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DPD vision
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- The vision could be strengthened with regard to transport and accessibility through including reference to facilitating access to active and sustainable travel networks, which would support more sustainable travel choices and improved access to key local services and amenities, including healthcare, education and employment opportunities.
- The vision could be further enhanced through incorporating more explicit wording relating to the conservation of cultural heritage and the historic environment, setting out the intention to protect the setting and significance of heritage assets alongside GTTS growth. Additionally, the draft vision could benefit from subsequent wording which would ensure that the design of GTTS pitches and plots are, wherever possible, in line with the character of surrounding settlements.
- More specific wording relating to the conservation of the natural environment is recommended, such as to support the conservation and enhancement of green and blue infrastructure and the potential to incorporate this into the development of GTTS sites, along with the various ecosystem services that these would employ, such as carbon sequestration and storage, flood alleviation, and air filtration.
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- No further recommendations at R18c.
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DPD objectives
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- The proposed objectives would benefit from more specific wording regarding accessibility to and from pitches and plots in order for GTTS residents to meet their needs in a sustainable way, including the potential to link to or provide active travel routes, which would secure further benefits for transport as well as human health and wellbeing.
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- It is recommended that more specific wording is included relating to the conservation and enhancement of the natural environment, including through protecting existing green and blue infrastructure and the potential to incorporate this into the development of GTTS sites, along with the various ecosystem services that these would provide such as carbon sequestration and storage, flood alleviation and air filtration.
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Windfall (non- allocated) sites policy (now Policy TR7)
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- It is recommended that the chosen approach and final policy wording for windfall (non-allocated) sites sets out detail which ensures these sites will be supported where they have access to local services and amenities, through sustainable and active modes of transport and that the sites are developed to meet all the needs of the GTTS community, despite not being allocated in the DPD.
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- It is recommended that the policy should strive for avoiding impacts, and seeking enhancements where possible, rather than avoiding only "significant harm" to the landscape and character
- Further wording could be included regarding the conservation and enhancement of cultural heritage assets and historic landscapes.
- It is recommended that the policy could seek to support GTTS sites on PDL in the first instance, over the use of previously undeveloped land. The policy states that "sites should preferably not be located on contaminated land and should preferably be on relatively flat land". It is recommended that this wording is clarified, in line with the NPPF paragraph 125(c)33 and good practice guidance for GTTS sites34, to ensure that use of contaminated land is supported where remediation has been undertaken. This will help to promote an efficient use of natural resources, whilst protecting health and safety.
- Inclusion of wording to ensure that green/blue infrastructure is conserved and enhanced, and/or cross-reference to other DPD policies that will secure biodiversity enhancements and protect designated biodiversity assets, could help to improve the sustainability performance of the policy in terms of water resources and biodiversity.
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Rural exception sites policy (now Policy TR6)
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- In order to strengthen the policy and ensure adverse impacts to Maidstone's rural areas are avoided, it is recommended that this policy contains detailed wording regarding the design of GTTS sites (or cross- references to the provisions of other design-focused policies). This should include the incorporation of green infrastructure, including the conservation and enhancement of existing features such as hedgerows, to ensure the development does not lead to unnecessary fragmentation of the ecological and habitat networks, as well as the design of each pitch/ plot to ensure they are in-keeping with the surrounding setting so as to maintain the local landscape character.
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- The policy could be enhanced through including criteria that seek to avoid loss of best and most versatile (BMV) agricultural land where possible, in order to conserve this natural asset.
- The policy would benefit from including further requirements to ensure that development is informed by heritage impact assessments and/or landscape appraisals, particularly where there is potential for sensitive designations to be affected. Furthermore, inclusion of wording regarding the design of GTTS sites (or a cross-reference to other design-focused policies) could strengthen the policy's performance. This should promote the incorporation of GI, including the conservation and enhancement of features such as hedgerows, to avoid fragmentation of ecological networks and help ensure site layout and pitch design are sympathetic to the local landscape character
- Inclusion of wording to ensure that SuDS or other measures to manage water runoff and protect blue/green infrastructure, especially where development will include new hardstanding development in current undeveloped areas, could help to improve the sustainability performance of the policy in this regard.
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General site design and layout policy (now Policy TR8)
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- It is recommended that the specific policy wording relating to site layout and design incorporates necessary wording to ensure the sites do not impede on the local landscape character as well as detail ensuring each site is laid out to ensure that the design is compatible with the GTTS traditional way of life to maintain family and community cohesion.
- The layout and design of new sites should be carefully considered with reference to good practice guidance35.
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- It is recommended that the policy should require connections to public transport and active travel networks to be prioritised wherever possible in order to support more sustainable travel modes.
- The draft policy refers to the need for development to be informed by a phase 1 habitat survey; it is recommended that this should instead refer Preliminary Ecological Appraisal (PEA), followed by Ecological Impact Assessment (EcIA) where necessary to inform any required mitigation.
- The policy could be strengthened via inclusion of specific wording that seeks to conserve and where possible enhance cultural heritage assets and their settings alongside GTTS growth
- It is recommended that in line with Environment Agency advice, the policy should ensure that every effort is made to connect new pitches to the mains sewer network, to reduce risks to groundwater quality associated with non-mains drainage solutions.
- The policy could be enhanced through introducing stronger reference to the need to avoid hardstanding development on areas of higher quality soil within the perimeter of GTTS sites, where these areas could instead be preserved for integrated green infrastructure or open spaces.
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Dayrooms and amenity blocks policy (now Policy TR9)
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- Similar to the general site and design layout policy recommendation, the policy wording regarding dayrooms and amenity blocks should contain detail to ensure the needs of the GTTS population are being met, including for families and children, seeking to ensure that new site layouts are both functional and considerate to their surroundings.
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- No further recommendations at R18c.
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General recommendations for the DPD
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- Wherever possible, GTTS communities should be regularly consulted with to identify key issues that can be addressed through the DPD.
- The DPD should ensure proposed sites for GTTS seek to provide suitable access to local services, healthcare and schools to facilitate sustainable development and integration with the community. This could include measures such as developing travel plans to improve public transport connections.
- Planning policies should recognise the multi-functional benefits of green and blue infrastructure including for wildlife, recreation, flood risk mitigation, urban cooling / shading and carbon storage and seek to incorporate GI features alongside 'grey infrastructure' wherever possible. Opportunities to link into wider ecological networks, and facilitate the delivery of the emerging Kent Nature Recovery Network, should be explored.
- In line with Environment Agency advice, every effort should be made to ensure new pitches and plots are able to connect to the mains sewer network and that discharges to ground in areas of high groundwater value and vulnerability are avoided. Furthermore, any proposed activities within any source protection zones should have regard to groundwater quality issues and environmental designations including source protection zones.
- The Environment Agency advocate that the DPD should look to enable or facilitate The Beult SSSI Restoration Plan36.
- MBC should actively engage with water companies to help plan for growth and ensure capacity at Waste Water Treatment Works.
- Careful consideration should be given to the level of flood risk in the local area when locating new or expanded GTTS sites, with caravans being particularly vulnerable to flooding. The likelihood of increased frequency and severity of flood risk due to climate change should also be considered when locating and designing sites.
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- It is recommended that the Environment Agency is consulted to confirm any potential for adverse effects beyond those identified in the SA, or any requirement for further flood risk assessments to determine need for site-specific mitigation and whether proposals might be acceptable.
- It is recommended that Council heritage officers, archaeological advisors and/or Historic England are consulted to confirm any potential for adverse effects beyond those identified in the SA, or any requirement for heritage impact assessments to determine need for site-specific mitigation.
- The DPD should demonstrate that there are no suitable alternatives outside of sensitive landscapes (i.e., the Kent Downs National Landscape) before considering allocating GTTS sites in this area, and ensure that site- specific assessments are carried out to inform any detailed mitigation measures that may be required to protect the special qualities of the National Landscape in line with national policy.
- The density of pitches/plots within sites should be carefully considered, including to ensure sufficient living space and to ensure fire safety in accordance with the Model Standards for Caravan Sites37.
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