Two mobile homes, two touring caravans and a dayroom are proposed on Green Belt land by the River Darent. What the application argues, and how to comment.

A two-pitch Gypsy/Traveller site is proposed on land off Horton Road, between South Darenth and Horton Kirby. Sevenoaks District Council validated the application on Wednesday 2 September. (Sevenoaks District Council planning register, 26/02186/FUL)

The application, reference 26/02186/FUL, is for land south of Fallen Willows on the west side of Horton Road. It seeks a change of use to a residential site for two Gypsy/Traveller households, comprising:

  • two mobile homes
  • two touring caravans, stored on site rather than lived in
  • one dayroom, an ancillary amenity building with no overnight accommodation
  • post and rail fencing, a gate and hardstanding

The site is under 0.2 hectares. It forms part of a larger area on the east bank of the River Darent that has been subdivided over the years into plots used mainly for grazing and keeping horses. The applicant is Mr John Friend, represented by WS Planning & Architecture of Reigate. (Application form and covering letter, via the application’s documents tab)

The Green Belt and flood questions

The land is in the Green Belt, and the covering letter does not dispute that. It argues the site qualifies as “grey belt” land, so that under paragraph 155 of the December 2024 National Planning Policy Framework the development would not be inappropriate in the Green Belt.

The letter also states that the site lies within Flood Zone 2, “which covers most of the site”. A flood risk assessment and a drainage statement are among the 14 submitted documents. The council’s current Local Plan policy for Traveller sites, SP6, is quoted in the letter itself; its criteria include that “the site is not located within an area liable to flood”. How the council weighs those two points against each other will be one of the main tests of the application.

Timeline of decisions on the Horton Road plots: Plot 4 granted at appeal in 2023, Plot 1 approved 25 July 2025, this application validated 2 September 2026, determination due 28 October 2026.
How the neighbouring plots have been decided. Graphic by Sevenoaks Online.

The plots next door have been approved before

The application site has no planning history of its own, but its neighbours do, and the covering letter leans on both:

  • Plot 4, immediately adjacent, was refused permission for three touring caravans for an extended Romany Gypsy family in application 22/02053/FUL. A planning inspector then quashed the council’s enforcement notice at appeal in 2023 and granted permission. The letter records the inspector’s view that the council could not show a five-year supply of Gypsy/Traveller pitches.
  • Plot 1, on the same stretch of grazing land south of Viaduct Terrace, was approved with conditions on 25 July 2025 under application 24/02239/FUL, for two mobile homes, two touring caravans and two dayrooms.

On need, the letter cites the district’s 2022 Gypsy and Traveller Accommodation Assessment by Arc4, which identified a need for 43 additional pitches in the district by 2040. It says permissions granted since then have reduced that figure to 11, but argues the assessment is out of date because the national definition of who counts as a Traveller for planning purposes has since widened. It also states that the council has not made any Gypsy and Traveller site allocations to date. These are the applicant’s figures and characterisations; the council’s officers will set out their own assessment in the report on the application.

Argued under a framework that has since changed

The covering letter is dated 2 October 2025 and makes its case under the December 2024 National Planning Policy Framework. The council’s register records the application as received on 17 August 2026, the same day the Government published a new Framework that replaces the December 2024 version. (MHCLG, National Planning Policy Framework, published 17 August 2026) The council will decide the application against national policy as it now stands, not as it stood when the case was written.

What it means for residents, and how to comment

Horton Kirby and South Darenth Parish Council was sent its consultation letter on 7 September. The register lists an expiry date of Monday 28 September and a determination deadline of Wednesday 28 October. Comments can be made on the application while it is under consideration, for or against, via the council’s planning portal:

Planning comments must be about material planning matters, such as flood risk, highway safety, landscape impact and policy, rather than who an applicant is.

Sources

Image: Horton Road, South Darenth by Chris Whippet, CC BY-SA 2.0, via Geograph.