Volume 2: Sustainability Appraisal of the Maidstone Gypsy, Traveller and Travelling Showpeople Development Plan Document 2023–2040
D.1 Overview
D.1.1 Introduction
D.1.1.1 This appendix provides an assessment of MBC's revised vision, objectives and nine preferred policies presented in the Regulation 18c 'Preferred Policies and Potential Sites' consultation for the emerging GTTS DPD, drawing on the 25 reasonable alternative policy approaches assessed in the previous Regulation 18b 'Preferred Approaches' SA.
D.1.1.2 The emerging DPD contains a range of strategic and non-strategic policies, including development management (DM) policies. At this stage of plan making, seven draft strategic policies have been prepared which cover broader issues including the spatial strategy and quantum of GTTS growth to be delivered through the DPD, whilst the two DM policies focus on more detailed planning guidance such as the design and layout of new GTTS development.
D.1.1.3 The DPD also contains 27 site allocation policies; these are assessed in Appendix F.
D.1.1.4 Each of the nine over-arching DPD policies appraised in this report has been assessed for its likely impacts on each SA Objective of the SA Framework (see Appendix A) and is in accordance with the methodology as set out in Chapter 2 of the main report (see Volume 1). For ease of reference the scoring system is summarised in Table D.1.1.
Table D.1.1: Presenting likely impacts
|
Likely impact |
Description |
Impact symbol |
|
Major Positive Impact |
The proposed policy contributes to the achievement of the SA Objective to a significant extent. |
++ |
|
Minor Positive Impact |
The proposed policy contributes to the achievement of the SA Objective to some extent. |
+ |
|
Negligible/ Neutral Impact |
The proposed policy has no effect or an insignificant effect on the achievement of the SA Objective. |
0 |
|
Uncertain Impact |
The proposed policy has an uncertain relationship with the SA Objective or insufficient information is available for an appraisal to be made. |
+/- |
|
Minor Negative Impact |
The proposed policy prevents the achievement of the SA Objective to some extent. |
- |
|
Major Negative Impact |
The proposed policy prevents the achievement of the SA Objective to a significant extent. |
- - |
D.1.1.5 Each appraisal in the following sections of this report includes an SA impact matrix that provides an indication of the nature and magnitude of effects. All impact matrices are accompanied by an assessment narrative which describes the findings of the appraisal and provides a rationale for the recorded impact values.
D.1.1.6 Within these policy assessments, where relevant, some recommendations for enhancement or improvement of the vision, objectives or policies have been suggested. These recommendations, alongside more general recommendations for the DPD going forward, are summarised in Chapter 8 of the main R18c SA Report (see Volume 1).
D.1.2 Overview of policy assessments
D.1.2.1 The impact matrices for all draft policy assessments are presented in Table D.1.2 below. These impacts should be read in conjunction with the assessment text narratives which follow in subsequent sections of this appendix.
Table D.1.2: Summary of policy assessments
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1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
|
| Policy Ref | Housing | Transport and accessibility | Community and crime | Health and wellbeing | Economy | Natural resources | Water | Air quality | Flooding | Climate change | Biodiversity | Cultural heritage | Landscape |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Vision | ++ | + | ++ | ++ | ++ | + | 0 | 0 | 0 | + | 0 | 0 | + |
| Objectives | ++ | + | ++ | ++ | ++ | + | 0 | 0 | 0 | 0 | + | 0 | + |
| TR1 | ++ | + | + | + | + | - | +/- | - | + | +/- | - | +/- | - |
| TR2 | ++ | 0 | + | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| TR3 | + | + | + | + | 0 | + | + | 0 | + | + | + | + | + |
| TR4 | ++ | - | - | - | + | - | +/- | - | +/- | - | +/- | 0 | +/- |
| TR5 | + | +/- | + | +/- | +/- | +/- | +/- | +/- | +/- | +/- | +/- | +/- | + |
| TR6 | + | + | + | + | + | - | 0 | 0 | 0 | 0 | + | 0 | 0 |
| TR7 | + | + | + | + | + | - | 0 | + | + | + | 0 | 0 | + |
| TR8 | + | + | + | + | 0 | 0 | + | 0 | + | + | + | + | + |
| TR9 | + | 0 | + | + | 0 | 0 | + | 0 | 0 | + | + | 0 | + |
D.2 Vision and Objectives
D.2.1 Vision
DPD Vision By 2040 Maidstone will be a borough where Gypsies, Travellers and Travelling Showpeople have:
- The ability to secure a high-quality, well-designed, climate-resilient home in a place where they feel they belong, where they feel safe and where they can be proud of;
- Sufficient suitable land/sites available to meet the identified need for accommodation including that of different tenures, and as a result, no longer have a need for unauthorised developments or encampments;
- Equal and inclusive access to services and facilities through the provision of well located, sustainable sites that promote stronger, more socially cohesive and resilient communities;
- Security and certainty about their future and that of their local environment, such that they have the opportunity to thrive while pursuing and preserving their traditional way of life; and
- The same opportunities and responsibilities as the borough’s settled community.
|
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
|
|
Plan Vision |
Housing |
Transport and accessibility |
Community and crime |
Health and wellbeing |
Economy |
Natural resources |
Water |
Air quality |
Flooding |
Climate change |
Biodiversity |
Cultural heritage |
Landscape |
|
Vision |
++ |
+ |
++ |
++ |
++ |
+ |
0 |
0 |
0 |
+ |
0 |
0 |
+ |
D.2.1.1 This vision for the GTTS DPD sets out the ideal progression of development for GTTS sites throughout the period to 2040. It sets out aims for the provision of high quality and well-designed pitches and plots on sites that are well located and sustainable, support social cohesion, and promote equal and inclusive access to services and facilities.
D.2.1.2 Through seeking to ensure that the identified accommodation needs are met, a major positive impact is identified for housing (SA Objective 1). By providing sufficient accommodation, the vision seeks to avoid the need for unauthorised developments or encampments. This could potentially result in less unregulated development on previously undeveloped land, and contribute to improving the surrounding landscape where existing unauthorised developments have altered the integrity and character of the landscape, ensuring growth is instead plan-led and can be directed to more sustainable locations of high-quality design. To this end, a minor positive impact could potentially be seen for natural resources and landscape (SA Objectives 6 and 13).
D.2.1.3 The establishment of sites which provide good access to key local services and amenities such as healthcare facilities, grocery shops, educational and employment opportunities will contribute to creating an integrated and sustainable community. As such, a major positive impact will be expected for community and crime, health and wellbeing and the economy (SA Objectives 3, 4 and 5). A minor positive impact is also identified in terms of accessibility (SA Objective 2); however, 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.
D.2.1.4 The vision further seeks to provide well-designed and climate-resilient development for GTTS communities. A minor positive impact on climate change (SA Objective 10) could therefore be achieved, although more specific reference to aspects of climate resilience would be beneficial, for example supporting low-carbon or renewable energy, improving energy efficiency, and implementing measures to manage flood, drought and heat risk.
D.2.1.5 There are not anticipated to be any significant effects on the remaining SA Objectives (7, 8, 9, 11 and 12) and as such a negligible impact is identified.
D.2.1.6 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. This could support the identification of more positive effects with regard to cultural heritage and landscape (SA Objectives 12 and 13).
D.2.1.7 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. This could then support more positive effects relating to biodiversity and climate change (SA Objectives 10 and 11), but also contribute to the subsequent positive effects which could be identified through ecosystem services for water and air quality (SA Objectives 7 and 8) and flooding (SA Objective 9).
D.2.2 Objectives
DPD Objectives
Objective 1: To provide a sufficient number of authorised pitches for Gypsies and Travellers, and plots for Travelling Showpeople in the most appropriate locations in Maidstone borough, in line with evidence of established need, thereby reducing the number of unauthorised developments and encampments;
Objective 2: To ensure all new development is built to a high quality design and positively contributes to biodiversity and environmental enhancements; and
Objective 3: To enable Gypsies, Travellers and Travelling Showpeople equal and inclusive access the services and facilities that meet their needs, in order to promote stronger, more socially cohesive and resilient communities.
|
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
|
|
Plan Objectives |
Housing |
Transport and accessibility |
Community and crime |
Health and wellbeing |
Economy |
Natural resources |
Water |
Air quality |
Flooding |
Climate change |
Biodiversity |
Cultural heritage |
Landscape |
|
Objectives |
++ |
+ |
++ |
++ |
++ |
+ |
0 |
0 |
0 |
0 |
+ |
0 |
+ |
D.2.2.1 The aim of DPD Objective 1 is to provide authorised pitches and plots to meet the accommodation need of the GTTS community in appropriate locations. A major positive impact will be expected for housing provision (SA Objective 1). Through seeking to reduce the number of unauthorised encampments, DPD Objective 1 could potentially result in less development on previously undeveloped land and contribute to a minor positive impact on natural resources (SA Objective 6).
D.2.2.2 DPD Objective 2 promotes development of high-quality design that "positivelycontributes to biodiversity and environmental enhancements". As such, a minor positive impact on biodiversity (SA Objective 11) is identified, although greater specificity of the proposed enhancements could secure stronger positive effects. Depending on the intention of the described "environmental enhancements", there is potential for positive effects against further SA Objectives. 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. This could then support more positive effects relating to biodiversity and climate change (SA Objectives 10 and 11), and secondary positive effects for water, air quality and flooding (SA Objectives 7, 8 and 9).
D.2.2.3 DPD Objective 3 seeks to ensure GTTS communities have equal and inclusive access to key services and facilities which are required to meet their needs. As a result, it is expected that communities at the development sites will be able to access healthcare facilities, grocery shops, educational and employment opportunities, which would contribute to integration with the settled community whilst maintaining the respective way of life of each community. Therefore, a major positive impact will be expected for community and crime, health and wellbeing and economy (SA Objectives 3, 4 and 5), and a minor positive impact on transport and accessibility (SA Objective 2). Objective 3 would benefit from more specific wording regarding accessibility to and from pitches and plots for GTTS residents to meet their needs in a sustainable way, including the potential to link to active travel routes, which would secure further benefits for transport as well as health and wellbeing.
D.2.2.4 Similarly to the DPD vision (see paragraph D.2.1.6), the DPD objectives could be further enhanced through incorporating wording relating to the conservation of the historic environment and landscape character alongside GTTS growth to support the identification of more positive effects with regard to cultural heritage and landscape (SA Objectives 12 and 13).
D.3 Strategic policies
D.3.1 Policy TR1: Spatial strategy
Policy TR1: Spatial Strategy
- Between 2023 and 2040, provision is made through the allocation of sites and the granting of planning permissions for 529 pitches for Gypsy and Traveller households and 7 plots for Travelling Showpeople households.
- New pitches and plots to address Maidstone borough's identified needs will be permitted:
Allocated sites
- On allocated sites across the borough, in accordance with strategic policy TR4 and the relevant detailed site allocation policy in the Plan.
Maidstone Urban Area
- On non-allocated sites within Maidstone Urban Area (as shown on the Policies Map), through development, redevelopment or infilling of appropriate urban sites (see policies LPRSP2 and LPRSP3), or through the redevelopment of previously developed land (see policy LPRHOU1).
Garden Settlements
- Within the Garden Settlements of Heathlands and Lidsing, which are identified as suitable broad locations for the provision of site(s) for Gypsies, Travellers and Travelling Showpeople beyond year 6 of the Plan. The emerging Supplementary Planning Documents will set out the high-level criteria for identifying suitable land for the provision of culturally appropriate accommodation. Working with site promoters, the Council will support the provision of new sites in these locations where there is evidenced need.
Rural Service Centres and Larger Villages
- On non-allocated sites within the Rural Service Centres and the Larger Villages (as shown on the Policies Map), through minor development such as infilling (see policies LPRSP6 and LPRSP7), or through the redevelopment of previously developed land (see policy LPRHOU1).
Countryside
- On non-allocated sites within the countryside (as shown on the Policies Map):
- Through appropriate intensification, reorganisation or expansion of existing authorised sites in accordance with strategic policy TR7 and with any other relevant policies in Maidstone's Development Plan; or
- through the redevelopment of previously developed land (see policy LPRHOU1); or
- as Rural Exception Sites (see policies LPRSP9 and TR6).
- Proposals on non-allocated greenfield land sites in the countryside (excluding Rural Exception Sites) will not be permitted unless it can be demonstrated by the applicant that:
- the need is identified through the Council's published evidence base and cannot be met through alternative sites under criteria 2.a-e of this policy; and
- the identified need outweighs any harmful impacts on the countryside – including the Kent Down National Landscape, which has the highest status of protection in relation to conserving and enhancing landscape and scenic beauty; and
- the proposal accords with policies LPRSP9 and TR7, and any other relevant Development Plan policies.
- the need is identified through the Council's published evidence base and cannot be met through alternative sites under criteria 2.a-e of this policy; and
- National policy on Green Belt and Flood Risk including application of the Sequential Test and Exceptions Test will be applied, where relevant to the proposal.
- In all cases, proposals should accord with all relevant policies in Maidstone’s Development Plan.
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1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
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|
Policy Ref |
Housing |
Transport and accessibility |
Community and crime |
Health and wellbeing |
Economy |
Natural resources |
Water |
Air quality |
Flooding |
Climate change |
Biodiversity |
Cultural heritage |
Landscape |
|
TR1 |
++ |
+ |
+ |
+ |
+ |
- |
+/- |
- |
+ |
+/- |
- |
+/- |
- |
D.3.1.1 Policy TR1 sets out the spatial strategy which will dictate the distribution of GTTS growth across the period to 2040. Maidstone has a clear settlement hierarchy with the county town of Maidstone in the north west, supported by a network of rural service centres, larger villages, and smaller villages/hamlets within the open countryside. Further to this, the adopted Maidstone Local Plan Review (LPR)1 sets out new garden settlements and strategic development locations.
D.3.1.2 Policy TR1 will be expected to have a major positive impact on housing (SA Objective 1) as it sets out the provision of 529 pitches for Gypsies and Travellers and seven plots for Travelling Showpeople, therefore meeting the identified needs in the latest GTAA (2025)2.
D.3.1.3 The policy sets out the distribution of new GTTS growth in accordance with the settlement hierarchy, including a focus on development and redevelopment within Maidstone's existing urban area, with minor development in lower-tier settlements. This approach could help to ensure access to existing public transport and active travel networks within established settlements, although careful planning would be needed to secure the required infrastructure and highways capacity to accommodate growth. The inclusion of GTTS development within the garden settlements of Heathlands and Lidsing is likely to provide opportunities to integrate active and sustainable modes of travel, in accordance with garden community principles. The policy does however also look to distribute a proportion of new GTTS development on non-allocated sites within the countryside and in villages, where sustainable transport options are likely to be more limited and journey times longer. On balance, a minor positive impact on transport and accessibility (SA Objective 2) is identified as GTTS development is expected to be prioritised in better-connected areas.
D.3.1.4 Similar benefits could potentially be seen for community and crime (SA Objective 3), where pitches on existing allocated sites will support current GTTS communities, and development at garden settlements and in proximity to the existing urban area / rural service centres will be likely to provide access to community facilities and employment opportunities. On the other hand, the proportion of development in rural countryside locations may result in increased isolation from services. Integrating a proportion of GTTS sites within existing and proposed settlements could foster co-existence with settled communities; however, this could also lead to social challenges in terms of tensions between GTTS and settled communities, as well as increased fear of crime and misunderstanding between these groups owing to cultural differences. Although there is potential for mixed effects, on the whole a minor positive impact is anticipated for SA Objective 3, given that Policy TR1 seeks to ensure careful site selection using evidence- based needs and balances urban and rural development, which will reduce the likelihood of unplanned developments that might lead to further tensions.
D.3.1.5 Minor positive impacts are also likely for both health and wellbeing (SA Objective 4) and economy (SA Objective 5) given that the majority of new growth will be directed towards serviced areas that offer improved access to green space, recreational facilities, healthcare and active travel as well as employment opportunities. However, it is acknowledged that these benefits may not be evenly distributed across all site types, with the more rural growth locations potentially providing more limited healthcare and economic inclusion.
D.3.1.6 Policy TR1 promotes the redevelopment of previously developed land (PDL), and small- scale infill development within settlements. These factors will help to support an efficient use of land. However, the policy also sets out that a proportion of new development will be in rural and countryside locations, which may involve the loss of previously undeveloped land and possibly high-quality agricultural land. There is potential for a minor negative impact on natural resources (SA Objective 6).
D.3.1.7 The policy supports development that is integrated within Maidstone urban area and other established settlements, where low-emission transport options may be more viable including public transport and active travel. However, there is potential that GTTS growth in more rural areas will be reliant on road-based travel, and development within and around Maidstone town is likely to cumulatively contribute towards increased emissions including within the 'Upper Stone Street' Air Quality Management Area (AQMA) where air quality objectives are already not being met. Overall, a minor negative impact on air quality (SA Objective 8) cannot be ruled out.
D.3.1.8 The policy demonstrates a proactive approach to managing flood risk by applying national policy, including Sequential and Exception Tests. This is particularly important given the vulnerability of caravans to flooding. This requirement will ensure that proposals are guided away from high-risk locations, although there may be some increase in runoff and contribution to localised surface water flooding owing to the introduction of impermeable surfaces without careful management and drainage measures. Overall, a minor positive impact is identified for flooding (SA Objective 9).
D.3.1.9 While the policy supports re-use of PDL, which may be more likely to avoid habitat loss, it also supports growth in countryside locations and infill development within settlements, which may lead to fragmentation of ecological networks including rural habitats and green links within urban areas. There is potential for a minor negative impact on biodiversity (SA Objective 11). Similarly, although small-scale infill development and re-use of PDL is more likely to be able to be integrated into the existing urban form, the distribution of GTTS development across Maidstone including in rural locations may cumulatively result in impacts on the integrity and character of the landscape. The policy will ensure that rural exception sites conserve and enhance the Kent Downs National Landscape, although there is potential for adverse effects on views and loss of tranquillity across Maidstone in general, depending on the site-specific location and design of GTTS sites. Overall, a minor negative impact on the landscape (SA Objective 13) cannot be ruled out.
D.3.1.10 The impact of Policy TR1 on water quality and efficient use of water resources (SA Objective 7) and climate change including the extent to which development will be able to draw from renewable or decentralised energy schemes (SA Objective 10) is uncertain. Furthermore, there is uncertainty in the potential impact on cultural heritage (SA Objective 12) including possible alteration of the setting of, or views to/from, heritage assets. These impacts will depend heavily on site-specific implementation and supporting policies including the location and design of pitches and plots.
D.3.2 Policy TR2: Approach to meeting accommodation needs
Policy TR2: Approach to meeting accommodation needs
- Through the allocation of sites, the identification of broad locations for growth and the granting of planning permissions, provision will be made for 529 pitches for Gypsies and Travellers and 7 plots for Travelling Showpeople over the plan period 2023 to 2040.
Meeting need in years 1 to 5 (site allocations)
- In accordance with the PPTS, site allocations that contribute towards meeting the identified needs3 for households who meet the PPTS Annex 1 definition (251 pitches and 2 plots) overs the first 5 years of the plan, 2023 to 2027, are identified on the Policies Map and listed under strategic policy TR4. The policy sets out the indicative number of additional pitches or plots that could be accommodated on each site.
- Any remaining unmet accommodation needs for Gypsy, Traveller and Travelling Showpeople households (including need for undetermined households4) over the first 5 years of the plan, 2023 to 2027, will be addressed primarily through the consideration of planning applications for additional pitches/plots within identified broad locations for growth – as per criterion 4 of this policy.
Meeting need in years 6 to 10 (Broad locations for growth)
- In accordance with the PPTS, any existing authorised permanent sites or land adjoining existing authorised permanent sites in the borough where the land is in control of the household on the existing site are identified as broad locations for growth where the provision of additional pitches/plots to meet identified accommodation needs between 2028 and 2032 are supported.
Meeting need in years 11 to 15 (Broad locations for growth)
- In accordance with the PPTS, any existing authorised permanent sites or land adjoining existing authorised permanent sites in the borough where the land is in control of the household on the existing site are identified as broad locations for growth where the provision of additional pitches/plots to meet identified accommodation needs from 2033 onwards are supported.
Unmet need (windfall sites)
- Any accommodation needs that cannot be met through site allocations or broad locations will be addressed through consideration of planning applications for pitches/plots on new sites (windfall sites) in accordance with national policy, policy TR1, policy TR7, and any other relevant Maidstone Development Plan policies.
- Additional sites may be allocated as part of a future review of the plan, based on updated evidence of needs.
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1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
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|
Policy Ref |
Housing |
Transport and accessibility |
Community and crime |
Health and wellbeing |
Economy |
Natural resources |
Water |
Air quality |
Flooding |
Climate change |
Biodiversity |
Cultural heritage |
Landscape |
|
TR2 |
++ |
0 |
+ |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
D.3.2.1 Policy TR2 sets out the provision of 529 pitches for Gypsies and Travellers and seven plots for Travelling Showpeople and how this will be phased over the Plan period 2023 to 2040, in accordance with PPTS.
D.3.2.2 By setting out to meet the identified needs in the latest GTAA (2025)5, a major positive impact on housing is likely (SA Objective 1). Furthermore, by providing sufficient accommodation, the policy could contribute to better social integration and community stability, helping to reduce the risk of informal unauthorised encampments which might otherwise lead to increased social tension or fear of crime. A minor positive impact on community and crime is identified (SA Objective 3).
D.3.2.3 Policy TR2 will not be expected to have a direct effect on any other SA Objective. The policy sets out that windfall sites will need to comply with the requirements of Policy TR1 and TR7 (see sections D.3.1 and D.3.7), which may help to avoid adverse effects and secure localised benefits associated with this aspect of growth on various SA Objectives, although negligible effects are identified as a result of Policy TR2 as a whole.
D.3.3 Policy TR3: Safeguarding permitted sites
Policy TR3: Safeguarding permitted sites
- Planning permission will not be granted for alternative use on all existing permanent, authorised Gypsy, Traveller and Travelling Showpeople sites unless it can be demonstrated that the site is no longer required to meet any identified accommodation need across the borough.
- Any other site that is subsequently granted a permanent planning permission for Gypsy, Traveller and Travelling Showpeople accommodation shall be safeguarded in accordance with this policy.
- Intensification, reorganisation or modest expansion of any permanent, authorised Gypsy, Traveller and Travelling Showpeople site to meet identified needs will be supported where proposals accord with policies TR7 and TR8, and any other relevant Development Plan policies.
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1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
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|
Policy Ref |
Housing |
Transport and accessibility |
Community and crime |
Health and wellbeing |
Economy |
Natural resources |
Water |
Air quality |
Flooding |
Climate change |
Biodiversity |
Cultural heritage |
Landscape |
|
TR3 |
+ |
+ |
+ |
+ |
0 |
+ |
+ |
0 |
+ |
+ |
+ |
+ |
+ |
D.3.3.1 Policy TR3 safeguards existing permanent, authorised GTTS sites for accommodation use unless proven unnecessary, therefore contributing towards meeting the identified needs of the community and resulting in a minor positive impact on housing (SA Objective 1).
D.3.3.2 The policy supports modest expansion, or reorganisation/intensification of existing sites to help meet identified needs. In this regard, the policy could potentially result in a minor positive impact on natural resources (SA Objective 6) by reducing the need to find additional, potentially undeveloped sites, elsewhere. Furthermore, facilitating additional pitches/plots on current sites may help to maintain community cohesion and avoid separation of family units; a minor positive impact on SA Objective 3 is therefore identified.
D.3.3.3 Policy TR3 cross-references to the requirements of Policy TR7 (Accommodation on non- allocation sites – see section D.3.7) and TR8 (General site design and layout – see section D.4.1). Policy TR7 sets out criteria for GTTS development relating to accessibility, environmental quality, flood risk, community integration, and landscape protection. Policy TR8 sets out design, environmental, and accessibility standards, with considerations for landscaping, biodiversity, sustainable energy, and safe access. As such, Policy TR3 has potential to indirectly lead to minor positive effects across SA Objectives 2, 4, 7, 9, 10, 11, 12 and 13.
D.3.3.4 The policy is unlikely to significantly affect the economy (SA Objective 5) or air quality (SA Objective 8).
D.3.4 Policy TR4: Accommodation on allocated sites
Policy TR4: Accommodation on allocated sites
- Subject to the submission of suitable planning applications to the local planning authority, proposals for the provision of gypsy, traveller and travelling showpeople accommodation on the sites listed below and as shown on the Policies Map, will be permitted where:
- the site is identified and allocated for that use in the table below;
- the whole site is to be occupied by people meeting the national planning definition of either Gypsies and Travellers or Travelling Showpeople, as appropriate;
- all caravans meet the definition of a caravan as set out in the Caravan Sites and Control of Development Act (1960) and the Caravan Sites Act (1968);
- the site layout inclusive of the additional pitches provides sufficient residential amenity and privacy for current and future occupiers; and
- proposals comply with the individual site allocation policy requirements and any other relevant Development Plan policies.
- the site is identified and allocated for that use in the table below;
| Gypsy and Traveller Sites (updated and carried forward from LPR) | ||
|---|---|---|
| Site reference | Location | Approximate number of pitches (net gain) |
| Boughton Monchelsea & Chart Sutton | ||
| GT(LPR2) | Greenacres (Plot 5), Church Lane | 2 |
| Boxley Downs | ||
| GT(LPR9) | Flips Hole, South Street Road | 5 |
| GT(LPR10) | The Ash, Yelsted Road | 5 |
| Coxheath & Farleigh | ||
| GT(LPR3) | Land at Blossom Lodge, Stockett Lane | 2 |
| GT(LPR5) | Kilnwood Farm, Old Ham Lane | 2 |
| Headcorn & Sutton Valence | ||
| GT(LPR4) | Rear of Granada, Lenham Road | 1 |
| Loose & Linton | ||
| GT(LPR1) | The Kays, Heath Road | 2 |
| Marden & Yalding | ||
| GT(LPR6) | 1 Oak Lodge, Tilden Lane | 2 |
| Staplehurst | ||
| GT(LPR7) | The Paddocks, George Street | 2 |
| Gypsy and Traveller Sites (updated and carried forward from LPR) | ||
|---|---|---|
| Site reference | Location | Site promoter nominated number of pitches |
| Boughton Monchelsea & Chart Sutton | ||
| C4S (021) | Chart View (rear of 1 Chart View) | 20 |
| LPR (022) | Land rear of Chart View (site A)¹ | 2 |
| LPR (023) | Land rear of Chart View (site B)² | 2 |
| C4S (029) | Peacock Farm³ | 15 |
| Coxheath & Farleigh | ||
| C4S (025) | Forstal Farm Barn | 35 |
| Harrietsham, Lenham & North Downs | ||
| C4S (028) | Oakland Place | 12 |
| C4S (030) | Riverwood | 15 |
| Headcorn & Sutton Valence | ||
| C4S (003) | Wood View Farm⁴ | 6 |
| C4S (004) | Acres Place⁵ | 6 |
| Leeds & Langley | ||
| C4S (017) | The Brishings | 20 |
| Marden & Yalding | ||
| C4S (005) | Dairy Lane | 3 |
| C4S (011) | Highlands Farm (East) – Site A⁶ | 8 |
| C4S (012) | Highlands Farm (East) – Site B⁷ | 16 |
| C4S (015) | Oakhurst | 15 |
¹ Currently awaiting decision for 3 mobiles and 3 tourers. (25/503131/FULL)
² Application for 5 mobiles refused Feb 2024. (23/505684/FULL)
³ Currently awaiting decisions on the site for 2 mobiles and 2 tourers (24/501943/FULL) and 3 mobiles and 3 tourers (25/503191/FULL)
⁴ Application for 6 lodges refused May 2022. Appeal withdrawn. (22/500705/FULL)
⁵ Currently awaiting decision for 8 mobiles and 8 tourers (25/501709/FULL)
⁶ Currently subject to enforcement action due to stationing of caravans (24/500055/CRVNP1)
⁷ Currently subject to enforcement action due to stationing of caravans (23/500732/CRVNP2)
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D.3.4.1 Policy TR4 sets out the preferred sites to be allocated through the DPD, based on available information at this Regulation 18c stage of plan making. MBC has prepared individual site allocation policies for each of the 27 sites listed under Policy TR4, which have been assessed individually in the SA process, with mixed effects identified against the SA Framework. The full assessments are set out in Appendix F.
D.3.4.2 Through Policy TR4, the DPD allocates land on 27 sites to provide approximately 198 pitches/plots in Maidstone (plus further site capacities to be confirmed) to contribute towards meeting identified accommodation needs over the Plan period to 2040. Overall, the proposed site allocations are likely to result in a major positive impact on housing provision (SA Objective 1).
D.3.4.3 The majority of the sites allocated via Policy TR4 are located within the recommended sustainable target distances to at least one key transport receptor (e.g., bus stops, railway stations, pedestrian routes, food stores, or schools) and healthcare receptors (e.g., hospitals, GP surgeries, green spaces, Public Rights of Way (PRoW), or cycle paths). However, all sites are outside the recommended distance from one or more of these receptors. Additionally, most of the sites lie beyond the recommended sustainable distance of 800m to a district or local centre. While effects are mixed at the individual site level, a minor negative impact is recorded overall in terms of transport and accessibility (SA Objective 2), community and crime (SA Objective 3) and health and wellbeing (SA Objective 4).
D.3.4.4 All allocated sites are located within the recommended sustainable distance of 5km from an economic development area (EDA) where a range of job opportunities are likely to be available. A minor positive impact is identified for the economy (SA Objective 5).
D.3.4.5 The total combined gross area of the proposed site allocations is approximately 23.3ha. Some 22 of the 27 sites comprise, either wholly or partially, previously undeveloped land of Grade 2 or 3 according to the Agricultural Land Classification (ALC), resulting in a loss of less than 20ha of potential best and most versatile (BMV) land. Overall, a minor negative impact on natural resources is identified, associated with the cumulative loss of soil with potential agricultural and/or environmental value (SA Objective 6).
D.3.4.6 A small number of sites lie within groundwater Source Protection Zones (SPZ) and/or in proximity to watercourses, where there is increased potential for runoff from new development to impact upon the quality of waterbodies. While all development has the potential to result in downstream impacts on water quality, the extent and severity of these impacts is likely to be lower for sites located further away from watercourses (i.e., the majority of allocated sites). At this stage, in absence of information regarding the type of drainage solutions to be implemented on each site, the effect of the proposed site allocations on water is uncertain (SA Objective 7).
D.3.4.7 A small number of the allocated sites lie within 200m of a main road, where there is potential for site end users to be exposed to higher levels of transport-associated air pollution. The majority of sites, however, are located further away from main roads, where air quality is likely to be generally good. Despite the positive provisions of other DPD policies, such as boundary treatments and screening that may minimise exposure to air pollution, the construction and occupation of approximately 198 new pitches/plots, along with associated traffic generation, may cumulatively contribute to a reduction in air quality. Overall, a minor negative impact on air quality (SA Objective 8) cannot be ruled out. Similarly, while the DPD policies promote opportunities for renewable energy generation, the cumulative increase in traffic due to the proposed GTTS development may lead to an overall minor negative impact on climate change (SA Objective 10).
D.3.4.8 While the majority of allocated sites lie in Flood Zone 1, where fluvial flood risk is low, and away from areas of high surface water flood risk, a small number of sites coincide with Flood Zone 2. At this stage, in absence of Sequential and Exception Test details, the effect of the proposed development on flooding (SA Objective 9) is uncertain.
D.3.4.9 Mixed effects have been identified for biodiversity. Potential adverse effects have been identified for a small proportion of the sites in proximity to biodiversity designations, where there is potential for increased development-related threats and pressures. In many locations, there is potential for positive effects on biodiversity at the local level, owing to the biodiversity net gain (BNG) requirements set out in other DPD policies. However, in absence of the Habitats Regulations Assessment (HRA) conclusions, the overall impact for biodiversity (SA Objective 11) remains uncertain due to the potential for development to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.
D.3.4.10 A small number of allocated sites lie in proximity to heritage assets (including listed buildings, conservation areas and registered parks and gardens), where there is potential for adverse effects on the setting of these assets. In line with the requirements of other DPD policies and adopted LPR policies, it is expected that any potential adverse effects can be mitigated. Overall, a negligible impact on cultural heritage (SA Objective 12) is identified.
D.3.4.11 Two sites (GT(LPR9) and LPR(256)) are located within the Kent Downs National Landscape, where there is potential for significant adverse effects on its special character and qualities without careful planning. The majority of allocations lie in areas away from sensitive landscape receptors, where there is potential for benefits to the local character and appearance of sites to be secured, owing to the requirements of other DPD policies (such as screening and boundary treatments). At this stage, in absence of further landscape evidence to confirm that any potential adverse effects on the landscape (including the Kent Downs) can be mitigated, the effect of Policy TR4 on landscape (SA Objective 13) is uncertain.
D.3.5 Policy TR5: New public site provision
Policy TR5: New public site provision
- The Council will support proposals for new high quality, well landscaped public sites to provide affordable pitches for the borough’s residents. This includes both site identification and delivery.
- The provision of future public sites will be supported where:
- There is an evidenced identified local need for the provision of affordable pitches/plots;
- Sites are located in accordance with the spatial strategy as set out under Policy TR1;
- Proposals accord with policies TR6 or TR7 and all other relevant Development Plan policies.
- At a future plan review, land may be allocated for the provision of new public sites, should an evidenced need exist.
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D.3.5.1 MBC currently owns and manages two public GTTS sites: Stilebridge Caravan Site and Water Lane Caravan Site. Policy TR5 supports the identification of additional public GTTS sites to meet identified needs, where these accord with the spatial strategy and other DPD policies.
D.3.5.2 Policy TR5 could potentially result in a minor positive impact on housing provision (SA Objective 1) through seeking to identify further appropriate sites for GTTS use in the borough.
D.3.5.3 The policy's focus on high-quality, well-landscaped public sites and affordable pitches could contribute to social inclusion and community stability by meeting local needs, as well as ensuring that GTTS development is well integrated into the surrounding landscape character. There is potential for a minor positive impact on community and crime (SA Objective 3) and landscape (SA Objective 13).
D.3.5.4 Via cross-reference to the requirements of DPD Policy TR1, TR6 and TR7, there is potential for positive effects to be seen across the SA Framework. However, as the location, nature and scale of any future sites to be identified under Policy TR5 is not known, the effect against all other SA Objectives is recorded as uncertain at this stage.
D.3.6 Policy TR6: Rural exception sites
Policy TR6: Rural exception sites
- In the countryside (i.e. outside of Maidstone Urban Area, the Rural Service Centres and Larger Villages), the Council will work with Parish Councils and local stakeholders to bring forward affordable local accommodation needs for its rural communities in line with national policy and the latest government guidance.
- The Council will grant planning permission for rural exception sites for Gypsy, Traveller or Travelling Showpeople households subject to the following criteria:
- Development has been proven necessary by a local accommodation needs survey, including evidence to demonstrates that the proposed future occupiers are either current residents or have an existing family or employment connection;
- The scale of the proposed site is in proportion to, and does not dominate, the nearest settled community;
- The development is sustainably located, with preference given sites close to settlements and communities where a range of community facilities, in particular schools, health care, and shopping facilities are accessible from the site preferably on foot, by cycle or by public transport;
- The development is or can be made safely accessible to and from the public highway by all vehicles using the site;
- Where national landscape, ecological and/or heritage designations have the potential to be affected by the proposed development, regard must be given to the designation(s) and its purpose, whilst complying with national policy and guidance. Proposals shall have regard to areas of higher landscape sensitivity and heritage value;
- In line with policy LPRSP14(A), deliver a minimum 20% biodiversity net gain; and
- The site will only be used for affordable Gypsy, Traveller or Travelling Showpeople accommodation in perpetuity to meet the need for which it was permitted. This will be secured by planning conditions and/or legal agreements as appropriate.
- Development has been proven necessary by a local accommodation needs survey, including evidence to demonstrates that the proposed future occupiers are either current residents or have an existing family or employment connection;
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D.3.6.1 Policy TR6 aims to facilitate the provision of affordable accommodation for GTTS households in rural areas, ensuring that developments meet local needs, are sustainably located, and respect environmental and community considerations.
D.3.6.2 By supporting development on rural exception sites where there is a proven need, the policy will help to ensure that the accommodation requirements for GTTS communities are met. A minor positive impact on housing (SA Objective 1) is therefore identified.
D.3.6.3 The policy will prioritise accommodation provision of future occupiers that are either current residents or have a family or employment connection. Furthermore, the policy highlights that safe highways access must be provided, and the sites should be in areas where facilities can be accessed in a sustainable way. In this regard, the policy could potentially help to maintain and develop community cohesion, improve social inclusion for vulnerable groups that may rely on public transport, and ensure sustainable transport options to access education, healthcare and shopping facilities. A minor positive impact is identified for transport and accessibility, community and crime, health and wellbeing, and the economy (SA Objectives 2, 3, 4 and 5).
D.3.6.4 Owing to their rural nature, there is a likelihood that rural exception sites will involve some use of previously undeveloped land. A minor negative impact on natural resources is identified (SA Objective 6). 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.
D.3.6.5 There is also potential for GTTS sites in countryside locations to conflict with the character of the surrounding landscape. The policy sets out the requirement for development on rural exception sites to have regard to landscape, ecological and heritage designations including areas of higher landscape sensitivity and heritage value. This will help to reduce the potential for adverse effects in terms of biodiversity, cultural heritage and landscape. In light of the requirement for 20% biodiversity net gain (BNG), a minor positive impact is expected in terms of biodiversity (SA Objective 11). Negligible effects are identified in terms of landscape and cultural heritage (SA Objectives 12 and 13) owing to the intention to reduce or avoid adverse effects. 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 green infrastructure (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
D.3.6.6 The requirement to ensure accessibility via foot, cycle or public transport may help to encourage uptake of lower emission transport modes; however, there is likely to be some reliance on road-based travel given the rural location of development under this policy. On balance, a negligible impact is identified for air quality and climate change (SA Objectives 8 and 10).
D.3.6.7 The policy is unlikely to lead to any significant effects on water or flooding (SA Objectives 7 and 9). 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.
D.3.7 Policy TR7: Accommodation on non-allocation sites
Policy TR7: Accommodation on non-allocation sites
- In accordance with the spatial strategy as set out under policy TR1, planning permission for Gypsy and Traveller and Travelling Showpeople accommodation will be granted on non-allocated sites where the following criteria are met:
- Site accessibility – the site can be safely accessed from the highways by pedestrians as well as by all vehicles using the site, including emergency services and service/maintenance vehicles;
- Access to services and facilities – the site should be sustainably located, with access to local services and facilities in the nearest settlement (e.g. education, healthcare, employment, shops and services), preferably by foot, cycle or public transport;
- Transport links – a range of transport mode options are or can be made available to reach services and facilities, reflecting the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability;
- Flooding – sites are not located in areas at risk from flooding (Flood Risk Zones 3a and 3b) based on the latest information from the Environment Agency or a specific Flood Risk Assessment which has been agreed by the Environment Agency. In accordance with national policy, Sequential and Exception Tests should be provided where necessary;
- Living environment – proper consideration should be given of the effect of local environmental quality (such as noise and air quality) on the health and well-being of occupants; consider noise from vehicles and noise from existing communities, and close proximity to sites allocated for business use if possible;
- Landscape character – sites should not result in significant harm to the landscape and character of an area, with particular regard to designations of both national and local importance including landscapes of local value and landscape character areas, and the cumulative effect of development on the landscape. See also policy LPRSP9 and policy TR8;
- Land particulars – Unless exceptional circumstance apply, sites should preferably be located in areas that are not inappropriate for ordinary 'bricks and mortar' housing. Sites should preferably not be located on contaminated land and should preferably be on relatively flat land. Sites specifically for Travelling Showpeople accommodation should be suitable for the storage and maintenance of show equipment and associated vehicles;
- Location within community – proposals should seek to promote an integrated co-existence between sites and the local community, seeking to improve community cohesion and relationships while acknowledging that the preference is often to be on the edge of settled communities but not isolated from them;
- Site size – in accordance with the PPTS, sites in rural or semi-rural settings should be of a scale that does not dominate the nearest settled community. Consideration should also be given to the cumulative size of multiple sites within the setting;
- Planning definitions – all caravans must meet the definition of a caravan in the Caravan Sites and Control of Development Act (1960) and the Caravan Sites Act (1968). All households occupying the proposed site must meet the latest PPTS Annex 1 definition of a Gypsy, Traveller or Travelling Showperson.
- Site accessibility – the site can be safely accessed from the highways by pedestrians as well as by all vehicles using the site, including emergency services and service/maintenance vehicles;
2. In accordance with the latest PPTS, the above criteria should also be used to guide land supply allocations where there is an identified need.
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D.3.7.1 Policy TR7 sets out MBC's intention to grant planning permission for GTTS accommodation on non-allocated (windfall) sites, provided that the development meets specific criteria related to accessibility, location, environmental quality, and landscape protection, ensuring sustainable integration with local communities.
D.3.7.2 Supporting development on appropriate non-allocated sites will be expected to have a minor positive impact on housing provision for GTTS communities (SA Objective 1), where these sites can help to meet local demand for accommodation.
D.3.7.3 The policy highlights that safe highways and pedestrian access must be provided, and the sites should be in areas where facilities including education, healthcare, employment and shops can be accessed via active travel or public transport. In this regard, the policy could potentially help to maintain and develop community cohesion, improve social inclusion for vulnerable groups that may rely on public transport, and support sustainable travel choices. A minor positive impact is identified for transport and accessibility, community and crime, health and wellbeing, and the economy (SA Objectives 2, 3, 4 and 5).
D.3.7.4 Through prioritising development in sustainable locations where the need to travel is reduced, and journeys by foot, cycle or public transport are more viable, there is potential for the policy to contribute to lower car dependency and a reduction in transport-associated emissions of greenhouse gases (GHGs) and other air pollutants. Furthermore, Policy TR7 highlights the need to consider the potential effects on noise and air pollution on the health and wellbeing of site occupants. A minor positive impact is identified for air quality and climate change (SA Objectives 8 and 10).
D.3.7.5 Policy TR7 will support development at sites that are not in areas of flood risk, informed by flood risk assessments and the sequential and exception tests where necessary. A minor positive impact on flooding (SA Objective 9) is therefore likely.
D.3.7.6 The policy seeks to ensure appropriate consideration of impacts (including cumulative effects) on nationally and locally important landscapes and promotes development that is of an appropriate scale to be in keeping with the surroundings. In line with the requirements of adopted local plan Policy LPRSP9 (Development in the Countryside) and DPD Policy TR8 (see section D.4.1) it is expected that development will help to conserve the landscape character and appearance. There is potential for a minor positive impact on the landscape (SA Objective 13), although 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.
D.3.7.7 The policy provisions in relation to landscape could indirectly benefit the historic environment in terms of protection for nationally and locally important features, which could include heritage assets or historic landscapes. However, in absence of specific wording to conserve and enhance cultural heritage, a negligible impact is identified (SA Objective 12).
D.3.7.8 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)6 and good practice guidance for GTTS sites7, 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. Based on the current wording, there is potential for a minor negative impact on natural resources (SA Objective 6) as the use of previously undeveloped land may be inadvertently encouraged.
D.3.7.9 The policy is unlikely to lead to any significant effects on water resources (SA Objective 7) or biodiversity (SA Objective 11). 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 this regard.
D.4 DM policies
D.4.1 Policy TR8: General site design and layout
Policy TR8: General site design and layout
- All sites considered through this Plan or subsequent planning applications will be required to comply with the general design criteria as set out in policy LPRSP15 and the following in so far as they are relevant to the site and its location:
Pitch/plot size
- Pitch sizes can vary, but as a minimum, it is generally expected that each pitch/plot should be able to accommodate an amenity block (see policy TR9), a mobile home (also known as a static caravan), and a touring caravan.
Site layout
- Where appropriate, larger sites of 10 or more pitches should consider the inclusion of communal children's play space;
- Where appropriate, proposals should consider the inclusion of facilities such as paddocks, field shelters, secure tack rooms and other equine uses.
Landscaping and boundaries
- Proposals must retain existing landscape features in order to ensure development is well screened and to minimise its visual impact;
- Appropriate native landscaping should reinforce the boundaries of the site. Additional landscaping to supplement existing must be provided but this should not be the sole means of mitigating the visual impact of the development;
- Hardstanding should be minimised to that which is necessary for safe access, parking and site use and must not prevent the retention and/or provision of boundary landscaping to screen the development;
- Hard boundary treatments must be sympathetic to the local area in terms of appearance and height. They must not be incongruous, prominent or have a detrimental visual impact on the character of the site and locality. In rural areas, they must not have a harmful urbanising impact and they must be softened by existing landscaping and/or proposed native landscaping;
- Proposals should be accompanied by a landscaping scheme designed in accordance with the principles of the Council's landscape character guidance (Landscape Character Assessment supplement 2012), which details the number, size, species maturity, spacing and position of retained and proposed native trees and landscaping including mixed native double staggered hedgerows, and a ten (10) year landscape management place for the retained and proposed native trees and landscaping.
Natural and Built Environment
- Ensure that the site and the layout proposed on it would not cause harm to the natural or historic environment, in accordance with policies LPRSP14(A) and LPRSP14(B);
- Assess the ecological impact of the development through a phase 1 habitat survey, which may as a result require on and/or off-site mitigation for the existing habitat of local flora/fauna;
- Demonstrate 20% Biodiversity Net Gain (BNG), in accordance with policy LPRSP14A;
- Provide measures to incorporate at least 10% on-site renewable or low carbon energy production measured as a percentage of overall consumption;
- Provide details of wastewater infrastructure and surface water drainage incorporating SUDS where possible;
- Where external lighting is required, proposals should accord with policy LPRQD2. Access, Parking and Storage
Access, Parking and Storage
- Provide safe vehicle and pedestrian access to and from the site to the public highway;
- In the case of plots for travelling showpeople, adequate space should be provided for the storage and maintenance of equipment;
- Unless necessary for the use of a travelling showpeople site, no vehicle over 3.5 tonnes shall be stationed, parked or stored on site.
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D.4.1.1 Policy TR8 aims to ensure that sites developed for GTTS use meet design, environmental, and accessibility standards, with considerations for landscaping, biodiversity, sustainable energy, and safe access.
D.4.1.2 The policy will ensure that the design and layout of GTTS sites is appropriate and sufficient to meet the needs of residents, including space for caravans and amenity blocks, paddocks, outdoor recreation, manoeuvring vehicles, and storing essentials on each pitch/plot. Therefore, a minor positive impact is likely in terms of provision of suitable accommodation, providing a sense of community, and supporting wellbeing for residents at each site (SA Objectives 1, 3 and 4).
D.4.1.3 The policy seeks to ensure there is "safe vehicle and pedestrian access to and from the site to the public highway". Whilst this provision will lead to a minor positive effect on transport and accessibility (SA Objective 2), 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.
D.4.1.4 Through seeking to minimise hardstanding areas to only what is necessary to facilitate use of the site, the policy will help to reduce the loss of soil resources including those that might be agriculturally or ecologically valuable. A negligible effect on natural resources is identified (SA Objective 6). 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.
D.4.1.5 Policy TR8 encourages the incorporation of sustainable drainage systems (SuDS) and will require details of wastewater infrastructure for the sites. By encouraging appropriate drainage and management of surface water, there is potential for a minor positive impact on water resources and flooding (SA Objectives 7 and 9). However, 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.
D.4.1.6 Incorporating SuDS can also help to ensure resilience to climate change and increased extreme weather events. Furthermore, the policy requires at least 10% of energy consumption to be via on-site renewable or low-carbon energy. These measures are likely to result in a minor positive effect in terms of climate change (SA Objective 10).
D.4.1.7 Under the policy, GTTS sites will need to be informed by ecological surveys to determine any necessary mitigation, and deliver 20% BNG. Coupled with the requirement for native planting in landscaping schemes, this is likely to help conserve and enhance biodiversity alongside the proposed GTTS growth. A minor positive impact on biodiversity (SA Objective 11) is therefore identified. 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 to Preliminary Ecological Appraisal (PEA), followed by Ecological Impact Assessment (EcIA) where necessary to inform any required mitigation.
D.4.1.8 The policy sets out a range of requirements which will help to ensure that GTTS sites are carefully designed and laid out so as to be in keeping with the surrounding landscape, informed by the Council's landscape character guidance. The policy supports the retention of existing landscape features, and new native planting, to provide screening and help to soften site boundaries, particularly in rural locations. A minor positive impact on landscape (SA Objective 13) is identified.
D.4.1.9 By seeking to conserve the landscape character and ensure appropriate screening from other nearby land uses, the policy could additionally help to conserve heritage assets and their settings. The policy will ensure that harm to the historic environment is avoided, with reference to the provisions of adopted local plan Policy LPRSP14(B). There is potential for a minor positive impact on cultural heritage (SA Objective 12); however, 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.
D.4.1.10 The policy is unlikely to have a significant effect on the economy (SA Objective 5) or air quality (SA Objective 8).
D.4.2 Policy TR9: Dayrooms and amenity blocks
Policy TR9: Dayrooms and amenity blocks
- Dayrooms and amenity blocks should be:
- appropriate both in scale and massing; single storey, relative to the size of the site, the number of households intending to utilise it, and the surrounding landscape;
- grouped with development and sited so as to be space effective in the context of the site; allowing for sufficient space for mobiles and tourers; and
- accessible to all users.
- appropriate both in scale and massing; single storey, relative to the size of the site, the number of households intending to utilise it, and the surrounding landscape;
- Proposed building materials should be in keeping with the surrounding area.
- Proposals should demonstrate accordance with LPR design policies LPRQD1 and LPRQD2 in terms of renewable energy measures, water consumption, integrated ecological enhancements, and external lighting.
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D.4.2.1 Policy TR9 sets out criteria for dayrooms and amenity blocks associated with GTTS sites. The policy supporting text highlights that each pitch is expected to provide essential amenities, such as "a hot and cold-water supply; toilet; and bathing, laundry and kitchen facilities suitable for the size of the pitch", and may serve as a communal living space for GTTS residents.
D.4.2.2 The provision of dayrooms and amenity blocks for GTTS sites will be expected to meet the nuanced needs of each site and their specific requirements, in terms of the households they are intended to serve and the site context. This will lead to a more cohesive GTTS community with adequate facilities to meet their needs and appropriate living space to integrate and socialise. A minor positive effect is likely for housing, community and crime, and health and wellbeing (SA Objectives 1, 3 and 4).
D.4.2.3 The policy sets out the need for dayrooms and amenity blocks to be of appropriate scale and massing, and of suitable building materials, for the size of the site and with respect to the surrounding landscape. In accordance with Policy LPRQD2 'External Lighting', development will be required to ensure minimal impact on biodiversity and amenity of surrounding areas associated with illumination. There is potential for a minor positive impact on the local landscape (SA Objective 13) in terms of the conservation of surrounding character, tranquillity and views.
D.4.2.4 Furthermore, in accordance with adopted local plan Policy LPRQD1 'Sustainable Design', development under this policy will ensure a 'fabric first' approach that incorporates energy and water efficiency measures, incorporates renewable or low-carbon energy where possible, and provides on-site green infrastructure and habitat enhancements. Overall, a minor positive impact on water resources, climate change and biodiversity is identified (SA Objectives 7, 10 and 11).
1 Maidstone Borough Council (2024) Adopted Local Plan Review 2021-2038. Available at: https://localplan.maidstone.gov.uk/home/local-plan-review [Date accessed: 27/08/25]
2 ORS (2025) Maidstone Borough Council Gypsy and Traveller Accommodation Assessment (GTAA) Final Report, April 2025. Available at: https://drive.google.com/file/d/18obwgzVDoV5jna3q6UxJFYUgGiQDLQfF/view [Date accessed: 12/08/25]
3 Maidstone Borough GTAA (2025)
4 Households who were not available for interview and therefor who's planning definition status – for the purposes of plan-making – could not be determined.
5 ORS (2025) Maidstone Borough Council Gypsy and Traveller Accommodation Assessment (GTAA) Final Report, April 2025. Available at: https://drive.google.com/file/d/18obwgzVDoV5jna3q6UxJFYUgGiQDLQfF/view [Date accessed: 12/08/25]
6 MHCLG (2024) National Planning Policy Framework. December 2024. Available at: https://assets.publishing.service.gov.uk/media/67aafe8f3b41f783cca46251/NPPF_December_2024.pdf [Date accessed: 14/08/25]
7 Department for Communities and Local Government (2008) Designing Gypsy and Traveller Sites: Good Practice Guide. Available at: https://assets.publishing.service.gov.uk/media/5a79e68040f0b670a8026416/designinggypsysites.pdf [Date accessed: 14/08/25]