector should consider the cumulative effect of Pedham Place alongside other planned and committed growth, rather than treating individual highway interventions in isolation.
“Least harmful” is not the same as “no harm”
The Council's earlier assessment concluded that concentrating growth at Pedham Place could be the least impactful of the National Landscape options. That is a comparative conclusion — not a finding that the development has no significant landscape or visual effects.
Promises need delivery mechanisms
Schools, public transport, health, utilities, roads, walking and cycling infrastructure and community facilities are part of the justification for a new settlement. The Plan should make clear what is required, who delivers it, how it is funded and what must happen before occupation.
Nature and environmental constraints
Development at this scale must address biodiversity, habitats, landscape character, water, drainage and recreational pressures. The environmental evidence needs to demonstrate that impacts can be avoided, mitigated or compensated in a credible and deliverable way.
The evidence — not the slogans
A credible campaign should distinguish between what the Council says, what the evidence actually establishes, and what remains a matter for the Inspector to test.
What the Council says
Including Pedham Place is presented as necessary to meet the District's housing requirement and as capable of providing strategic infrastructure, including education, employment, community facilities and improvements around M25 Junction 3.
What BeesNotWasps asks
We ask whether the evidence is sufficiently robust, coordinated and deliverable to justify allocating a strategic new settlement in protected landscape — and whether reasonable alternatives have been properly tested.
Landscape
The Council's own earlier evidence records significant landscape impacts across the options assessed, while identifying Pedham as comparatively less harmful. That distinction matters: comparative preference does not remove the need to demonstrate compliance with the National Landscape policy framework.
Environmental assessment
The Regulation 19 evidence base includes a Habitats Regulations Assessment. This should be read alongside the site's biodiversity, landscape, water and recreational impacts rather than treated as a substitute for considering the whole planning case.
What does “sound” mean?
At Regulation 19, residents are not being asked simply to vote “for” or “against” development. The Planning Inspector will examine whether the Plan meets the statutory and soundness tests.
| Test | Question for Pedham Place | Our evidence-led concern |
|---|---|---|
| Positively prepared | Does the Plan meet assessed needs and deal appropriately with cross-boundary matters? | Has the Council demonstrated that the chosen strategy and the scale of Pedham are the right response, rather than simply the route to reaching the housing number? |
| Justified | Is the strategy based on proportionate evidence and a reasonable comparison of alternatives? | Is the exceptional case for a major development in protected landscape sufficiently evidenced, including the alternatives and the consequences of choosing them? |
| Effective | Can the allocation actually be delivered as planned? | Are transport, education, health, utilities, public transport and other infrastructure supported by clear delivery, funding and phasing mechanisms? |
| Consistent with national policy | Does the Plan follow the relevant national planning policy framework? | Has the Plan demonstrated that the environmental, Green Belt, National Landscape, transport and sustainability consequences are appropriately addressed? |
Modify the Local Plan so that Pedham Place (ST5-2) is removed as an allocation, unless and until the evidence required to demonstrate soundness is robustly established.
Why the cumulative impact matters
Pedham Place does not exist in a vacuum. Its effects need to be considered alongside other growth already planned or proposed in the area, particularly where journeys converge on the same strategic and local highway network.
For BeesNotWasps, this is especially important around M25 Junction 3. A highway scheme may improve a particular movement or junction, but that does not automatically demonstrate that the wider network can accommodate the combined demand from multiple developments over time.
The Regulation 19 representation should therefore ask the Inspector to consider cumulative traffic, junction performance, rat-running, village impacts, public transport capacity and the timing of mitigation.
Make your Regulation 19 response count
You do not need to be a planning expert. The most useful response is your own words, focused on a specific policy or allocation, explaining why you think a soundness test is not met and what should change.
1 · Find ST5-2
In the Council consultation, look for Policy ST5 / ST5-2 Pedham Place and the supporting Development Brief.
Open the Regulation 19 consultation ↗2 · Explain the problem
Choose the relevant test — positively prepared, justified, effective or consistent with national policy — and explain the evidence behind your concern.
3 · Say what should change
For example: “Modify the Local Plan to remove Pedham Place (ST5-2) as an allocation under Policy ST5.”
4 · Submit by the deadline
11:59pm, Thursday 17 September 2026. Keep a copy of your submission.
Read the primary sources
These links are deliberately weighted toward Sevenoaks District Council's published material so readers can check the evidence themselves.
Regulation 19 consultation
Official consultation page, documents and response route.
Open consultation ↗Local Plan evidence base
Includes the Regulation 19 Habitats Regulations Assessment and National Landscape evidence.
Open evidence base ↗Pedham Place proposals
Sevenoaks District Council's overview of the proposal and supporting documents.
Open Pedham Place page ↗Important distinction
The former Wasps stadium proposal is not the same thing as the current ST5-2 allocation. The Regulation 19 case presented here focuses on the proposed Pedham Place settlement allocation itself.
One final message
We are not asking people to rely on slogans. We are asking residents to look at the evidence, ask whether the Plan has proved what it needs to prove, and make a clear representation to the Planning Inspectorate through the Regulation 19 process.
🐝 Let's not let Pedham Place disappear quietly into the Plan. Let's put the evidence in front of the Inspector — and make the case for protecting our Green Belt, National Landscape, wildlife, villages and already-pressured infrastructure.
This page is campaign information, not legal or planning advice. Always check the Council's current consultation documents and make your Regulation 19 representation in your own words.