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

• DPD Policy TR6 (Rural Exception Sites) will ensure preference is given to sites that are close to settlements and communities where a range of facilities are accessible, including healthcare.
• DPD Policy TR7 (Accommodation on Non-allocated Sites) sets out criteria for non-allocated sites, including access to services and facilities (e.g., healthcare).
• Policy LPRHOU8 (Gypsy, Traveller and Travelling Showpeople Accommodation) requires local services including healthcare to be accessible from GTTS sites, preferably via sustainable modes of travel.
• Policy LPRSP13 (Infrastructure Delivery) sets out a range of infrastructure priorities including new health facilities, and various other LPR policies outline extensions or improvements to existing healthcare centres.

Access to leisure facilities – all GTTS sites are located beyond the recommended sustainable distance to leisure facilities, with potential implications for social exclusion and limited recreational opportunities.

• Policy LPRCD1 (Shops, Facilities and Services) supports proposals for leisure development in Maidstone, and various other LPR policies set out the provision of new sports facilities.

Access to open / green spaces – the majority of GTTS sites are located beyond the recommended sustainable distance to open / green space for recreation and leisure, potentially limiting opportunities for outdoor exercise and recreation. Two sites (0084 and LPRGT1(5)) partially coincide with green space.

• DPD Policy TR8 (General Site Design and Layout) will encourage sites of 10 or more pitches to provide communal children's play space.
• Policy LPRINF1 (Publicly Accessibly Open Space and Recreation)sets out standards for the quantity and quality of publicly accessible open spaces to be provided either on-site or off-site within specified distances.
• Policy LPRSP13 (Infrastructure Delivery) sets out a range of infrastructure priorities including new open space.
• Policy LPRSP14(A) (Natural Environment) requires development proposals to contribute to improved accessibility of natural green space within walking distance.
• Various area-based LPR policies seek to resist the loss of local facilities including green spaces.

Loss of mineral resources– approximately half of GTTS sites coincide with Mineral Safeguarding Areas (MSAs) where there is potential for sterilisation of mineral resources via the introduction of non- minerals development.

• Proposals that fall within MSAs will be required to undertake a minerals assessment to assess the viability and practicability of prior extraction of minerals resource in accordance with Policy DM9 (Prior Extraction of Minerals in Advance of Surface Development) of the Kent Minerals and Waste Local Plan4.

Loss of high-quality soils – the majority of GTTS sites contain previously undeveloped land of Agricultural Land Classification (ALC) Grade 1, 2 or 3 which may include 'best and most versatile' (BMV) agricultural land.

• DPD Policy TR1 (Spatial Strategy) encourages an efficient use of land via redevelopment, infilling and use of previously developed land (PDL) in Maidstone's settlements.
• Policy LPRHOU1 (Development on Brownfield Land) promotes an efficient use of land.

Watercourse quality – new development has potential to result in downstream impacts on water quality owing to increased runoff, especially for the proportion of GTTS sites in close proximity to watercourses.

• DPD PolicyTR8 (General Site Design and Layout) requires development proposals for GTTS sites to provide details of wastewater infrastructure and incorporation of Sustainable Drainage Systems (SuDS) where possible.
• DPD Policy TR9 (Dayrooms and Amenity Blocks) cross-references to water efficiency measures required by Policy LPRQD1 (Sustainable Design) including BREEAM 'Very Good' rating.
• Policy LPRSP14(A) (Natural Environment) requires development proposals to control pollution to protect water quality and mitigate against the deterioration of water bodies.

Groundwater SPZ – a small number of GTTS sites lie within Source Protection Zones (SPZs) where there is increased potential for contamination of groundwater.

• DPD Policy TR8 (General Site Design and Layout) requires development proposals for GTTS sites to provide details of wastewater infrastructure and incorporation of SuDS where possible.
• Policy LPRSP14(A) (Natural Environment) requires development proposals to control pollution to protect groundwater quality and mitigate against adverse impacts on groundwater SPZs and principal aquifers.

Exposure to air pollution associated with main roads – a small number of GTTS sites are located within 200m of a main road where residents are more likely to be exposed to higher levels of air pollution associated with road transport.

• DPD Policy TR7 (Accommodation on Non-allocated Sites) sets out criteria for non-allocated sites, including for living environments, to ensure that noise and air quality implications on the health of occupants from surrounding land uses are considered.
• DPD Policy TR8 (General Site Design and Layout) includes requirements for boundary landscaping to screen developments which may indirectly help to reduce exposure to pollution from adjacent roads.
• Policy LPRSP15 (Principles of Good Design) sets out a range of criteria for new development including the need to ensure proposals do not result in, or its occupants are exposed to, excessive air pollution.
• Policy LPRTRA1 (Air Quality) and other transport-focused LPR policies will help to protect and improve air quality, ensuring that relevant proposals submit an Air Quality Impact Assessment.

Exposure to air/noise pollution and vibrations associated with railways – a small number of GTTS sites are located within 200m of a railway line where air/noise pollution and disturbance is likely to be higher.

• DPD Policy TR7 (Accommodation on Non-allocated Sites) sets out criteria for non-allocated sites, including for living environments, to ensure that noise and air quality implications on the health of occupants from surrounding land uses are considered.
• DPD Policy TR8 (General Site Design and Layout) includes requirements for boundary landscaping to screen developments which may indirectly help to reduce exposure to pollution from adjacent railway lines.
• Policy LPRSP15 (Principles of Good Design) sets out a range of criteria for new development including the need to ensure proposals do not result in, or its occupants are exposed to, excessive noise, vibration or air pollution.

Fluvial flood risk – a small number of GTTS sites are located wholly or partially within Flood Zones 2 and/or 3 where residents will be exposed to higher levels of flood risk, and development may exacerbate existing flood risk on site or downstream.

• DPD Policy TR1 (Spatial Strategy) recognises the requirement to apply the Sequential Test and Exception Test where necessary.
• DPD Policy TR7 (Accommodation on Non-allocated Sites) sets out criteria for non-allocated sites, including for flood risk, to ensure that GTTS sites are directed away from Flood Zone 3a and 3b, and subject to site-specific flood risk assessments where necessary.
• Policy LPRHOU8 (Gypsy, Traveller and Travelling Showpeople Accommodation) requires GTTS development to avoid areas at risk of flooding (Zones 3a and 3b).
• Policy LPRSP14(C) (Climate Change) sets out a range of measures to ensure that development in the borough mitigates and adapts to climate change including a requirement for Flood Risk Assessments for development in Flood Zone 2 or 3, or sites over 1ha.

Surface water flood risk – a small number of GTTS sites coincide with areas of SWFR where residents will be exposed to higher levels of flood risk, and development may exacerbate existing flood risk on site or in surrounding areas.

• DPD Policy TR1 (Spatial Strategy) recognises the requirement to apply the Sequential Test and Exception Test where necessary.
• DPD PolicyTR8 (General Site Design and Layout) requires development proposals for GTTS sites to provide details of surface water drainage incorporating SuDS where possible.
• Policy LPRSP14(C) (Climate Change) sets out a range of measures to ensure that development in the borough mitigates and adapts to climate change, including regard to surface water management plans.

Opportunities for renewable/low-carbon energy use – in absence of site-specific data, there is potential for adverse or positive effects with regard to GHG emissions and opportunities for GTTS development to draw on renewable or low-carbon energy sources.

• DPD Policy TR8 (General Site Design and Layout) requires development proposals for GTTS sites to incorporate at least 10% on-site renewable or low carbon energy production measured as a percentage of overall consumption.
• DPD Policy TR9 (Dayrooms and Amenity Blocks) cross-references to the requirements of Policy LPRQD1 (Sustainable Design) that will ensure a 'fabric first' approach incorporating energy efficiency measures and renewable or low-carbon energy where possible.
• Policy LPRSP14(C) (Climate Change) sets out a range of measures to ensure that development in the borough mitigates and adapts to climate change.

Threats and pressures to European sites – Sites 0021 and 0306 are located less than 50m from the North Downs Woodland Special Area of Conservation (SAC), and Site 0235 is located within 400m of Queendown Warren SAC where significant adverse effects are likely. A small number of GTTS sites are located within identified recreational Zones of Influence (ZOI)5 or Nutrient Neutrality Catchment6, where there is potential for adverse effects. The Habitats Regulations Assessment (HRA) Screening has identified likely significant effects associated with air quality, water quality/quantity, recreational pressure and urbanisation effects at several European sites.

• DPD Policy TR6 (Rural Exception Sites) will ensure regard is given to the designation and purpose of national ecological designations when granting permission for rural exception sites.
• DPD Policy TR9 (Dayrooms and Amenity Blocks) requires GTTS proposals to demonstrate integrated ecological enhancements in line with Policy LPRQD1 (Sustainable Design).
• Policy LPRSP14(A) (Natural Environment) sets out the highest level of protection for SACs, SPAs and Ramsar sites in line with the Habitats Regulations, including a requirement to demonstrate nutrient neutrality within applicable areas and contribute to recreational mitigation within the 6km ZOI of Medway Estuary and Marshes SPA/Ramsar.

Threats and pressures to SSSIs – two sites (0021 and 0306) lie adjacent to, SSSIs where there is potential for direct adverse effects. A small number of further sites lie within Impact Risk Zones (IRZ) that indicate consultation with Natural England will be required.

• DPD Policy TR6 (Rural Exception Sites) will ensure regard is given to the designation and purpose of national ecological designations when granting permission for rural exception sites.
• Policy LPRSP14(A) (Natural Environment) requires development proposals to enhance, extend and connect habitats including designated biodiversity sites.

Loss or fragmentation of ancient woodland – three GTTS sites (0069, 0084 and 0085) partially coincide with ancient woodland leading to potential direct habitat loss. Several other sites lie in proximity to ancient woodland where air pollution, recreation, and habitat fragmentation impacts are possible.

• DPD Policy TR8 (General Site Design and Layout) will ensure that any ecological impacts of GTTS developments are identified and mitigated, including the use of native trees in landscaping schemes, and ensuring 20% BNG in line with Policy LPRSP14(A).
• Policy LPRSP14(A) (Natural Environment) requires development proposals to enhance, extend and connect habitats including ancient woodland.

Threats or pressures to LNRs – one site (0235) lies in proximity to an LNR where there is potential for adverse effects such as air pollution and recreation.

• DPD Policy TR8 (General Site Design and Layout) will ensure any ecological impacts of GTTS developments are identified and mitigated and ensure 20% BNG in line with Policy LPRSP14(A).
• Policy LPRSP14(A) (Natural Environment) requires development proposals to enhance, extend and connect habitats including designated biodiversity sites.

Threats or pressures to LWS and priority habitats – one site (0085) wholly coincides and one site (0069) partially coincides, with LWS (and deciduous woodland priority habitat), leading to potential direct habitat loss. Two sites wholly coincide with priority habitat (C4S-001 and LPR256). A small number of other sites partially coincide with priority habitats including deciduous woodland and traditional orchard, leading to potential habitat loss or degradation. A number of other sites lie in proximity to LWS where air pollution, recreation and habitat fragmentation impacts are possible.

• DPD PolicyTR8 (General Site Design and Layout) will ensure any ecological impacts of GTTS developments are 

  identified and mitigated, and ensure 20% BNG in line with Policy LPRSP14(A).

• Policy LPRSP14(A) (Natural Environment) requires development proposals to enhance, extend and connect habitats including LWS and priority habitats.

Impacts on National Landscapes – some 18 reasonable alternative GTTS sites lie within the Kent Downs National Landscape, and a further two sites potentially within its setting, where there is potential for adverse effects on its special qualities and character.

• DPD Policy TR1 (Spatial Strategy) highlights the need for any windfall development to conserve and enhance the landscape and scenic beauty of the Kent Downs National Landscape.
• DPD Policy TR6 (Rural Exception Sites) will ensure regard is given to the designation and purpose of national landscape designations when granting permission for rural exception sites.
• Policy TR8 (General Site Design and Layout) sets out requirements for landscaping and boundaries to ensure that GTTS sites are well screened and visual impacts are minimised.
• Policy LPRSP9 (Development in the Countryside) emphasises that great weight should be given to the conservation and enhancement of the Kent Downs National Landscape and its setting.
• Policy LPRSP15 (Principles of Good Design) sets out a range of criteria for new development including the need to respond positively to, and where possible enhance, the landscape character of the area and to ensure Landscape Character Guidelines and the Kent Downs Management Plan are adhered to.

Alteration of landscape character – while many GTTS sites are small scale, enclosed, and/or previously developed, approximately half of GTTS sites have potential to be discordant with the surrounding landscape character, as described within the published Landscape Character Assessment (LCA) (2012)7.

• DPD Policy TR5 (New Public Site Provision) supports the development of high quality, well landscaped public GTTS sites.
• DPD Policy TR8 (General Site Design and Layout) will ensure GTTS development is designed in accordance with the LCA (2012) and sets out guidance relating to boundary treatments and landscaping to ensure development is in keeping with its surroundings.
• DPD Policy TR9 (Dayrooms and Amenity Blocks) cross-references to the requirements of Policies LPRQD1 (Sustainable Design) and LPRQD2 (External Lighting) that will ensure integration of green infrastructure and protection of tranquillity.
• Policy LPRHOU8 (Gypsy, Travellerand Travelling Showpeople Accommodation) requires GTTS development to avoid harm to the landscape and rural character of the area, including cumulative effects, and promotes landscaping schemes to screen/soften site boundaries.
• Policy LPRSP15 (Principles of Good Design) sets out a range of criteria for new development including the need to respond positively to, and where possible enhance, the character of the area, incorporating high quality design and natural features.

Implications for areas of Local Landscape Value – approximately half of GTTS sites have potential to compromise or detract from key landscape characteristics of LLVs within which they are situated.

• Policy LPRHOU8 (Gypsy, Traveller and Travelling Showpeople Accommodation) requires GTTS development to avoid harm to the local landscape character and existing landscape features.
• Policy LPRSP14(A) (Natural Environment) requires development proposals to protect landscape character including Landscapes of Local Value.
• Policy LPRSP9 (Development in the Countryside) requires the distinctive character of areas of local landscape value to be conserved and enhanced.