1. Impact on Area of Outstanding Natural Beauty (AONB)

I object to the proposal for polytunnels to become a permanent feature of the landscape at Salmans Farm in the strongest possible terms for the following reasons:

The AONB status imposes on SDC a duty of protection, conservation, enhancement and environmental stewardship for those areas of the High Weald AONB within its control. This application flagrantly contravenes those concepts in every respect and raises the question of whether AONB status counts for anything.

The original 2010 consent for the existing polytunnels was granted on a temporary basis due to the limited fertility life of the soil for the proposed activity and nothing has changed.

The Planning officer in 2010 notes in his planning report (SE/10/00517) that:

“The main adverse visual impact of the polytunnells results from the large expanses of shiny, white polythene coverings, which are an eye-catching and obviously un-natural element in the landscape”

I agree with the Planning Officer’s views as expressed above. The Polytunnels do not preserve the landscape. The extent and nature of the development accentuated by the shiny surface of the polythene covers makes them a conspicuous and jarring feature in the landscape.

Further the extensive blocks of polytunnels would fail to meet the high national standards set by AONB policies in both the Framework and Development Plan policy. Their scale, height, form and appearance would further fail to protect both the visual qualities of the AONB and the openness of the Green Belt.

There is a clear pattern of AONB encroachment by stealth: temporary becomes permanent; farming becomes non-soil industry; accommodation facilities become permanent. This is back-door development running roughshod over the planning process and the ultimate goal will be housing.

It was established in the Nashes’ Farm Appeal case that an AONB status trumps most if not all commercial activities, because of the harm they do to unique landscapes which have evolved over centuries and millennia.

AONB’s have the status akin to National Parks, yet one of them in a prime part of England has been sullied by an Agri-industrial development which, after its first temporary approval in 2004 should never have been renewed. Now the site is faced with an application to destroy the AONB for all future generations.

Such a development would set a precedent for polytunnels to be located anywhere, if it is determined that even AONB status could not prevent them. 2. The land needs to be returned to its natural state and made available to local farmers.

A crucial and fundamental reason why this application should be rejected is that in 2010 a temporary permission was only granted for a period of 8 years. The Planning officer in that decision comments that.

“Consequently, not only would harm to the landscape character of this part of AONB be restricted, albeit to 9 months within each year, but there would be no permanent impact on the AONB from the proposals. On cessation of the use in 8 years time, any harm to the AONB would be extinguished. After this, the polytunnels will be removed and the site will become available for an alternative agricultural use”.

As stated by the Planning Officer, there is no intention to allow the harm to the AONB to become permanent.

The basis on which the 2010 decision was made must now be respected and implemented.

Local farmers have maintained, enhanced and worked in harmony with the AONB for the past 500 years.

Local farmers provide local employment and support the local economy.

The land therefore needs to be returned to its natural state and made available to local farmers who will work in harmony with the AONB whilst providing local employment and supporting the local economy.

3. No justification has been provided as to why this operation should not take place on other, less visually sensitive sites or location.

4. The applicant's Visual Impact Assessment (VIA) is flawed in its conclusion. I refer you to the Liz Lake Associates VIA report which has been submitted to you on behalf of the Protect Penshurst group of concerned residents. The report by Liz Lake Associates identifies serious shortcomings in the VIA prepared on behalf of the applicant by David Huskisson. 5. The applicant's Visual Impact Assessment (VIA) could mislead. The applicant’s VIA prepared by Huskisson Brown Associates has been prepared with photographs which could mislead.

Specifically, photographs contained in the report on the sheet labelled “new views” have all been taken in December 2016 and January 2017 during the period when the plastic sheeting is not in place on the polytunnels. These photographs do not therefore show in any way the impact on the AONB when the polytunnels are in place. For a full and true VIA analysis please refer to the Liz Lake VIA.

Secondly, the photographs on the photo sheet dated 2009 contain photos from 2006 – 2009 which have the smaller polytunnels and do not show the new, much larger and much higher polytunnels recently installed.

6. This is not Agriculture, it is an Industrial Operation. This operation does not use the land itself as the soil has been exhausted for many years and the plants are now grown in pots set upon concrete slabs.

This industrial operation does not therefore require the use of AONB land to succeed, it merely requires space, which can very easily be accommodated on brownfield land or low quality non- protected farmland.

7. Vital Information has been withheld by the applicant, from the public Specifically: a) Investment at the land at Salmans Farm b) Figures of economic contribution

8. The vital financial information submitted, but withheld from the public by the applicant, has not been independently verified. For any reliance to be placed on this information it must be externally audited. Until this is completed it cannot be relied upon as a true and fair representation of the economic facts.

9. There is no economic benefit provided to the local economy as claimed by the applicant.

The applicant and his business is based in Maidstone and is not local. Their business operations do not contribute to the local economy at all. All employment is of migrant labour from Eastern Europe.

All downstream suppliers eg packaging etc are provided by non-local businesses

A token effort to advertise for local employees has only been made in the village shop in the last two weeks of June, just prior to the submission of the planning application.

10. Any economic benefits must be off-set against real harm to the protected AONB landscape.

11. A series of temporary consents should not be read as a green light. The last temporary planning permission was only granted on the "balance" of issues principally on the 8 year time period that the polytunnels would be in place. In fact the Planning Officer responsible for the 2010 application only recommended the approval of the temporary application on the basis that the damage to the environment would be temporary, and that the landscape would be returned to its natural state at the end of the temporary consent.

The applicant cannot therefore now request permanent approval on the basis that his operations have been present on this site for the period of the temporary consents.

12. The applicant was aware of the temporary nature of the current planning permission and should have tailored his investment expenditure accordingly. The Applicant’s Statement of Investment made during a temporary planning permission cannot therefore be considered for, nor used to justify, the granting of a permanent planning approval.

If the applicant has failed to tailor his investment expenditure according to the timeline of the temporary planning permission and has overinvested, it is due to his own negligence, and he cannot now claim this as a reason for the permanent approval of his application to remedy his negligence.

13. The impact on the character and the reputation of the village will have a negative effect on local businesses who rely on tourism to the village. Sevenoaks District Council has a duty to protect local businesses as opposed to huge industrial concerns such as Clockhouse Farms who are not local and do not contribute to the local economy or local employment.

14. I strongly urge SDC to stop this cancer from spreading across our AONB. This is not farming but an industrial business run purely for profit with no concern of the impact on the local community or the Area of Outstanding Natural Beauty.

15. The Land should be returned to local farmers who have worked hard for the last 500 years in maintaining such a wonderful AONB landscape whilst earning a living and providing local employment.