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

Appendix F: Assessment of Site Allocation Policies

F.1 Overview

F.1.1 Introduction

F.1.1.1 This appendix provides an assessment of 27 draft site-specific policies prepared by Maidstone Borough Council (MBC) presented in the Regulation 18c 'Preferred Policies and Potential Sites' consultation for the emerging Gypsy, Traveller and Travelling Showpeople (GTTS) Development Plan Document (DPD), setting out MBC's preferred sites for allocation and their site-specific requirements.

F.1.1.2 The DPD also contains a range of strategic and development management (DM) policies to guide the proposed development, which have been assessed in Appendix D.

F.1.1.3 Each site allocation policy appraised in this appendix has been assessed for its likely impacts on each SA Objective of the SA Framework (see Appendix A) in accordance with the methodology as set out in Chapter 2 of the main report (see Volume 1).

F.1.1.4 The site allocation policies relate to proposed development sites which have also been assessed as part of the reasonable alternative sites in the SA process, based on the site assessment methodology as presented in Appendix B. The assessment of site policies has drawn on the findings from the post-mitigation evaluation of reasonable alternative sites (see Appendix E), but also takes into account the further site-specific information and mitigation proposed through the site policies for the allocated sites.

F.1.1.5 For ease of reference the scoring system is summarised in Table F.1.1.

Table F.1.1: Presenting likely impacts

F.1.1.6 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.

F.1.1.7 Within these policy assessments, where relevant, some recommendations for enhancement of the site allocation policies have been suggested (see Table F.3.2). These recommendations, alongside more general recommendations for the DPD going forward, are also summarised in Chapter 8 of the main SA Report (Volume 1).

F.2 Site allocation policies

F.2.1 Policy GT(LPR1) – The Kays, Heath Road, Linton

F.2.1.1 Policy GT(LPR1) sets out details for the allocation of Site 0057 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.1.2 The following assessment considers the extent to which the provisions of Policy GT(LPR1) will further improve sustainability of the site.

F.2.1.3 Policy GT(LPR1) sets out the requirements for the location of pitches within the site, and access to the site. The policy will be likely to ensure that the GTTS development is of an appropriate scale to its surroundings and that safe access is provided. These provisions are, however, unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the SA Objectives remains unchanged from that presented for Site 0057 in Appendix E.

F.2.1.4 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.2 Policy GT(LPR2) – Greenacres (Plot 5), Church Lane, Boughton Monchelsea

F.2.2.1 Policy GT(LPR2) sets out details for the allocation of Site 0168 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.2.2 The following assessment considers the extent to which the provisions of Policy GT(LPR2) will further improve sustainability of the site.

F.2.2.3 Policy GT(LPR2) sets out the requirements for the location of pitches within the site. By ensuring the additional pitch is situated on the existing hardstanding on-site, any loss of previously undeveloped land is likely to be avoided. Therefore, a negligible impact on natural resources (SA Objective 6) is identified.

F.2.2.4 The policy requires trees and hedges along the site's frontage to be maintained, and a new landscaped boundary to the south. This will be likely to help to minimise intrusion on the landscape, and potentially enhance the character and appearance of the site and its surroundings. A minor positive impact on the landscape (SA Objective 13) is identified.

F.2.2.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site 0168 in Appendix E.

F.2.2.6 See TableF.3.2for recommendations regarding the residual adverse or uncertain effects identified.

F.2.3 Policy GT (LPR3) – Land at Blossom Lodge, Stockett Lane, Coxheath

F.2.3.1 Policy GT(LPR3) sets out details for the allocation of Site 0018 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.3.2 The following assessment considers the extent to which the provisions of Policy GT(LPR3) will further improve sustainability of the site.

F.2.3.3 Policy GT(LPR3) sets out the requirements for the location of pitches within the site. By ensuring the additional pitches are situated on the existing hardstanding on-site, any loss of previously undeveloped land is likely to be avoided. Therefore, a negligible impact on natural resources (SA Objective 6) is identified.

F.2.3.4 The policy requires hedgerows and trees surrounding the site and adjacent to the Public Right of Way (PRoW) through the site to be maintained, set out via an approved landscaping scheme. This will be likely to help to minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.3.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site 0018 in Appendix E.

F.2.3.6 See Table  F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.4 Policy GT(LPR5) – Kilnwood Farm, Old Ham Lane, Lenham

F.2.4.1 Policy GT(LPR5) sets out details for the allocation of Site LPRGT1(5) as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.4.2 The following assessment considers the extent to which the provisions of Policy GT(LPR5) will further improve sustainability of the site.

F.2.4.3 Policy GT(LPR5) sets out the requirements for a landscaping scheme and wildlife management plan that ensures trees and woodland alongside the site boundaries are maintained and ecological enhancements are secured. Furthermore, a 15m buffer between mobile homes and ancient woodland is required, affording additional protection to the nearby Kiln Wood and the wider 'Kiln Wood and Oxley Wood, Lenham' Local Wildlife Site (LWS). Despite these measures, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.4.4 The proposed landscaping scheme and maintenance of trees and woodland will be likely to help minimise intrusion on the landscape and reduce potential for harm to the character and appearance of the site and its surroundings, although specific protection is only afforded through the policy to trees along the site boundaries rather than elsewhere on- site. Overall, a negligible impact on the landscape (SA Objective 13) is identified.

F.2.4.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site LPRGT1(5) in Appendix E.

F.2.4.6 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.5 Policy GT(LPR6) – 1 Oak Lodge, Tilden Lane, Marden

F.2.5.1 Policy GT(LPR6) sets out details for the allocation of Site 0177 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.5.2 The following assessment considers the extent to which the provisions of Policy GT(LPR6) will further improve sustainability of the site.

F.2.5.3 Policy GT(LPR6) sets out the requirement for the existing landscape buffer to the west of the site to be retained and ensures the capacity of the site remains capped at two pitches. The policy will be likely to ensure that the GTTS development remains screened, limiting visual intrusion into the wider landscape. These provisions are, however, unlikely to further enhance the site's sustainability performance beyond what was identified in the post- mitigation assessment. Accordingly, the assessment of the policy against the SA Objectives remains unchanged from that presented for Site 0177 in Appendix E.

F.2.5.4 It is recommended that Policy GT(LPR6) requires a site-specific Flood Risk Assessment to be submitted with any planning application, given the site's location wholly within Flood Zone 2. The allocation should also be supported by evidence that the Sequential Test has been applied and, if necessary, the Exception Test, to ensure that GTTS development at this location would be safe and appropriate. See TableF.3.2for further recommendations regarding the residual adverse or uncertain effects identified.

F.2.6 Policy GT(LPR7) – The Paddocks, George Street, Staplehurst

F.2.6.1 Policy GT(LPR7) sets out details for the allocation of Site 0081 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.6.2 The following assessment considers the extent to which the provisions of Policy GT(LPR7) will further improve sustainability of the site.

F.2.6.3 Policy GT(LPR7) sets out the requirements for a landscaping scheme and ecological assessment to inform the proposed development, that ensures trees and hedges alongside the site boundaries are maintained and enhanced including a stronger boundary to the north of the site. These measures will be likely to help minimise intrusion on the landscape, and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.6.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by ecological assessments as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain, owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.6.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site 0081 in Appendix E.

F.2.6.6 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.7 Policy GT(LPR9) – Flips Hole, South Street Road, Stockbury

F.2.7.1 Policy GT(LPR9) sets out details for the allocation of Site 0106 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.7.2 The following assessment considers the extent to which the provisions of Policy GT(LPR9) will further improve sustainability of the site.

F.2.7.3 Policy GT(LPR9) sets out the requirements for a landscaping scheme to be prepared that ensures the existing landscaped boundaries of the site are maintained. These measures will be likely to help minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. However, given the site's location within the Kent Downs National Landscape, a minor negative impact on the special qualities and character of the landscape cannot be ruled out (SA Objective 13). It is recommended that Policy GT(LPR9) requires a site-specific landscape assessment (such as a Landscape and Visual Appraisal) to inform the site layout and design to ensure that any potential adverse effects can be avoided or suitably mitigated.

F.2.7.4 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site 0106 in Appendix E.

F.2.7.5 See Table F.3.2 for further recommendations regarding the residual adverse or uncertain effects identified.

F.2.8 Policy GT(LPR10) – The Ash, Yelsted Road, Stockbury

F.2.8.1 Policy GT(LPR10) sets out details for the allocation of Site LPRGT1(10) as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.8.2 The following assessment considers the extent to which the provisions of Policy GT(LPR10) will further improve sustainability of the site.

F.2.12.3 Policy C4S(001) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures may help to reduce the potential for intrusion on the landscape, although given the current undeveloped nature of the site and the presence of green infrastructure across much of the site, it is unclear to what extent these features could be retained alongside the proposed development of GTTS pitches. Overall, a negligible impact on the landscape (SA Objective 13) is identified.

F.2.12.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required by the policy, could potentially identify opportunities for new habitat creation or enhancement. However, as the site is entirely comprised of traditional orchard priority habitat, any development is likely to result in some loss of this habitat, leading to significant short- to medium-term adverse effects despite any off-site compensatory measures. A major negative impact on biodiversity cannot be ruled out (SA Objective 11). It is recommended that Policy C4S(001) makes reference to the need to carry out a PEA and EcIA, rather than a Phase 1 Habitat Survey. Development should only be permitted where it can be demonstrated that harm to the priority habitat can be avoided and BNG secured.

F.2.12.5 These provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the SA Objectives remains unchanged from that presented for Site C4S-001 in Appendix E.

F.2.13 Policy C4S(002) – Land adjacent to Shenley Corner

F.2.13.1 Policy C4S(002) sets out details for the allocation of Site C4S-002 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.13.2 The following assessment considers the extent to which the provisions of Policy C4S(002) will further improve sustainability of the site.

F.2.13.3 Policy C4S(002) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures may help to reduce the potential for intrusion on the landscape, although given the current undeveloped nature of the site and the presence of trees, it is unclear to what extent these features could be retained alongside the proposed development of GTTS pitches. Overall, a negligible impact on the landscape (SA Objective 13) is identified.

F.2.13.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.13.5 The policy recognises the need to take into account flooding as a constraint to development. However, as 85% of the site area lies within Flood Zone 2, it is unclear whether additional pitches could be accommodated in the area of the site within Flood Zone 1. At this stage of the assessment process, a major negative impact on flooding (SA Objective 9) cannot be ruled out. It is recommended that Policy C4S(002) requires a site- specific Flood Risk Assessment to be submitted with any planning application. The allocation should also be supported by evidence that the Sequential Test has been applied and, if necessary, the Exception Test, to ensure that GTTS development at this location would be safe and appropriate.

F.2.13.6 These provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the SA Objectives remains unchanged from that presented for Site C4S-002 in Appendix E.

F.2.13.7 See Table F.3.2 for further recommendations regarding the residual adverse or uncertain effects identified.

F.2.14 Policy C4S(003) – Wood View Farm

F.2.14.1 Policy C4S(003) sets out details for the allocation of Site C4S-003 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.14.2 The following assessment considers the extent to which the provisions of Policy C4S(003) will further improve sustainability of the site.

F.2.14.3 Policy C4S(003) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures will be likely to help minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.14.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. This would be especially important given the site's location with respect to ancient woodland, with Kings Wood situated close to the site boundary across Lenham Road. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites. It is recommended that Policy C4S(003) makes reference to the need to maintain appropriate buffer distances between built development and ancient woodland, and ensures that opportunities are sought to support nature recovery.

F.2.14.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site C4S-003 in Appendix E.

F.2.14.6 See Table F.3.2 for further recommendations regarding the residual adverse or uncertain effects identified.

F.2.15 Policy C4S(004) – Acres Place

F.2.15.1 Policy C4S(004) sets out details for the allocation of Site C4S-004 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.15.2 The following assessment considers the extent to which the provisions of Policy C4S(004) will further improve sustainability of the site.

F.2.15.3 Policy C4S(004) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures will be likely to help minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.15.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.15.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site C4S-004 in Appendix E.

F.2.15.6 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.16 Policy C4S(005) – Dairy Lane, Chainhurst

F.2.16.1 Policy C4S(005) sets out details for the allocation of Site C4S-005 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.16.2 The following assessment considers the extent to which the provisions of Policy C4S(005) will further improve sustainability of the site.

F.2.16.3 Policy C4S(005) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures may help to reduce the potential for intrusion on the landscape, although given the current undeveloped nature of the site and its relatively large scale, it is unclear to what extent any benefits for the local landscape could be achieved alongside the proposed development of GTTS pitches. Overall, a negligible impact on the landscape (SA Objective 13) is identified.

F.2.16.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.16.5 These provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the SA Objectives remains unchanged from that presented for Site C4S-005 in Appendix E.

F.2.16.6 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.17 Policy C4S(008) – The Lodge

F.2.17.1 Policy C4S(008) sets out details for the allocation of Site C4S-008 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.17.2 The following assessment considers the extent to which the provisions of Policy C4S(008) will further improve sustainability of the site.

F.2.17.3 Policy C4S(008) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures will be likely to help minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.17.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.17.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site C4S-008 in Appendix E.

F.2.18 Policy C4S(011) – Highlands Farm (East) – Site A

F.2.18.1 Policy C4S(011) sets out details for the allocation of Site C4S-011 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.18.2 The following assessment considers the extent to which the provisions of Policy C4S(011) will further improve sustainability of the site.

F.2.18.3 Policy C4S(011) sets out the requirements for a landscaping scheme to inform the proposed development that ensures hedgerows alongside the site boundaries are maintained and enhanced. These measures will be likely to help minimise intrusion on the landscape and help to conserve the character and appearance of the site and its surroundings. There is potential for a minor positive impact on the landscape (SA Objective 13).

F.2.18.4 The proposed landscaped boundary to be established, including planting of native species, accompanied by an ecological survey as required under the policy, will be likely to identify and secure opportunities for new habitat creation. There is potential for positive effects on biodiversity at the local level; however, in absence of the HRA conclusions the overall impact for SA Objective 11 remains uncertain owing to potential for development at this site to contribute to cumulative adverse effects associated with air quality, water quality/quantity and recreation at European sites.

F.2.18.5 For the remaining SA Objectives, the policy's provisions are unlikely to further enhance the site's sustainability performance beyond what was identified in the post-mitigation assessment. Accordingly, the assessment of the policy against the other SA Objectives remains unchanged from that presented for Site C4S-011 in Appendix E.

F.2.18.6 See Table F.3.2 for recommendations regarding the residual adverse or uncertain effects identified.

F.2.19 Policy C4S(012) – Highlands Farm (East) – Site B

F.2.19.1 Policy C4S(012) sets out details for the allocation of Site C4S-012 as assessed in the SA process. The full assessment of the site, alongside other reasonable alternatives, can be found in Appendix C (pre-mitigation) and Appendix E (post-mitigation).

F.2.19.2 The following assessment considers the extent to which the provisions of Policy C4S(012) will further improve sustainability of the site.