Volume 2: Sustainability Appraisal of the Maidstone Gypsy, Traveller and Travelling Showpeople Development Plan Document 2023–2040

Appendix C: Reasonable Alternative Site Assessments

C.1 Introduction

C.1.1 Overview

C.1.1.1 A total of 158 reasonable alternative sites have been identified by Maidstone Borough Council (MBC) during the preparation of the Gypsy, Traveller and Travelling Showpeople (GTTS) Development Plan Document (DPD).

C.1.1.2 The location of the 158 reasonable alternative sites is shown in Figure C.1.1 and C.1.2, and their specifications as provided by MBC are summarised in Table C.1.1.

C.1.1.3 Each of the sites appraised within this report have been assessed for likely impacts on each of the 13 SA Objectives, as outlined in the SA Framework (see Appendix A). Likely sustainability impacts have been set out in Tables C.2.1 to C.14.1 against each receptor within each SA Objective chapter, in accordance with the site assessment methodology set out in Appendix B, as well as the methodology information set out in Chapter 2 of the main Regulation 18c SA Report (see Volume 1).

C.1.1.4 The receptor-only impacts, based on the red line boundary and site proposal information provided by MBC, help to identify the potential impacts on site if there were no policy or mitigation. The potential mitigating influence of the MBC GTTS DPD policies (alongside other adopted plan policies) is considered within Appendix E.

C.1.1.5 It should be noted that whilst every effort has been made to predict effects accurately, the sustainability impacts have been assessed at a high level and are reliant upon the current understanding of the baseline. These assessments have been based on information provided by the Council as well as expert judgement.

Table C.1.1: Reasonable alternative GTTS sites in Maidstone

C.2 SA Objective 1: Housing

C.2.1 Housing provision

C.2.1.1 The majority of identified reasonable alternative GTTS sites contain existing pitches or plots and as such, the identified need is likely to be contributed to through intensification or expansion. Based on the information provided by the Council, derived from the Pitch Deliverability Assessment¹ and liaison with landowners, the number of existing pitches on each site and the anticipated net gain in pitches is set out in Table C.1.1 above, with the total pitch capacity of each site derived from the sum of existing and potential pitches.

C.2.1.2 Table C.2.1 below details the impact each site is anticipated to have on housing. The proposed development at 134 sites have potential for a minor positive impact on housing where it is likely they will provide a capacity of between one and nine pitches. Some 19 sites are expected to have a capacity of 10 pitches or more; there is potential for a major positive impact on housing for these sites.

C.2.1.3 It should be noted that MBC will be carrying out a detailed capacity assessment at each site to understand the deliverability and feasibility of pitches at each site, in accordance with other relevant policy requirements. As such, the capacity figures may be subject to change. At the time of writing, the capacity of Sites C4S-001, C4S-002, C4S-008, C4S- 019 and LPR256 is unknown; the impact of these sites on housing provision is therefore recorded as uncertain.

Table C.2.1: Sites impact matrix for SA Objective 1 – Housing

C.3 SA Objective 2: Transport and Accessibility

C.3.1.1 Table C.3.1 below sets out a summary of the identified impacts for each receptor in relation to SA Objective 2 (Transport and Accessibility).

C.3.2 Bus stops

C.3.2.1 There are several key bus routes which run within the borough, primarily leading into the town of Maidstone where the most regular bus services are found, with more infrequent services provided throughout the rural settlements.

C.3.2.2 A total of 127 of the GTTS sites are located more than 400m from a bus stop with a frequent service, as the sites are predominantly located in rural parts of the borough. As such, a minor negative impact has been identified for these sites where new residents may be less likely to choose to travel via bus.

C.3.2.3 A total of 16 sites are located within 400m of a bus stop with infrequent services (0002, 0020, 0044, 0053, 0055, 0161, 0167, 0168, 0170, 0184, 0188, 0204, 0252, 0307, C4S-003 and C4S-005). As these sites are already located on a bus route which allows for potential for increased services, a negligible impact is identified for these sites on access to bus services.

C.3.2.4 There are 15 sites where the majority of the site area is located within the identified 400m sustainable target distance of a bus stop providing a frequent service (0001, 0021, 0026, 0048, 0057, 0108, 0111 0125, 0214, 0306, C4S-002, C4S-017, C4S-025, C4S-028 and C4S-030). These sites will therefore be expected to provide residents with sustainable access via bus and as such a major positive impact has been identified.

C.3.3 Railway stations

C.3.3.1 There are 13 railway stations across Maidstone, the majority of which are located in and around Maidstone town, including Maidstone East Station and Maidstone West Station, among others. Several stations are located to the north and east of the borough, such as Hollingbourne and Lenham Stations, as well as several to the south of the borough including Staplehurst and Marden Stations. However, this does leave the central portion of the borough, as well as a large area of the Kent Downs National Landscape within Maidstone Borough, largely disconnected from the rail network.

C.3.3.2 A total of 124 GTTS sites are located beyond the sustainable 2km stretch distance from a national network railway station which is likely to result in a minor negative impact with regard to sustainable access to railway stations for these sites.

C.3.3.3 Some 10 GTTS sites are located within a sustainable 2km stretch distance of a railway station (Sites 0059, 0068, 0074, 0206, 0208, 0211, 0213, 0226, C4S-011 and C4S-012), allowing reasonable access to rail travel, as well as beyond the DPD area. These sites have been identified as having a minor positive impact on access to travel via the national rail network.

C.3.3.4 The remaining 24 GTTS sites (Sites 0010, 0026, 0055, 0071, 0077, 0080, 0081, 0084, 0113, 0176, 0177, 0191, 0214, 0236, 0244, 0261, 0307, C4S-001, C4S-002, C4S-008, C4S-028, C4S-030, LPR256 and LPRGT1(5)) are likely to have a major positive impact on access to travel via the national rail network. These sites are located within a sustainable 1.6km target distance of a railway station and as such are expected to provide residents with sustainable access to local services, facilities and amenities as well as sustainable opportunities to travel beyond the DPD area boundaries where necessary.

C.3.4 Access to pedestrian/cycle routes

C.3.4.1 Access to pedestrian routes and cycle routes will ensure GTTS site residents have a safe and sustainable way to reach local facilities on foot, ensuring those who do not have access to other sustainable means of transport are able to reach essential facilities.

C.3.4.2 A total of 147 sites are not located adjacent to an existing pedestrian route or cycle path which would ensure safe and sustainable passage to essential services, and as such a minor negative impact has been identified.

C.3.4.3 For the remaining 11 sites (0018, 0020, 0057, 0111, 0234, 0306, 0321, C4S-017, C4S-025 and LPR256), a minor positive impact has been identified where the sites are located adjacent to a cycle path and/or footpath, thus providing a method of safe and sustainable access to local services and facilities.

C.3.5 Food stores

C.3.5.1 Larger food stores including supermarkets are generally located in and around Maidstone town. In the rural parts of the borough there is a lower concentration of food stores, with small supermarket stores, convenience stores and farm shops being more common.

C.3.5.2 The majority (147) of the GTTS sites have been identified as having a minor negative impact with regard to access to food stores, where they are located beyond the 800m sustainable stretch distance from this essential facility.

C.3.5.3 Six of the GTTS sites (0020, 0075, 0081, 0108, 0169 and 0249) are located within the 800m stretch distance of a food store, allowing residents some access to provisions required to meet their daily needs. For these sites, a negligible impact has been identified.

C.3.5.4 The remaining five sites (0057, 0161, 0167, 0168 and 0170) are wholly located within the 600m sustainable target distance of a food store and are likely to result in a major positive impact for this receptor. These sites will ensure residents of have greater access to food provisions required to meet their daily needs, particularly for those residents who may not have the capability to walk further distances.

C.3.6 Access to primary schools

C.3.6.1 There are a total of 58 primary, infant and junior schools distributed throughout the DPD area. Some 132 GTTS sites are located beyond the recommended 1km distance. For these sites, a minor negative impact has been identified where sustainable access to a primary school is more limited.

C.3.6.2 There are 14 GTTS sites which are located within 800m to 1km of a primary school, thus providing some access to primary education facilities. A negligible impact has been identified for these sites.

C.3.6.3 The remaining 12 sites (0002, 0111, 0161, 0167, 0168, 0170, 0219, 0232, 0249, 0256, C4S-003 and C4S-025) are located where the majority of the site is within a sustainable 800m target distance of a primary school. A major positive impact has been identified for these sites as they are expected to provide sustainable access to education facilities for primary school aged children.

C.3.7 Access to secondary schools

C.3.7.1 Nine secondary schools are distributed throughout the DPD area. A total of 135 of the GTTS sites are located outside of a 2km stretch distance from a secondary school which would require further travel and as well as an increased need for the use of private cars. As a result, a minor negative impact has been identified for these sites.

C.3.7.2 Eight GTTS sites (0002, 0017, 0118, 0178, 0232, 0256, 0321 and LPR256) have been identified as having a negligible impact on access to secondary schools where they are located within 1.5km to 2km and as such providing some access to secondary education facilities.

C.3.7.3 There is one site, 0234, which is partially located within 1.5km of a secondary school and as such a minor positive impact has been identified. For the remaining 14 sites (0046, 0055, 0057, 0084, 0161, 0167, 0168, 0170, 0219, 0244, 0249, 0307, C4S-025 and LPRGT1(5)), a major positive impact on access to secondary education facilities has been identified where the sites are within a sustainable 1.5km target distance from a secondary school. Development in these locations will be expected to provide safe access through sustainable means to facilities for secondary school aged children.

C.3.8 Access to further education

C.3.8.1 There are six facilities in Maidstone providing sixth form and college education, as well as Aylesford School which lies just outside the DPD area boundary. A total of 118 of the GTTS sites are located over the 3km sustainable distance from further education facilities, as such resulting in a negligible impact on access to further education facilities, where 16– 18-year-olds may be required to travel greater distances in order to access a wide range of educational opportunities.

C.3.8.2 One site, 0042, is partially located within the 3km sustainable distance from further education facilities and as such a minor positive impact has been identified for this site.

C.3.8.3 The remaining 39 sites are wholly located within the 3km sustainable distance of a sixth form or college facility. Development in these locations will likely provide residents with safe and sustainable access to further education facilities and as such a major positive impact has been identified for these sites.

Table C.3.1: Site impact matrix for SA Objective 2 - Transport and Accessibility

C.4 SA Objective 3: Community and Crime

C.4.1.1 Table C.4.1 below sets out a summary of the identified impacts for each receptor in relation to SA Objective 3 (Community and Crime).

C.4.2 District and local centres

C.4.2.1 District and local centres are expected to provide residents with access to local services and amenities as well as facilitate greater levels of community engagement.

C.4.2.2 There are 22 district and local centres located across the DPD area, with the greatest number found in and around the town of Maidstone. Six of the district and local centres are located in more rural areas such as Lenham, Staplehurst and Yalding, among others.

C.4.2.3 A total of 153 GTTS sites are located beyond the 800m stretch distance from district or local centres, which has potential to increase difficulties for GTTS residents to integrate with the settled community. As such, a minor negative impact has been identified for these sites, where residents have potential to be more isolated than if they were located a closer distance to the local community.

C.4.2.4 There are five sites which are located within the 800m stretch distance of a district and local centre: Sites 0020, 0169, 0249, C4S-008 and C4S-025. These sites are more likely to provide residents with access to key services and amenities, as well as the opportunity to become engaged with community activities and make use of community facilities. As a result, a minor positive impact has been identified for these sites with regard to access to district and local centres.

C.4.3 Indices of Multiple Deprivation

C.4.3.1 Indices of Multiple Deprivation (IMD) measure the relative levels of deprivation in 32,844 LSOAs (Lower Layer Super Output Areas) in England. Deprivation is measured according to 39 indicators such as crime, unemployment, income, access to housing and education. The deciles relating to the overall relative deprivation for each of the LSOAs² have been used in this assessment.

C.4.3.2 A total of 81 of the GTTS sites are located in LSOAs which fall within the 10-50% most deprived areas (all within either Decile 4 or 5 of the IMD). For these sites, a minor negative impact has been identified where development in these LSOAs has the potential to exacerbate inequalities, increase fear of crime and pressure on local services.

C.4.3.3 The remaining 77 GTTS sites are located in LSOAs which fall within less deprived areas (all within Decile 6, 7, 8 or 9 of the IMD). A negligible impact is identified for these sites where these are likely to locate development within areas that experience less deprivation. Development in these areas has potential to avoid increasing social pressures faced by residents in more deprived areas.

Table C.4.1: Site impact matrix for SA Objective 3 - Community and Crime

C.5 SA Objective 4: Health and Wellbeing

C.5.1.1 Table C.5.1 below sets out a summary of the identified impacts for each receptor in relation to SA Objective 4 (Health and Wellbeing).

C.5.2 Access to NHS Hospitals with an A&E department

C.5.2.1 There is one hospital in the DPD area which provides an Accident and Emergency (A&E) facility, Maidstone Hospital, with two others likely to serve Maidstone residents found just outside of the DPD area including Tunbridge Wells Hospital and Medway Maritime Hospital.

C.5.2.2 The majority of the GTTS sites are located outside of an 8km stretch distance from an NHS hospital providing an A&E service. For these 119 sites, a minor negative impact has been identified where there is more limited access and likely longer travel times to emergency healthcare facilities.

C.5.2.3 There are 29 sites which are located between 5km and 8km from an NHS hospital providing an A&E facility. A negligible impact has been identified for these sites, where residents have a greater chance of accessing emergency healthcare facilities through safe and sustainable means.

C.5.2.4 For the remaining 10 sites (0017, 0018, 0020, 0046, 0169, 0219, 0234, 0249, 0321 and C4S-025) a major positive impact has been identified where the majority of the site falls within a sustainable 5km target distance of an NHS hospital providing an A&E service meaning residents are more likely to be able to safely, and through sustainable means, access emergency healthcare facilities.

C.5.3 Access to GP surgeries

C.5.3.1 GP surgeries are predominantly concentrated in and around the town of Maidstone, with several also found in more rural areas, such as Len Valley Practice and Marden Medical Centre, among others.

C.5.3.2 A total of 143 sites are located over the 1km stretch distance from a GP surgery and are identified as having a minor negative impact, where residents are more likely to face challenges in safely and sustainably accessing healthcare facilities to meet their day-to- day needs.

C.5.3.3 Sites 0017, 0018, 0020, 0046, 0169, 0219 and 0234 are located between 800m and 1km from a GP surgery and as such provide greater opportunities to accessing local healthcare facilities. A negligible impact has been identified for these seven sites.

C.5.3.4 One site, 0244, is located partially within a sustainable 800m target distance from a GP surgery and is likely to provide safe and sustainable access to local healthcare facilities. A minor positive impact is identified for this site.

C.5.3.5 The remaining seven sites (0108, 0111, 0249, C4S-003, C4S-017, C4S-025 and LPR256) are located where the majority of the site is within the sustainable 800m target distance from a GP surgery where it is expected to that residents will have safe and sustainable access to local healthcare facilities. A major positive impact has been identified for these seven sites.

C.5.4 Access to leisure facilities

C.5.4.1 There are a total of two Council-owned leisure facilities in the Maidstone DPD area including Lockmeadow Health Club and Maidstone Leisure Centre, both of which are located in the town of Maidstone.

C.5.4.2 Given that the GTTS sites are predominantly located in rural locations, all of the sites are located outside of the 1.5km sustainable target distance and the 2km stretch distance from a leisure facility. As such, minor negative impacts have been identified for all 158 of the GTTS sites, where these sites are unlikely to encourage the use of leisure facilities.

C.5.5 Access to open/ green space

C.5.5.1 Having access to open and/or green spaces is known to have benefits for physical and mental wellbeing through providing opportunities for sport, recreation and socialisation, as well as opportunities to appreciate nature. Greenspaces also break up urban form and can assist with decreasing the exposure of residents to poor air quality.

C.5.5.2 Two sites (0084 and LPRGT1(5)) coincide with a natural/semi-natural open space known as Kiln Wood Nature Reserve. There is potential for development at these two sites to result in a net loss of accessible green space, leading to a major negative impact on health and wellbeing.

C.5.5.3 A total of 112 sites are located beyond the sustainable target distance for any type of open/ green space, as set out in greater detail in the methodology (see Appendix B). For these sites, a minor negative impact has been identified owing to the reduced access to open or green spaces for recreation and leisure.

C.5.5.4 There are 26 sites which fall within the sustainable target distance of only one type of open/green space. A negligible impact has been identified for these sites where they will provide some limited access to this recreational resource.

C.5.5.5 There are 11 GTTS sites within the sustainable target distances of two or three different types of open/green space, allowing residents greater opportunity to access a variety of spaces with associated recreation and leisure activities. A minor positive impact is likely for these sites.

C.5.5.6 The remaining seven GTTS sites (0020, 0048, 0108, 0111, 0167, 0168 and 0170) are located within a sustainable target distance of four or more different types of open/green space. These seven sites have potential to result in a major positive impact, where residents can access a wide variety of spaces for socialisation, sport and recreational activities close to home.

C.5.6 Access to PRoW/cycle networks

C.5.6.1 The PRoW network and cycle network which are found throughout the DPD area provide residents with access to the countryside with opportunities for exercise and recreation likely to support the mental and physical wellbeing of residents.

C.5.6.2 The majority of sites (154) lie where part of the site is within 600m of a PRoW or cycle route. These sites are likely to provide some access to active travel routes, where there is potential for a minor positive impact for these sites.

C.5.6.3 The remaining four sites (0021, 0244, 0306 and LPR256) wholly lie within 600m of both a PRoW and cycle path. As such, a major positive impact has been identified for these sites on access to PRoW/cycle networks.

Table C.5.1: Site impact matrix for SA Objective 4 - Health and Wellbeing