Question 2: To what extent do you agree with the proposed spatial strategy policy? Please provide comments to support your answer.
Agree. The spatial policy needs to adhere to National Planning Policy requiring councils to assess and meet the needs of the GTTS community. Agree that the preferred approach is to provide pitches and plots in the most sustainable locations aligned to the Settlement Hierarchy as set out in a to d. b. We welcome that Maidstone Urban area is considered as a location for development but understands that the town is unlikely to be a suitable location for new sites/pitches. However, the most culturally appropriate and easiest way to meet need is likely to be the expansion and/or intensification of existing sites where appropriate and in accordance with proposed DM policies. This is the TWBC approach. Alongside this, the consideration of sites put forward through the call for sites process and maximising the number of pitches provided in accordance with proposed DM policies. c. Garden settlements and Strategic Development Location -TWBC supports the potential to incorporate pitches/plots within these locations. This has been the TWBC approach in its Adopted Local Plan, where provision is provided within its Paddock Wood Strategic policy (site allocation STR/SS 1). MBC will need to demonstrate that it has reliable sources of windfall schemes that come forward. We welcome the approach of intensification and expansion of authorised sites. Has there been any work to show the likely number of pitches that could be accommodated in this way? ii. TWBC agrees with this approach – brownfield first. Has there been any work to show the likely number of pitches that could be accommodated in this way? 3. Greenfield Land in the Countryside: It is acknowledged that G & T provision starts from being inappropriate in the Green Belt. However, if MBC is to optimise its supply and meet its need in full and given that this is where need is likely to arise, this DPD should consider whether there is appropriate Green Belt and/or grey belt land that could be released to provide new sites. This was a comment that TWBC made at the 18b consultation that has not been addressed. In addition, there should be consideration of appropriate development in the National Landscape. Not supportive of a rural exception site policy as such development rural exception sites will come forward through windfall development. However, if a rural exception site policy is to be promoted and there is an identified need this needs to be quantified, and an idea given for where this need arises to guide where exception sites could be located to meet the need arising. 4. Agree that pitches should not be provided on land that does not accord with national policy for flood risk. 5.Agree that all proposals should accord with Development Management policies
No answer given
Background & General Matters National Highways is the government owned company which operates, maintains and improves the Strategic Road Network (SRN) as the strategic highway company appointed under the provisions of the Infrastructure Act 2015 and in accordance with the Licence issued by the Secretary of State for Transport. National Highways is a statutory consultee to the planning process. It has a specific obligation to deliver economic growth through the provision of a safe and reliable SRN in line with the provisions set out in DfT Circular 01/2022: The strategic road network and the delivery of sustainable development. Circular 01/2022 is national policy that sits alongside MHCLG NPPF (2024) Further information about National Highways' role in the planning system and how we are aiming to be a proactive planning partner can be found at https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road-network-in-england/ . The Role of Local Plans/DPDs With Regards the Strategic Road Network Each Local Plan/DPD must identify and mitigate as appropriate, the impacts of the polices and development it contains on the SRN. Likewise, individual consented or proposed developments must also identify and mitigate as appropriate their impacts. In doing so, no assumptions can be made regarding the Government or National Highways bringing forward as yet uncommitted schemes that would also mitigate the Local Plan. However, National Highways will work with all parties to seek to identify where, alongside any bespoke mitigations, it may be possible and sensible to look to create cumulative impact schemes covering any combination of Local Plan/ development impacts. Likewise, National Highways will expect all parties to take a pragmatic approach when considering the impacts of emerging Local Plans and/or unconsented applications, using sensitivity testing and other tools. Vision & Validate, Monitor & Manage A key change in national transport and planning policy brought about via C1/22 and the NPPF (2024) are the shift from older style “predict and provide” (ie if demand for road space is forecast, then it is planned for) to “Vision & Validate” and “Monitor & Manage” (ie to look to manage the future through active, sustainable transport and other means, and then keep progress under active review). While the policy and practices continue to evolve, the following may assist: V&V and M&M are based on the achievement of sustainable development supported by active and sustainable travel. Active/sustainable travel includes walking/ wheeling/ cycling (occasionally equestrian) plus public transport plus to a degree EVs (but seeking to reduce reliance on car travel) Ø They should express the Vision (the what do you want to achieve and why, for the plan/ development). To be strategic and long term, the Vision will need to be fairly high level. Ø They should explain the Validate (the how are you going to achieve the Vision in practice – this can include mitigations/ programmes etc but often also the governance, funding, deliverability etc ie showing that there is reasonable certainty the “how” will work in practice). This should be sufficiently detailed to demonstrate it is deliverable/ funded etc but equally allow for evolution over time or new means to achieve the same Vision ends. Ø They should set out the M&M (the how will you know if you are achieving the vision and if you are not, what will you do about it) These need to be enshrined as a golden thread connecting Local Plan/DPD policy/ supporting evidence / the Infrastructure Delivery Plan. With regards this DPD we are content that all this can largely be achieved in conjunction with the adopted Local Plan. Duty To Co-operate We are content that from the National Highways/ Strategic Road Network perspective, the Council and their advisors have met their obligations set out in the Duty to Co-operate. In doing so, as per normal practice, while the SRN with the borough includes parts of the M2 and M20, the evidence base will, and potential impacts and mitigations may, cover a wider area, and may also need to cover non-SRN links. We are content the given the scale of the likely individual developments, their distribution and cumulative impact, that the existing adopted Maidstone Local Plan modelling is sufficient to support this DPD. The degree to which individual sites will need to be supported by their own Transport related evidence can be determined on a case-by-case basis at pre-application or application stage. Going forwards, while the Duty is to be ended in due course, the NPPF (2024) sets out requirements for Council’s to address as appropriate and relevant with other authorities and statutory consultees “strategic matters”. Transport and Movement are strategic matters. The net effect is that the Council will continue to need to work with us to progress the Local Plan/DPD and its evidence base. In due course, the normal practice would be for the Council to reflect the work done in a Statement of Common Ground” ahead of the submission of the Plan to the Planning Inspectorate, with any further updates as necessary before/ during the examination. We commit to using our best endeavours to continue to assist the Council in the production of their Local Plan/DPD and its supporting evidence base. Detailed comments on the R18c DPD We have no objections to the R18c plan per se. But have the following comments
No answer given
Retains original proposed spatial strategy approach (including safeguarding non-allocated and rural exception sites) and now this approach is strengthened with site-specific allocation policies, more detailed development management criteria, enhanced sustainability considerations, and a call-for-sites mechanism.
I agree with some of the proposed spatial policies however when you look at some of the sites being put forward this is doesnt seem to have been taken into account.
No answer given
The policy seems to be starting from the 'wrong' place. Why are so many sites required in the areas specified? How does this 'density' compare with other pars of the country?
The ethos of the policy is to direct development toward the largest settlements first. However, the proposed allocations do not follow this strategy, as they locate all new traveller sites in the least sustainable locations for development, i.e. rural countryside purely based on the available land put forward to date. This is not in accordance with PTTS or the objectives of the NPPF. There is no need to add the wording ‘will be permitted’ as this gives weight to words outside of a Development Plan policy itself. Repetition of section 38(6) of the Planning and Compulsory Purchase Act 2004 is more appropriate. Section 2 and 3 should refer in the text directly to compliance with the Development Plan. Policy 2e(i) requires more clarity on what is ‘appropriate’ in order to comply with the policy. For example, standards set in terms of pitch size, spacing, amenity, soft landscaping, access, highway safety and parking. Although withdrawn, the DCLG Good Practice Guide provides such information that could be used. This is referenced in the DPD but criteria should be part of the policy, not advised. Specification such as a maximum site size of 15 is therefore requested. Individual pitch sizes of 320m2 should be specified, as referred to in the ORS The Gypsy, Traveller and Travelling Showpeople Accommodation Assessment. (GTAA) (2025) at 1.28. Section 5 must interrelate with NPPF 11d. The Council is requested to consider whether pitches could be allocated on any of the larger sites identified for bricks and mortar development. In the same way that self build plots are often identified, so could Gypsy and Traveller Pitches. East Hertfordshire Council have successfully achieved this in their 2018 Local Plan at Gilston, policy GA1, which allocates 15 pitches into a mixed use, 10,000 home allocation. We also do not support the intensification of existing authorised sites for the reasons set out in our response to questions 1 and 3.
As a local resident, I do not believe that larger villages such as Hollingbourne are suitable locations for Gypsy, Traveller and Travelling Showpeople Pitch (GTTP) sites, including any future ‘windfall’ plots. Hollingbourne has very limited local facilities. There is no village hall, shop, post office, GP, dentist or secondary school, and access to Hollingbourne Primary School is already restricted for local families. With planned housing growth in the area, pressure on school places will only increase. As the school has a very small intake of around 15 children per year, even a small number of additional pupils in a single year group would have a noticeable impact. The village and surrounding area contain a large number of listed buildings and nearby conservation areas. This historic character is very important to me and to many residents, and it also supports tourism in the area. Locating GTTP sites close to these heritage assets would harm the character and setting of the village. Eyhorne Street is a gateway to the Kent Downs Area of Outstanding Natural Beauty and is valued for its countryside, wildlife and open landscape. Development on green belt land, farmland and woodland should be avoided wherever possible. Local roads such as Greenway Court Road, Hospital Lane and Greenway Lane already suffer from fly-tipping, and I am concerned that additional sites would worsen this problem without strong and enforceable controls. A 400-metre buffer from the village is not sufficient, particularly for residents living on the edges of the village. Even at this distance, GTTP sites would still result in increased traffic through Hollingbourne to access services that are not available locally, placing further pressure on narrow rural roads that are not suited to larger vehicles. For these reasons, I believe GTTP sites would be better located in areas with better access to services and a road network capable of supporting the additional traffic, rather than in or around villages like Hollingbourne
Strategic Policy TR1 – Spatial Strategy Submitted to: Maidstone Borough Council 1. Unsound Spatial Strategy – Driven by Land Availability, Not Proper Planning I strongly object to Policy TR1 because it explicitly acknowledges that the spatial strategy is not being guided by sustainability, settlement hierarchy, or balanced growth, but instead by: • The historic location of existing sites • The limited availability of land put forward by site promoters Paragraphs 66–67 confirm that the Council accepts a reactive and land-led approach, rather than a plan-led strategy. This directly conflicts with the fundamental purpose of plan-making under the National Planning Policy Framework (NPPF), which requires plans to be: • Positively prepared • Justified • Effective • Consistent with national policy A strategy that is “dictated” by where land happens to be available is neither justified nor sound. 2. Disproportionate and Inequitable Burden on Rural Communities The Plan places a clearly disproportionate share of development in the countryside, while: • Making virtually no provision in the Maidstone Urban Area • Acknowledging that no urban sites were submitted, yet making no meaningful attempt to identify or enable them This results in: • Rural villages and hamlets absorbing the majority of impacts • Urban areas being effectively shielded from responsibility • An inequitable distribution of development contrary to the stated settlement hierarchy Rural communities should not be expected to accommodate borough-wide needs simply because they are perceived as easier locations to deliver development. 3. Conflict with Countryside Protection Policies The Plan repeatedly recognises that Maidstone borough is predominantly rural and environmentally sensitive, yet simultaneously proposes that: • Most new Gypsy and Traveller accommodation will continue to be delivered in the countryside • Including beyond settlement boundaries and outside the 400m buffer This is fundamentally inconsistent with: • The intrinsic character and beauty of the countryside • The protection of agricultural land • The safeguarding of landscape, heritage, and ecological assets The policy sets up a structural conflict where countryside protection is acknowledged in principle but overridden in practice. 4. Failure to Properly Apply the Settlement Hierarchy Although the Plan states that provision should align with the settlement hierarchy, it then: • Concedes that this is largely unachievable • Accepts continued deviation as the norm rather than the exception This undermines the credibility of the hierarchy entirely. A hierarchy that is routinely overridden is not functioning as a genuine spatial planning tool. 5. Greenfield Development by Default, Not Exception Despite strong policy wording, the Plan creates conditions under which: • Greenfield countryside sites will continue to come forward • “Very special circumstances” risk becoming routine rather than exceptional • Cumulative harm is not properly addressed The requirement for applicants to demonstrate unmet need elsewhere places the burden on local communities to absorb impacts arising from systemic failures in land identification and delivery. 6. Inadequate Consideration of Cumulative Impacts The Plan assesses sites and locations largely in isolation, without sufficient consideration of: • Cumulative visual harm • Incremental erosion of rural character • Infrastructure strain on small settlements • Long-term social and environmental consequences This is particularly concerning where expansion of existing sites is actively encouraged, potentially leading to significant intensification over time. 7. Over-Reliance on Future Supplementary Planning Documents Key elements of delivery—particularly within Garden Settlements—are deferred to future SPDs that: • Do not yet exist • Contain no guaranteed outcomes • Push meaningful solutions beyond year 6 of the Plan This leaves rural communities exposed in the short to medium term while urban and strategic locations remain theoretical. 8. Lack of Genuine Alternatives or Balanced Options The Plan fails to demonstrate that: • All reasonable alternatives have been robustly explored • Urban, brownfield, or regeneration opportunities have been actively enabled • Strategic-scale solutions have been prioritised over piecemeal rural delivery As such, the Plan cannot be considered “justified” as required by soundness tests.
At this stage, several sites on the edge of conurbations are being proposed, with none of the required assessments (for flood risk, impact on waterways, pollution, safety etc) having been done. So all discussion could be for naught. C4S(008) in Bearsted, for instance raises many concerns, obvious to residents but seemingly not clear to MBC. Water Lane is a narrow, muddy, flood-prone country lane, with no footpath or lighting. The proposed site is only accessible down a very shoddy private road. No indication has been given in these opaque documents as to the number of large, heavy vehicles that could be using this access, or how many people will be living on site, so the environmental impact is impossible to define. No consideration appears to have been given as to how services (water/sewerage/power) will be supplied, or the impact the provision of these would have on the village, in the construction phase or the long term. Community facilities are already over-subscribed, which was ignored by MBC in the allowing of the Roundwell development, so any further additional housing in the village will have a negative impact.
Whilst I understand the need to find land available in the countryside, this has meant disproportionately affecting smaller settlements. For example, nearly 90% students in Ulcombe primary school are from traveller families. This level of overrepresentation in smaller villages and hamlets impacts on integration of the settled and traveller community, without commensurate benefits from community impact levies in terms of improved transport links, extended social provisions etc.
The balance of settled vs travelling community within a small village areas is incorrect with areas such as Ulcombe where the travelling community is starting to out number the settled. This does not provide social cohesion or a supportive community and leads to more division.
While I don't disagree that this cohort of society need suitable housing, it needs to be exactly that. Kent is overrun, as your consultation says, with more 'Gypsy/Travellers' than elsewhere in the country. There needs to be a fair balance with the rest of society. You frequently allow these sites to overgrow their intended capacity and over-allow in the same areas, creating 'tribal' tendencies ie aggressive and intimidating behaviour which is seen in many of the areas in your consultation. You - MBC and KCC - run on a policy of 'allocate and hide'. You allow this community to access land others cannot and vastly overgrow their sites, and you also permit them planning which is unattainable for others. You then, utterly, fail to ensure planning and building regulations are adhered to for example, no suitable foul drainage but just using hosepipes which either run into their land and adjacent to neighbouring property (I have an example, please contact me if you want more details), or are run over main roads to neighbouring land (which they don't own). This is environmental pollution which makes a mockery of things you say in this consultation. Have you ever actually properly visited and inspected a 'Traveller' site, especially post 'planning'? There is a disproportionate level of retrospective planning allowed. Your planning emails are full of them. The use of 'day rooms' is laughable. While I don't have an issue with them per se, they are not generally 'day rooms' but permanent residency slipped in under the radar. However, where day rooms are permitted, the sites tend to be better maintained so they appear to be a positive but should be subject to the same rules everyone else is expected to comply with. The planning rules are supposed to prevent construction on flood plains. There are, however, examples where you have ignored this and allowed sites to be constructed enabling the incumbents to provide flood protection to themselves but causing flooding to roads and other land, causing detrimental impact to infrastructure. And before you say, these comments are biased, they are based on daily, lived-in, real experience of what living in close proximity with 'Gypsy/Travellers' is actually like.
Larger villages such as Hollingbourne should be exempt from consideration for GTTP allocated plots and subsequent ‘windfall’ plots at later phases of this consultation. Lack of Facilities and Amenities - Hollingbourne has no village hall, no shop, no post office, no doctor, no dentist and no secondary school provision in the village. There is already limited scope for access to Hollingbourne Primary School for the settled community. Both this and the schools in the surrounding area will be oversubscribed in the next 4 years with the increase in planning for the settled population in these villages. Schools with large GTTP intake often see a reduction of the quality of education for the children of the settled residents. This due to lack of regular attendance and higher rates of non-attendance of the GTTP community. Hollingbourne Primary School has an intake of 15 children per year: the higher the proportion of GTTP children in a year’s cohort, the more significant the disruption in the school and the greater the negative impact on the educational outcomes for all children in that cohort. Protection of Heritage -There is a high prevalence of listed buildings Grade I, Grade II* and Grade III and three conservation areas close to some of the proposed sites. We should do everything to preserve the historic heritage of the area to attract travel and tourism and its economic benefits. Including GTTP pitches in the vicinity of these heritage sites will have a negative impact. Protection of the Natural Environment – Eyhorne St is the gateway to the Kent Downs AONB and has wonderful Kentish landscapes with diverse wildlife, flora and fauna. We should be minimising development on green belt, farmland and woodlands in the area. Roads such as Greenway Court Road, Hospital Lane and Greenway Lane are notorious hotspots for fly-tipping. MBC would need to demonstrate how this would be mitigated were the current and additional GTTP pitches approved. 400 metres is an insufficient radius and will have a negative impact on the settled community especially those on the outskirts of a larger village such as Eyhorne St. Any plan needs to demonstrate how it will minimise anti-social behaviour and rural crimes such as fly-tipping that often occur along rural roads. With regard to access to facilities and services, GTTP communities located 400m away from the larger village will still drive through the village to access facilities that are not provided in the village itself, adding to the already overburdened rural road network e.g. Eyhorne St, Greenway Court Road, Greenway Lane. Locating the pitches in places with greater access to facilities and on a road network that has the capacity to support the increase in the movements of large vehicles associated with a travelling community would be a better proposal.
I am writing to formally object to the proposed development of a traveller site at Green Lane, Langley. This is a highly residential area, and placing a traveller site here would have a significant impact on the community as a whole. Firstly, Green Lane is accessed via a narrow, one-lane track, which is frequently subject to flooding. This presents clear difficulties in ensuring safe and reliable access to the site, especially during adverse weather. Moreover, the site is overlooked by a large number of homes, which raises serious privacy concerns for both the local residents and any future site occupants. It is also important to note that this site has previously been refused planning permission for residential development due to the concerns about the viability of this land being suitable for housing. There is no reason why these valid concerns should now be disregarded to permit a traveller site, which would still face the same fundamental issues. Furthermore, several alternative sites are available that are far better suited to this purpose. These sites are located in less densely populated areas, minimising the impact on local residents. Additionally, they offer improved access points and better infrastructure, making them more practical and appropriate options. In light of these considerations, I urge the council to reject the proposal at Green Lane and focus on these alternative sites, which would be far less disruptive to the community and better meet the needs of a traveller site.
Flood Zones and polices 4. We agree that both will need the sequential and exceptions test to be carried out if required on a case-bycase basis. 82. Yes agree 86. Yes agree, we would encourage development to be moved out of 3a and 3b where possible, due to the flood risk, as caravans are highly vulnerable and we would need to be satisfied that these would be safe during a flood event. Also, safe access and egress is considered when dealing with planning applications in these areas.
MAIDSTONE GYPSY, TRAVELLER AND TRAVELLING SHOWPEOPLE DEVELOPMENT PLAN DOCUMENT (DPD) REGULATION 18(C) CONSULTATION On behalf of Homes England (‘the Heathlands Garden Community Site Co-Promoters’), we write in response to Maidstone Borough Council’s (‘MBC’ or the ‘Council’) Gypsy, Traveller and Travelling Showpeople Development Plan Document – Preferred Policies and Potential Sites (Regulation 18c) Consultation We welcome the Council’s Regulation 18c consultation on the forthcoming Gypsy, Traveller and Travelling Showpeople (GTTS) DPD, and with it the Council’s ambition to meet the full pitch needs of the Gypsy and Traveller community. As promoters of a major site within the Adopted Local Plan, the co-promoters are conscious of the role that all sites can play in helping to meet the need for GTTS sites across the borough. The Co-Promoters broadly support the Vision and Objectives of the draft DPD and acknowledge that Heathlands may play a proportionate role in helping the Council meet its need for pitches. Policy TR1:Spatial Strategy identifies a need for 529 pitches across the plan period, with paragraph (2)(c) identifying the roll that Garden Communities at Lidsing and Heathlands play in meeting need beyond year six of the plan as broad locations for growth.
Thank you for consulting Kent County Council (hereafter referred to as the County Council) on the Maidstone Gypsy, Traveller and Showpeople Development Plan Document (DPD), in accordance with the requirements of the Localism Act 2011. The County Council has reviewed the DPD and for ease of reference, has provided comments structured under the chapters and sections used within the document. General Commentary: Minerals and Waste From this DPD, it is not evident that Maidstone Borough Council (MBC) has considered Minerals and Waste matters and therefore the County Council wishes to remind MBC that it considers it important that the document has regard for all the potential constraints that would need to be considered in the identification of suitable sites. This should include the presence of safeguarded land-won mineral deposits as shown on the Mineral Safeguarding Areas proposals map for the Maidstone Borough Council (MBC) area. The presence of economically important mineral deposits may be a significant constraint in site identification as the presumption is to conserve their potential importance. Policy CSM 5: Land-won Mineral Safeguarding of the adopted Kent Minerals and Waste Local Plan (KMWLP) sets out the presumption to safeguard. Any potential sites identified in the Gypsy, Traveller and Showpeople DPD would have to be assessed against that presumption to justify an exemption from safeguarding. Policy DM 7: Safeguarding Mineral Resources of the adopted KMWLP 2024-39 sets out the potential exemption criteria that could be invoked. Moreover, potential sites either coincident or within 250m of safeguarded waste management, or mineral processing, or transportation facility would also have to be considered against the safeguarding presumption (as set out by Policy CSW 16: Safeguarding of Existing Waste Management Facilities). The presumption is that such safeguarded sites would not have their continued lawful operation compromised by incompatible development situated close to them, if not when coincident where other safeguarding tests would be relevant. Policy DM 8: Safeguarding Minerals Management, Transportation, Production & Waste Management Facilities of the adopted KMWLP 2024-39 sets out both the potential exemption criteria that could be invoked and the tests for acceptable impacts when within 250m of safeguarded facilities. Please see below for further specific comments on the sections within the Supplementary Planning Document Consultation: Policy TR1 - Spatial Strategy: Highways and Transportation The County Council is supportive of the proposed strategy, which focuses the provision of new plots and pitches on allocated sites, existing or planned built-up areas and existing authorised sites. This approach will help to ensure that the new accommodation is provided in locations where suitable access arrangements can be made available and there are opportunities for journeys to be undertaken by walking, cycling and public transport.
I would like to make the following comments on both the MBC Gypsy, Traveller and Travelling Showpeople Plan dated November 2025 and the supporting Appendix C of Volume 2 of the sustainability appraisal of the Plan. The plan details the overall vision and key objectives to deliver sustainable accommodation for Gypsy and Travellers which is also the guiding principals embedded in all the MBC housing developments Plans to ensure any development is sustainable and meets MBC sustainability criteria for everyone in the Borough irrespective of their ethnicity. These criteria are quite rightly rigorously applied and enforced on all Developer or individual Settled community planning applications however Appendix C states that the majority of the existing sites and those identified to be expanded are unsustainable and do not meet the MBC planning sustainability criteria. Global warming effects us all irrelevant of ethnicity and it is totally unacceptable for one ethic group to be seen as not being subject to this key planning principal as it will create tensions with the settled community contrary to the Plan objectives and could be seen as ethically prejudice whilst placing an increased burden on the Gypsy and Traveller site residents of car transportation. As stated in Appendix C many of the current sites in the RSC’s mean the Gypsy and Traveller’s have to travel several miles along unlit roads with no public transport, no footpaths to access fundamental services of shops, Healthcare facilities, schools, railway stations etc… I regularly see Mothers with babies in arms and in push chairs as well as children walking along these roads to access the RSC’s facilities. This is as a direct result of planning permission being granted by MBC disregarding the planning policy of sustainability and I fear this will eventually lead to serious injury or even death as these sites are expanded. There is a real and present danger this will further deter any integration with the Settled Community, as a larger Gypsy and Traveller site is ethnic homogeneity, enhances spatial confinement, is mutually distance and retreats into the private sphere of the patriarchy family is not facilitating integration but re enforcing separation which is contrary to the vision and objectives outline in the plan. This isolation of larger sites also sharpens the boundary between the Gypsy and Traveller Community and the Settled Population driving them to the margins, reinforcing disidentification and prejudice. Again, all of which is contrary to the vision and objectives of the plan. The Plan document acknowledges that at a Parish level there are substantially higher populations of Gypsy and Traveller communities and maybe even higher as there is often a reluctance to disclose their ethnicity. The Plan should also acknowledge in the background that these disproportionate higher levels of Gypsy and Traveller populations are as a direct result of the previous MBC planning decisions. In particular their decision to ignore MBC’s own sustainability criteria and the NPPF guideline which insists that the scale of such sites does not dominate the nearest settled Community and the decision to ignore the cumulative effect on the Parish’s population and the local landscape. The Parish level statistics clearly demonstrate that these Parishes are currently have a disproportionate number of Gypsy and Traveller pitches and any further increase would further breach the NPPF guidelines regarding dominating the nearest Settled Communities. A personal concern has been realised in that the output of these cumulative decisions has been be used as the basis of this development plan with existing unsustainable sites being enlarged to meet the identified need. It seems the Plan has been retro fitted to the “ easy “ option for MBC ignoring the key objectives including sustainability by expanding existing sites or relying on the Gypsy and Traveller community to source and purchase the land, apply for planning permission or retrospective permission, all leading to larger, Irregular and unmanaged Gypsy and Traveller sites which could be seen as creating sort of “ghettos” rather driving integration and delivering on the improvements health, safety, education and employment outlined as key important objectives in the Plan. Point 65 states that rural locations are generally more suited to the keeping of horses and whilst this is true it should not be used as a reason to sites to be located the rural areas. Horse ownership is not an accommodation need and not an essential part of keeping to a nomadic lifestyle. Today the majority of Gypsy and Travellers use motor vehicles and touring caravans to maintain a nomadic lifestyle which do not need to be located in rural locations. To include a comment regarding horse ownership is stereotyping and could be seen as ethnic discrimination. Likewise caravans are regularly seen parked in urban areas and it should not be suggested that rural locations offer better manoeuvring ability especially when the rural roads are often very narrow with occasional passing bays. In the spatial strategy point 68 of the Plan states that Maidstone Town Centre and the Urban areas are most sustainable locations for development and in the forward it states that 20,000 new homes will be built by 2038 but no sites for Gypsy and Traveller pitches has been or will be allocated in Urban areas. The larger residential building developments are generally closer to shops, transport links and health care facilities as a pre requisite of obtaining planning permission. Therefore a requirement to include Gypsy and Traveller accommodation should be mandatory on any new development along either an element of Social housing and this should not be waived by paying a large community infrastructure level as seems to be happening on other developments to reduce Social Housing quotas. Point 68 also states that the closest urban site at Coldharbour Lane is owned by Tonbridge and West Malling Council to meet their Council needs. The Plan does not state whether MBC have looked at this approach with a view to buying land outside the Borough to build a managed site or sites to meet their accommodation needs and meet their sustainability and design criteria’s. The Council should actively pursue this approach which is also used by London Borough’s to meet their social housing needs. Point 72 regarding Invicta Barracks. The document does not give clear reasons why this site is not suitable as an urban location. Development of such brownfield sites has been undertaken before and heritage and environmental constraints have also been accommodated. The site is an ideal site for development of a managed site. It is located near all the amenities, transport links, road networks, healthcare facilities, schools and its location facilitates integration with the local settled community making it an ideal site for a managed site by either MBC, a registered landlord, housing association etc… If after another detailed review, the Invicta Park Barracks is deemed not suitable for a Gypsy and Traveller site then it should not be suitable for any residential settled housing as this would be both incongruous and discriminatory. Safeguarding The safeguarding of permitted sites should include a mechanism to ensure that the sites are solely used by Gypsy and Travellers. There are many mobile homes on current permitted sites that are rented out on a weekly rental basis to non Gypsy and Travellers. Enforcing this requirement will create additional accommodation. Safeguarding should also include a programme to ensure the current permitted sites have met the original planning conditions and they meet the design and health and safety guidelines to ensure the well being of all the residents. Site Design I welcome the design policy on design and layout of new sites which should be enforced however the provision of paddocks, field shelters and other equine facilities should not take preference over providing residential accommodation as horse ownership is not an essential need and can be satisfied by using local livery services both self serviced and managed. Health and Safety: The policy should cover sanitation detailing how dirty water, rain water and sewage are managed on the pitch from both the amenity block or day room to ensure the health and safety of all the residents and to negate any environmental impact. When designing the layout of a site, careful consideration must be given to the health and safety of residents, and in particular children, given the likelihood of a high density of children on the site, vehicles and caravans. It is important to ensure that appropriate traffic calming measures are considered for all sites ensuring that appropriate drainage is accommodated within the scheme to allow for the effective passage of surplus water. Clear and effective signage should be introduced including clear directions should be in place to indicate the location of hydrants and other access points for the fire service etc when attending an emergency on site. The need for separate vehicular/pedestrian access should also be considered. Access for emergency vehicles: Consultation with the local fire and rescue service officer at the designing of a site to gain advice as to a minimum turning and reversing requirements of emergency vehicles in confined spaces for example, which may impact the design. To increase potential access points for emergency vehicles, more than one access route into the site is recommended. Where possible, site roads should be designed to allow two vehicles to pass each other. Specific guidance should be sought from the local fire authority for each site. Although roads on sites do not require adoption, it is recommended that all roads are constructed to adoptable standards of MBC to avoid future maintenance costs, and in anticipation of increased wear and tear due to frequent movement of heavy vehicles. Security The Site layout can play an important role in avoiding a sense of enclosure and isolation amongst Gypsies and Travellers. The aim should be to ‘design out’ crime and social exclusion and ‘design in’ community safety and social inclusion through openness of design, allowing ease in passing through, whether walking or driving. Care also needs to be taken to ensure that proper concern is shown for the safety of residents and children. Site layout should maximise natural surveillance enabling residents to easily oversee all areas of the site. Scheme specific advice on security provision for the site should be obtained from the Police Community Liaison Officer. I have a real concern that many of the current larger Gypsy and Traveller sites do not meet both the Health and Safety requirements and the access to emergency services. Additionally comments on Appendix C The detailed Map showing the location of all the existing sites is hard to read but I have a real concern on the numbers used to calculate the reasonable alternative site assessments. So I looked at the data for the Petsfield site really well and it is incorrect. The site was granted 2 pitches over 15 years ago and then had an additional 3 pitches approved and sited in October 2020 under planning application 20/502748. Therefore from late 2020, the existing is 5 and not the 2 stated in the appendix C. C.1.1.5 states the assessments were based on the baseline information given by the Council. This raises serious questions about the validity of all the numbers provided on both documents. How many of the other site numbers are wrong ? Was pre 2020 data used and why ? Is the overall base case being used flawed not only on these assessments but in the wider existing site calculations..?
Councillors have considered this consultation and have the following comments: An emphasis on the urgent need for affordable pitches for both social and planning appeal reasons. Evidential underpinning for affordable pitch need must be more rigorous.to prevent the current sprawl of uncontrolled development, and for reasons of equity. The current chaotic mess cannot continue. A need to consider the impact of keeping and managing horses as part of planning considerations. Access to utilities, health, social care and education needs to be more robustly addressed within the document A need to consider the impact of day rooms and ancillary facilities and to set out parameters for these
No answer given
Question 1 - Disagree. I strongly object to the intensification, expansion, and reorganisation of existing sites. It is highly inappropriate to further expand large sites, most of which are over-crowded, with poor layouts, with no proper regard for ecology. Many of these sites large sites are associated with crime and disorder and expanding them will only increase their domination of the immediate settled community (not the nearest village or town but the nearest house or houses). Sites that that are located in a LLV, must not be permitted to grown in size or to subdivide pitches. Enforcement must be a key part of these policies. Without enforcement, any policy will not be effective. To date, enforcement has been non-existent or too little, too late with MBC eventually allowing pitches and sites which has resulted in large, sprawling, unregulated, dominating sites and this must end. It has sent a message to some G&T that they can do what they want, where they want. This is unacceptable and must stop. Our open countryside, LLV and ecology – our legacy for everyone – it must be protected. New sites or the expansion of existing sites must not be allowed when proposed in our decreasing LLVs and sensitive ecological landscapes. To encourage G&Ts to educationally achieve, gain and sustain employment and increase their socio-economic statuses and social mobility, sites and pitches need to be allocated within walking distance (sustainability) to amenities and ideally be interspersed within settled communities. This approach would encourage meaningful interactions and socialisation between the G&T and settled community and in the longer-term reduce tensions. Sites and pitches need to be considered within or on the edge of towns to facilitate this approach and not in the open countryside, and especially not in an LLV. Question 2 - Strongly disagree. It is disappointing to read that MBC has chosen to ignore KALC and Headcorn and Ulcombe Parish Council’s, and several other responses, to the Regulation G&T 18b Consultation around G&T accommodation need figures and calculations. The figures in this 18c Consultation are the same as those set out in 18b – why is this? Why have you not taken into consideration the comments of those who responded to Consultation 18b? These figures and calculations are inaccurate, and over-estimate G&T accommodation need. Therefore, MBC are starting from a flawed position. The G&T populations in Headcorn and Ulcombe are already substantial – indeed they represent some of the largest in the UK. This begs the question, why? The answer is a mix of inaccurate figures, flawed calculations, and a lack of enforcement, which has damaged our precious open countryside, LLVs, ecology and sadly has created tension between G&Ts and the settled communities. Many G&Ts see MBC as an authority that does not enforce or when it does it, it never follows through. This is why we have such an elevated and increasing level of demand. Indeed, for example, in Ulcombe the G&T population (about 222) represents around 25% of the population (2021 Census)! This level is disproportionate to the settled community and not in line with national guidelines. There is tension between the settled and G&T communities and accommodating any more in this locality will not help to reduce tensions, indeed it will do the opposite. G&T communities, according to Government figures, have (on average) reported lower levels of social mobility, and higher levels of being represented in the criminal justice system and being sentenced to prison than the settled community. If MBC are serious about addressing inequalities, then the proposed policy would be to accommodate G&T where there is ready access (on foot) to services, health care, employment, and education. Accommodating G&T in rural area, especially in the open countryside, is highly inappropriate and means that G&Ts must rely on private transport to access health, social care, education, and employment. This is against national G&T policy, which raises the question - why are MBC proposing this policy? G&T sites should be established in towns (or on the edge) where there is ready access to facilities and resources. MBC needs to adopt a policy where new housing developments over a certain volume not only need to provide a quota of affordable housing but also in areas where there is G&T need, they also need to provide G&T pitch provision. This would help to meet G&T accommodation needs and importantly to ensure G&T and the settled community are integrated and this would bring about greater longer term social mobility opportunities and benefits to those G&T communities, which sadly have lower socio-economic status and social mobility statuses. Accommodating G&Ts on huge sites, does not help to encourage G&T to move from being an inward-facing, closed culture that is cut-off from wider society. Huge, intensified sites also increase tensions between the G&T and the local settled community. Cultural differences are made more stark and vast numbers encourages validation of these differences instead of establishing small sites, inter-mixed within existing settled communities, which encourages understanding, socialisation, and acceptance. These large sites are often associated with (and many would say encourage) crime and disorder, which again increases tensions between communities. They are also often over-crowed, with few amenities and are unregulated. G&T policy is supposed to reduce tensions between the G&T and settled communities, yet encouraging and establishing huge sites does the opposite. There are already several established sites that are large, growing, and unregulated and they have grown based on lack of enforcement by MBC, retrospective applications, and an ongoing disregard for national and local planning policy. For example, along the Lenham Road, Headcorn, TN27, where in a short space of time MBC has allowed existing sites e.g. The Meadows, Martins Gardens to grow exponentially all via retrospective planning applications with no or extremely limited enforcement. Indeed, when the Planning Inspector disallowed sites in March 2023 unallowed sites on the Rear of the Meadows, MBC enforcement officials went out to the site and encouraged those on disallowed pitches to apply for planning as they disagreed with the Planning Inspector’s considered view. This makes enforcement a tiger with no teeth and sends a strong message to some G&T that they can do what they like, where they like – and indeed this is what has and still is happening! A substantial number of newer sites have sprung up along Lenham Road and G&T massively outnumber the handful of houses (settled community) that are along the Lenham Road. Sadly, this has only served to increase tension between the two communities – this is not right, fair and is against national policy. MBC has allowed greenfield sites in open countryside in a LLV to be systematically destroyed along the Lenham Road and in other areas of Headcorn and Ulcombe. The settled community would not be allowed to build houses, let alone huge housing estates in open countryside in a LLV – yet G&T are allowed to establish sites, many of which are sprawling, have not regard for ecology, do not meet Kent Design Standards, and do not meet foul water disposal regulations. How does this policy sit with the Landscape Character Assessment 2025/26 consultation – where the LLV Headcorn Pasturelands have been recommended as being in the ‘conserve’ category? How does this sit with MBC commitments to ecology? Taking The Meadows as an example of one of the substantial number of sites along the Lenham Road – this started off as a one or two caravans on a green field site in open countryside in an LLV. It is now a huge, sprawling, over-crowded site, with illegal foul wastewater disposal, with caravans extending deep into the open countryside to form the Rear of the Meadows. There is ongoing crime, disorder associated with this and many of the other G&T sites along Lenham Road. See the March 2023 Rear of the Meadows Planning Inquiry report for evidence of trespass, using neighbouring private land as a human toilet, sheep worrying, invasion of land and erecting caravans on private land, outputting foul waste water onto neighbours land, light pollution, which can be seen for miles, noise from dogs barking for hours, noise from motorbikes being driven around the site, shouting, abuse, threats and intimidation by some of the G&T on this side to the local settled community. Locals find the Meadows site overwhelming, dominating and intimidating. Yet MBC want to add an additional 20 pitches to the Rear of the Meadows – how can this be a good idea? It is also frustrating that a huge G&T unregulated ‘housing estate’ – the Meadows - has been allowed to be established when an application for a housing estate for the settled community, including affordable housing would not be allowed. This one rule for the G&T community and another for the settled community has created tensions and increasing the size of already huge sites is not appropriate and will only serve to increase tensions. This is surely against national policy.
Gypsy, Traveller and Travelling Showpeople Plan – Regulation 18 Consultation Linton Parish Council supports and agrees with the response submitted by the Kent Association of Local Councils (KALC) in respect of the Regulation 18 consultation on the Gypsy, Traveller and Travelling Showpeople Plan. The Parish Council endorses the points made within that submission, including concerns about the accuracy of the assessed need, the proposed trajectory, and the need for stronger and more enforceable planning policies. The Parish Council shares KALC’s concern that previous experience following the 2017 Local Plan Review demonstrates that planning permissions for Gypsy and Traveller pitches significantly exceeded assessed need, and that without stronger policies, monitoring and enforcement, this situation is likely to be repeated. In addition, Linton Parish Council wishes to raise concerns regarding infrastructure provision. During a recent open planning forum relating to application reference 24/504496/FULL (Beacon Park), Maidstone Borough Council officers stated that the Council has no control over infrastructure providers and that it is for those providers to “catch up”. The Parish Council considers this to be a serious issue. It highlights the ongoing problem of development coming forward without the necessary supporting infrastructure being in place. This includes health services, education provision and other essential facilities. Linton Parish Council is concerned that further site allocations or approvals, including Gypsy and Traveller sites, in the absence of confirmed infrastructure capacity will place additional strain on existing communities in Linton and surrounding parishes, including Loose and Coxheath. It will also disadvantage Gypsy and Traveller families by placing them in areas where access to essential services is already limited. The Parish Council therefore strongly supports the position set out in the KALC draft response that infrastructure capacity and deliverability must be a key requirement before any further site allocations or planning permissions are progressed through this Plan.
Q1 – Vision and Objectives Proposed amendment • In the fourth bullet point, prior to the semicolon, add: “to the extent afforded to the settled community”. Reason / policy justification • Ensures parity of treatment with the settled community (PPTS para 13; NPPF paras 8, 130). • Reduces perception and reality of preferential treatment beyond statutory requirements. Additional Comment • Vision and objectives should reflect the need for well-managed, safe, and sustainable sites, not just supply. • Consideration should be given to domestic abuse, literacy, education, and social inclusion within Traveller communities, as these affect site management and integration. • Sites should be professionally managed and maintained by councils, registered providers, or developers, to ensure long-term sustainability, community safety, and integration. Q2 – Policy TR1 (Spatial Strategy) Deletion of first paragraph under “Countryside” Proposed amendment • Delete the first paragraph under the Countryside section which allows in-principle development on existing authorised sites. Reason / policy justification • Prevents a blanket presumption in favour of intensification or expansion without assessment of individual site merits (PPTS para 13; NPPF paras 11, 60, 79, 174). • Maintains compliance with countryside protection and avoids dominance over nearby settled communities. • Ensures plan-led scrutiny rather than reliance on historical or windfall permissions. Extension of large-development provision Proposed amendment • Extend the Garden Settlements approach to other large developments. Reason / policy justification • Aligns with PPTS strategic provision and NPPF sustainable development principles (PPTS para 10; NPPF paras 62, 73). • Prevents pressure on small communities while increasing delivery. Additional Comment • The current approach risks unsustainable sites, often distant from services and along unsafe roads. • Emphasises need for sites within or adjacent to urban areas, with access to shops, healthcare, and transport. • Supports integration rather than ethnic homogeneity; small, manageable sites (max ~15 pitches) are preferable for health, safety, and social cohesion. • Sites should be professionally developed and maintained by local authorities, housing associations, or developers. • Compliance with sustainability criteria for urban services, including healthcare and transport, is essential.
Swale thanks you for giving us an opportunity to comment on this document. This document from Maidstone portrays how they are preparing to address the accommodation needs of the Gypsy, Traveller and Travelling Showpeople communities in the borough. It sets out the preferred policies and potential sites. Although there are no new sites on the boundary between Swale and Maidstone, in Policy TR4, an existing site near the border of Swale GT(LPR10) The Ash, Yelsted Road, is allowed to intensify by approximately 5 pitches (net gain), subject to planning permission. Swale would request early engagement on this site. Additionally, the total pitch and plot requirements are 529 and 7, respectively, however, only 251 pitches and 2 plots are deliverable. SBC acknowledges the duty to cooperate matters set out in your consultation and that Maidstone will engage with neighbouring authorities to identify whether they are in a position to help accommodate any potential unmet need for Gyspy and Travellers and Travelling Showpeople. At this time SBC would like to make clear that we do not have a 5-year supply of sites to meet our Gypsy and Traveller need and that it is highly unlikely that we will be able to accommodate any potential unmet arising from Maidstone in the foreseeable future. Moving forward, SBC would look forward to continuous cooperation and early engagement on Gypsy and Traveller and travelling show people matters as they progress.
Dear Sir, Headcorn Parish Council Response to Maidstone Borough Gypsy, Traveller and Travelling Showpeople Plan: Preferred Policies and Potential Sites Regulation 18C Consultation (November 2025) Headcorn Parish Council is the elected body that represents the residents in Headcorn Parish within Maidstone Borough, Kent. Headcorn Parish is a designated Neighbourhood Plan Area and the views expressed in this response have been informed by Headcorn Parish Council's Neighbourhood Plan work (https://headcornpc.org/headcorn- neighbourhood-plan/). Headcorn's Neighbourhood Plan 2022-2038 recently passed both its examination and its referendum and was formally adopted (made) by Maidstone Borough Council on 13th October 2025 (see: https://localplan.maidstone.gov.uk/home/neighbourhood-planning/headcorn) Headcorn Parish Council welcomes the opportunity to respond to this consultation on the Regulation 18C draft Gypsy, Traveller and Travelling Showpeople Plan ("the dDPD"). It considers that a robust gypsy, traveller and travelling showpeople plan is an important component in planning policy and is needed to ensure that development is successful. Unfortunately, Headcorn Parish Council currently has significant concerns about soundness of the proposed policy approach. It therefore considers that more work is needed to ensure that the policies will be judged sound and deliver an effective policy framework. As set out in paragraph 36 of the National Planning Policy Framework ("NPPF"), December 2024 (as amended), to be judged as sound and pass examination, a Local Plan needs to demonstrate that it: has been positively prepared; is justified; will be effective; and is consistent with national policy and, in particular, will enable the delivery of sustainable development, where sustainable development is defined in relation to economic, social and environmental objectives (see the definition of sustainability in paragraph 8 of the NPPF). Headcorn Parish Council does not consider that the proposals, as set out, are consistent with national policy and will not enable sustainable development. In particular, it considers that the drafting of strategic policies supporting intensification, expansion and reorganisation of non-allocated existing gypsy and traveller sites (such as Policy TR1 Part 2.e; Policy TR2; and Policy TR3 Part 3) will result in overdevelopment and will create a range of social and environmental issues. Headcorn Parish Council notes that (unlike small sites) large gypsy and traveller sites within the Parish already create a separation between the settled and gypsy and traveller communities and are associated with a range of social problems, such as anti-social behaviour. The proposed policy approach of intensifying, reorganising and expanding existing sites (without identifying a priori which sites can support this), will exacerbate these issues. Such separation is contrary to the intension of the NPPF, as well as Objective 3 of this dDPD. In addition, the proposed approach will produce results that are directly contrary to the Vision and Objective 1 of this dDPD, in relation to reducing unauthorised development. It is the experience of Headcorn Parish Council that gypsy and traveller development rarely has planning permission prior to occupancy, and even where it does theoretically have permission, the development that takes place bears no resemblance to the one that was permitted (see, for example, the site layout approved as 24/501146/FULL, compared to the site layout in practice). Combined with extremely weak enforcement by Maidstone Borough Council, far from reducing unauthorised development, the proposed approach will create a carte blanche where any site (even sites with retrospective planning permission) can expand unchecked, resulting in large developments that would not otherwise be acceptable in planning terms. The approach will also result in an ever-increasing concentration of gypsy and travellers within a small number of Parishes, including Headcorn. Given the complex needs of many within the gypsy and traveller community, such high concentrations will place a significant strain on education, health, police and social services within the affected areas. Therefore, without an upfront commitment to supporting infrastructure delivery and to fund increased support services, the approach cannot be considered sustainable. Headcorn Parish Council notes, for example, that Headcorn Primary School is already at full capacity and is therefore not in a position to support the additional population increase. The failure to produce Plan policies that will deliver the Vision and Objectives of the dDPD means that, in addition to failing to support the delivery of sustainable development, the draft dDPD also fails the test of soundness on the grounds that it is not justified (in the sense set out in NPPF paragraph 36). Headcorn Parish Council's concerns about the strategy and policies within the Regulation 18C Gypsy, Traveller and Travelling Showpeople Plan, particularly in relation to their sustainability, means Headcorn Parish Council also has significant concerns about the accompanying Sustainability Appraisal. Given Headcorn Parish Council considers a change of policies are needed for the dDPD to be judged sound, it decided not to undertake a detailed response on the Sustainability Appraisal at this time. However, Headcorn Parish Council would be happy to talk through its concerns, if that would be helpful. Our responses to the questions posed in the consultation are included at Annex 1 below. Headcorn Parish Council considers that the issues raised in its response to Maidstone Borough Council's Gypsy, Traveller and Travelling Showpeople Regulation 18b Consultation are also relevant for this dDPD, particularly in relation to estimated need. For convenience, it therefore includes a summary of the issues raised in its Regulation 18b response, as well as the responses to individual questions in Annex 2. Question 1: To what extent do you agree with the proposed Vision and Objectives of the Gypsy, Traveller and Travelling Showpeople Development Plan Document? Partially disagree. Headcorn Parish Council considers that the Vision for the dDPD could do more to discourage unauthorised development. Indeed, far from discouraging it, as worded, the Vision implicitly condones unauthorised development as necessary. Headcorn Parish Council does not consider that the implicit condoning of unauthorised development is sound as it: is not compatible with the Plan being positively prepared; is not justified; and does not meet the definition of sustainable development. For example, unauthorised development can do considerable environmental damage, such as destroying hedgerows, contributing to pollution of local waterways and worsening surface water flooding through excessive use of hard standing. Headcorn Parish Council also notes that Maidstone Borough Council’s approach to deterring unauthorised development (including enforcement action), is much stricter in relation to the settled community than it is for the gypsy and traveller community. This creates tensions between the two communities, as it is perceived as unfair and undermines trust. Therefore, to meet the definition of soundness, as well as in the interests of fairness, Headcorn Parish Council considers that the second and fifth bullets of the Vision should be redrafted, to avoid implicitly condoning unauthorised development, so that they read: Sufficient suitable land/sites available to meet the identified need for accommodation including that of different tenures The same opportunities and responsibilities as the borough’s settled community, including a requirement not to undertake unauthorised development. Question 2: To what extent do you agree with the proposed spatial strategy policy? Please provide comments to support your answer. Strongly disagree/partially disagree. In relation to the drafting of Policy TR1: Spatial Strategy: For the reasons given in its response to the Regulation 18b consultation, Headcorn Parish Council considers that the target of 529 pitches for Gypsy and travellers set out in TR1 Part 1 is too high. In relation to TR1 Part 2 of the policy, Headcorn Parish Council: is pleased to see that Garden settlements have been included as an option within the spatial strategy, and considers that development of these settlements provides a unique opportunity to provide well integrated gypsy and traveller accommodation (TR1 Part 2.c) to meet the calculated need. considers that the policy for Rural Service Centres and Larger Villages needs to be clarified to make clear that it refers to development within the settlement boundary set out in the adopted Local Plan, not within the wider parish (TR1 2 Part 2.d). This would bring it in line with Maidstone’s adopted Local Plan (“MBC LP”). strongly opposes the proposed approach of giving a carte blanche for the intensification, reorganisation and expansion of existing gypsy and traveller sites within the countryside (TR1 Part 2.e.i). (See below for proposals on tightening the proposed rules.) Headcorn Parish Council considers that larger, privately-owned gypsy and traveller sites in the countryside are a major source of problems and should be avoided where possible. It therefore considers that, with the exception of Council owned/run sites, the development of greenfield sites within the countryside should be restricted to minor development only, including rules to avoid gaming the system by first subdividing a field and then applying for permission for each subdivision separately (TR1 Part 3). Headcorn Parish Council would like to see explicit mention of the fact that the Development Plan includes Neighbourhood Plans added to Policy TR1 Part 5, to ensure these are given appropriate visibility. Headcorn Parish Council considers that the proposed approach to intensification, expansion and reorganisation of existing gypsy and traveller sites in the countryside is neither justified nor consistent with sustainable development. In particular, it considers that: it is likely to encourage not deter unauthorised development, given the high likelihood it will be subsequently authorised (in line with current practice). Unauthorised development is often associated with significant detriment, but under the proposals once retrospective permission is given further expansion can take place, creating perverse incentives. it will result in overcrowded sites with poor amenities, eroding the living standards of residents and will lead to a range of social problems. This is particularly true as intensification is likely to take place without prior planning permission, and the proposed approach will make it harder to challenge. it will result in further concentration of the gypsy and traveller population within a few Parishes (including Headcorn), as the proposals would mean that development will mainly take place where there is existing development. This will exacerbate existing issues and can only be considered sustainable, if it is supported by significant infrastructure investment and an upfront commitment to fund the education, health, police and social services needed to support the gypsy and traveller communities, who often have a range of complex needs. This is lacking from the current Plan, which makes no reference to required enhancements to infrastructure and support services to support the proposals. it is likely to result in development that creates a range of landscaping and access issues and that will be contrary to the relevant policies for the area in question, but will be hard to challenge. For example, it is likely to result in a continuation of current development practices that result in developments where each individual unit has its own access onto the highway system (rather than a single access for the site as a whole), resulting in the suburbanisation/urbanisation of the countryside, as well as environmental harm. For example, the site layout approved under 24/501146/FULL, involved a single access point for the site as a whole, and a development that would be in keeping with existing development patterns in the countryside and would preserve trees and hedgerows to encourage wildlife. In practice when the site came to be developed, most of the hedgerow has been torn out and individual entrances to the site have been added to highway (Love Lane) without permission, with high fences and other impermeable barriers added that are more suitable for an urban setting. This type of change will be harder to prevent under the proposed policy, given the explicit permission of reorganisation. 3 It is contrary to one of the rationales for why gypsy and traveller development needs to be in the countryside set out in paragraph 65 of the dDPD, namely the keeping of horses, as site intensification and expansion will reduce land available for this use. Headcorn Parish Council recognises that for individual families, as their children grow, may need more accommodation to deal with this (in the same way the settled community may seek to add an extension). It considers that this could be dealt with by allowing for the addition of more touring caravans to accommodate children, rather than a blanket permission for site expansion and intensification. Headcorn Parish Council notes that larger sites in the countryside are in general the ones that create significant issues. It therefore considers that large sites should be avoided where possible and should ideally only be supported where they are Council owned and/or run to prevent problems. Reflecting the problems cause by larger sites, Headcorn Parish Council also considers that any major development in the countryside (defined in the NPPF as “development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more”), should only be allowed where it comes forward as an allocated site within the Local Plan (and that this should apply to both the settled and gypsy and traveller communities). This would ensure proper scrutiny of any proposals and a consideration of sustainability issues. Headcorn Parish Council notes that under the new rules for Local Plans, there will be regular opportunities for sites to come forward as allocated sites within the Local Plan and therefore does not consider that prohibiting large developments on unallocated sites is overly onerous, considering the planning benefits of doing so. Headcorn Parish Council therefore considers that much stricter rules should be applied to any permitted intensification, expansion or reorganisation, in order to limit potential detriment and reduce perverse incentives. To achieve this, it considers that Policy TR1 Part 2.e.i should include much stricter rules for intensification, reorganisation and expansion, namely that it can only take place where: it represents the addition of touring caravans to accommodate young adult children of the existing residents (in other words allowing the accommodation to expand to meet the needs of a nuclear family unit); or is limited to one or two units within existing site boundaries, that use the existing site access and where the broader site as a whole (ie. including all the units within the original field boundary, such as any previous subdivisions) would not be defined as a major development (ie the final development within a field will involve fewer than 10 homes and a site of less than 0.5 hectares or 1.235 acres).
Q1 - To what extent do you agree with the proposed Vision and Objectives of the Gypsy, Traveller and Travelling Showpeople Development Plan Document? Ulcombe Parish Council strongly disagrees Ulcombe Parish has the highest percentage of G&T pitches per settled population in the whole country. We strongly disagree with the “vision” to provide the majority of the 529 extra pitches on existing sites. We need to emphasise that the number of existing pitches and of the G&T population in Ulcombe and Headcorn have been seriously underestimated and seem to have been ignored because the proposed vision of “Putting People and the Environment First” certainly does not apply to Headcorn Ward. Headcorn Ward has about 40% of all G&T mobile homes in Maidstone Borough and we in Ulcombe are appalled at the cavalier disregard in many cases for protecting Landscapes of Local Value, and the countryside, which is constantly blighted by inappropriate development in a very unsustainable area. There is no point having countryside policies if Maidstone regularly ignores them which means the “Vision” becomes rather meaningless. Objective 1 should be reworded to say …..“in line with MBC’s Local Plan countryside policies, the PPTS planning guidelines and the NPPF on Sustainability. Objective 2 Agreed in principle Objective 3 It is all very well to talk of G & T needs, but where are the needs of the settled community listed? They have been ignored which goes against the guidelines in the PPTS. The needs of the settled community are largely ignored in Reg 18c and there is a built in bias as MBC has ignored its own Reg18c Appendix B (especially Section B.3), its Local Plan LPRHOU8 the NPPF and PPTS 2024 (para 13) which says traveller sites should be sustainable and LPA policies should promote integrated co-existence (no sign of this in Ulcombe). The Local Plan proposes to promote access to health services, ensure protection of the environment and reduce long-distance travelling. None of these “Visions” is possible in Ulcombe as we have no public transport, no village pub, no medical facilities or shops and no services. Headcorn has these facilities, but they are 5.5km away by car on a country lane with no footpath. We have had house applications refused by MBC because of unsustainability and the need for car use. MBC justifies the unsustainable nature of 127 of the proposed sites (Reg 18c Appendix C) by claiming that the deficiencies are only of “minor negative impact” (para C.3.2.2). This is a deliberate snub to the settled population of Ulcombe which cannot understand why MBC wants to overwhelm a small village when the obvious solution is to spread G & Ts more fairly around the borough or simply refuse to allow them to dominate Maidstone. MBC is perceived as a soft touch, but experience of fruit and hop picking is now perceived to be irrelevant as modern farms employ large groups of foreign workers on temporary permits. In Appendix C, it says (for example) in para C.3.2.2 on Bus stops that 127 sites are located more than 400m from a bus stop with frequent services. The distance measure is breached for many more sustainability criteria. But this breach of Appendix B3 is apparently only a “minor negative impact “when in fact it is a major negative impact if the nearest shops, medical facilities, and public transport are 5.5km away in Headcorn with no access on a narrow lane with no public transport, paths or cycle ways, In para 43 of the Reg 18c Consultation, it says that the G&T population of Maidstone is 5.74 per 1,000 residents. This is distorted because it is using town areas in Maidstone that have very few gypsies and travellers to water down the percentages. It is disgracefully misleading. In Ulcombe, the G & T population figure, including children, is between 222 and 267 based on 3 occupants in each of the 74 mobiles and 1 occupant in each tourer. The population of Ulcombe in the 2021 Census is 929 including children. The traveller population is therefore between 24% and 29% of Ulcombe’s population including children, which would rise closer to 33% if the proposed extra mobile homes in Ulcombe are agreed. This makes a mockery of the figure in para.43, on these figures we urge MBC to scrap any idea of adding more mobiles in the parish of Ulcombe or indeed in Headcorn Ward. There are serious tensions in Ulcombe between the two main traveller groups (Irish and English) and between the travellers and many in the settled community. This is why the PPTS is so specific in its guidelines about how to reduce tensions, which MBC is ignoring. The Consultation document para 19 correctly says that G&Ts have histories, heritage and traditions that distinguish them from settled communities. It is because Ulcombe is “ dominated” by such a large G & T population (PPTS para 14) that these tensions are increasing, particularly as the G&TS do not need to integrate because their communities are so large. Q2. To what extent do you agree with the proposed spatial strategy policy? Please supply comments to support yout answer. Ulcombe Parish Council strongly disagrees MBC - MOBILE COUNTING ERRORS FOR ULCOMBE PARISH We list below the errors in counting and understanding by MBC of the existing Ulcombe Mobile Count and in the Potential additional Mobile homes in Ulcombe as listed in Table C.1.1 of Appendix C. a) Existing Mobiles in Ulcombe The Mobile home count for a number of Ulcombe existing sites is incorrect in the GTAA 2023. There are 28 not 7 in the 3 sites below, plus tourers, which are often unofficially occupied by extended family members. Ulcombe Existing Mobile stock December 2025# Martins Gardens (TN27 9LJ) - 12 not 6 Neverend Lodge (ME17 1EF) - 2 not 1 Neverend Barns (ME17 1EF) - 14 not 0 Golden Oaks (ME17 1ED) - 1 The Vine, Green Hill Lane (ME17 1NF) - 5 Water Lane (Public Site) ( ME17 1DH) - 14 Opposite Water Lane (ME17 1DH) - 1 Hawthorn Farm (ME17 1EF) - 5 Roydon to rear of Vine Cottage (ME17 1EF) - 7 Roydon Farm itself (ME17 1EF) - 5 Land to rear of Neverend Farm (ME17 1EF) - 8 Total (excluding tourers) - 74 pitches b) Ulcombe Potential Additional Pitches as per Table C.1.1 in Appendix C of Reg 18c. We object to any more Mobile homes in Ulcombe because our small village of 340 dwellings is completely dominated. If these new pitches are allowed, we will have 74 +27 = 101 Mobile home pitches and a G&T population of about one third of the settled community. Ulcombe had a Call for Sites in 2019 including one G & T site at Hawthorn Farm. All 4 sites were declared to be in the red zone as unsustainable, and this is a major reason why further G & T development in Ulcombe is contrary to MBC’s own policy on sustainability. Since 2019, we now have no public transport at all. The village pub has closed and all services, cafes, shops and medical facilities are in Headcorn 5.5km away. There is no bus to Headcorn, no pavements and no cycle tracks, The road is a country lane. We have had several planning refusals by Maidstone for houses on the grounds that the use of cars would be against MBC’s policy to discourage cars. This is ludicrous in the country and it is revealing that all these sustainability policies (whether from MBC, PPTS or the NPPF) do not seem to be applied to G &T sites. This is not fair or equal treatment. We take issue with para 79 because although MBC admits the countryside has an intrinsic rural character and beauty that should be conserved and protected for its own sake. It then says that there is a need to support certain developments in the countryside where it contributes to maintaining a prosperous rural economy and to maintaining mixed communities. We would like to know what economy because supporting shops are 5.5km away and the extra mobiles do not need to be in Ulcombe for this, and we already have the most mixed community in Maidstone, Ulcombe is not a sustainable village and thus PPTS 2024 para 24 applies. It says there should be a presumption in favour of sustainable development. This has not happened so far. And para 26 says that for traveller development applications. LPAs should strictly limit new traveller site development in open countryside that is away from existing settlements and should ensure that sites in rural areas respect the scale of, and do not dominate the nearest settled community. In PPTS para 28 it says that if the LPA cannot demonstrate a 5 year supply of deliverable sites then it should check if NPPF 2024 para 11d applies. However, NPPF para 11d ii clearly says that any attempt to justify sustainable development should not take place if the adverse impacts significantly and demonstrably outweigh the benefits. This is definitely the case in Ulcombe, which is why we are against expanding out traveller sites. Comments on Potential Sites Hawthorn Farm, 4 sites - [LPR 032, 0116, 0264, 0225 ] proposes 7 more Mobiles - (ME17 1EF). This makes the total around Hawthorn Farm of 12 mobiles. We very much object to any more mobile homes in post code ME17 1EF which already has 41 Mobile homes dominating the settled community of 11 houses. This is not “putting the people first” as claimed in the proposed vision and completely contradicts PPTS 2024 para 14 on domination, contradicts para 23, para 24 about sustainable development, and contradicts para 26 that LPAs should strictly limit new traveller site development in open countryside that is away from existing settlements and should ensure that sites in rural areas respect the scale of, and do not dominate, the nearest settled community. NPPF para 11d ii (mentioned in PPTS para 26) clearly says that any attempt to justify breaching para 26 should not take place if the adverse impacts significantly and demonstrably outweigh the benefits. This is the case for all potential new pitches in Ulcombe in Reg 18c. Woodview Farm C4S-003 - proposes 6 more Mobiles (ME17 1LU) - The owner of this property in 2022 applied for 6 mobile homes but it was refused by MBC and the Appeal was dismissed. The owner then sold the land in 2 halves and the two new current owners want you to drop this site from your list of potential sites. Water Lane 0145 - proposes 7 more Mobiles (ME17 1DH) - This proposal completely damages the historic environment of the Kingswood. When Water Lane caravan site was first established there were no TPOs. It sits in the middle of the Kingswood, which is an Ancient woodland protected by MBC because it is over 500 years old. No expansion of pitches is possible without cutting down and removing ancient trees. Some of the current travellers bought an area of the Kingswood on the other side of Water Lane and cut down many ancient trees protected by TPOs and submitted an application for mobile homes. MBC refused permission and the Planning Inspectorate dismissed the appeal (see APP/W/2235/C/25/3369052). We oppose any attempt by MBC to breach the Inspectorate’s decision as this would be environmental vandalism and contrary to NPPF 11d ii. Land Rear of Neverend Farm – 0248 - proposes 5 more Mobiles (ME17 1EF) - This would be adding to an existing environmental disaster. This site is landlocked with no legal or prescriptive Right of Way although the site is owned by the travellers. It was a greenfield site until about 400 tonnes of hardcore were added. The track is a private track established by the owner of Neverend Farm to give access from the road to their farm buildings and market garden which is now their garden. The G & Ts currently claim a right of way to the road but have never produced evidence. MBC refused the application for the 8 mobiles and 8 tourers and went to the High Court for a Permanent Injunction. This was granted but the G & T owners of this landlocked field went to Appeal (APP/W/2235/C/19/3243809 and 19/3241823). The Appeal was upheld although, the Local Plan says there has to be “safe access”. MBC were furious with the Appeal decision because it said that MBC’s countryside policies in the Local Plan were out of date, despite the fact that MBC policies cover the whole Borough and not field by field, and that a policy of protecting the countryside is not time restricted. This site needs to be taken off the list because it is an inappropriate site and is causing great tension. Green Hill Lane - 0114 - proposal 2 more Mobiles (ME17 1NF) - Ulcombe Parish Council objects to the proposal to increase the traffic on the narrow Lenham Road. The 0.8 hectare site already has 5 mobiles and is too small for 7 mobiles and tourers in addition to the owner’s storage of many caravans for his business. We have consistently supported MBC’s countryside policies to protect the rural environment for future generations, but generally to no avail. To say: “the settled community should have certainty about their future and that of the local environment” is welcome but not believable as MBC constantly breaks its word on sustainability, in the cause of blighting the beautiful countryside for a disputable figure of G&T “need”. It should be an objective to oppose the urbanisation of intrinsically dark landscapes in unsustainable areas as a result of hardstanding, fences, mobile homes, tourers, all night lighting and a multitude of vehicles and noise. These are reasons for refusal used by MBC if countryside applications are inappropriate but rarely on G & T applications. Many rural areas in Maidstone, especially Headcorn Ward and the villages of Ulcombe and Headcorn, have far too many G & T sites already because of the problems of poor infrastructure, and with services and facilities needing cars to access them. MBC needs to question the “so called” need for 529 pitches. Any private company faced with the problem and cost of G&T accommodation would rightly demand to have clearer details of those wanting to come to Maidstone. Otherwise, the “need” is based less on robust evidence and more on nothing but a wish list. We think MBC should apply more rigour to these speculative figures. If existing travellers in Maidstone were asked if they had a further need in the future for more pitches, the answer is bound to be “yes”. There should have been more rigour in the interviews. Given the number of G & T sites in Headcorn Ward with permanent status, they should not be expanded as per Policy TR1 because of all the current problems referred to above, including the fact that many of these sites are in unsustainable areas, like Ulcombe. The Spatial Strategy in the New Local Plan and Policy TR1 should apply to both allocated as well as to current non-allocated sites to prevent worsening an existing situation with new pitches. All new traveller sites should be allocated to Wards which have very few G & T sites, and especially to areas in or very close to the urban area, given that Headcorn Ward has about 40% of the total mobile homes in Maidstone.
Summary Conclusion 0. This submission concludes that: • the consultant’s report underpinning the assessed needs assumed for Reg18C is flawed; • the assessed needs are, in reality, far less; • the Trajectory for assessed needs is therefore far less and profiled substantially differently to Reg18C’s proposal; • that different Trajectory could be met by evidenced windfalls history, without any need for newly identified pitches; • to the extent that windfalls reduce in the future, Lepus Consulting offers a list of 27 candidate sites, subject to further mitigation and their meeting sustainability criteria, or otherwise MBC would need to add other sustainable sites / pitches to that candidate list; • MBC should strengthen, and, as necessary, add to existing policies to enable it to avoid a recurrence of the situation after 2017 Local Plan Review; and • MBC should seek to dispel its reputation as a “soft touch”. Context 1. This submission does not examine allocation policies, but addresses the overarching subject of provision of accommodation for that section of our community that identifies as Gypsy & Traveller. 2. All sections of our community have a right to their accommodation needs being assessed and addressed where reasonable, with principles of fairness applying in all instances. 3. To treat any section in an unfair way could be held to be divisive or even racist and that must be avoided. Background 4. Our Reg 18B submission was, in essence, ignored by MBC. 5. As it remains valid, it is appended to this submission for the benefit of the Inspector at eventual Examination and, as necessary, will be re-submitted at Reg19. 6. MBC’s questions included within Reg18B gave no opportunity for respondents to offer comment on the report from Opinion Research Services (ORS) that underpinned the assumed “need” within Reg18B. 7. This Reg18C continues that avoidance of comments on that consultant’s report. 8. The analysis by ORS has apparently been accepted by MBC without challenge; we offered challenges in our submission to Reg 18B, but MBC chose not to pursue them, even though they might have delivered a consequential substantial reduction in assessed needs. 9. Evidently MBC continues completely to agree with the conclusions of ORS and has not brought any critical analysis to bear, despite the fact that ORS’s January 2023 Interim Report included the observation in its page 38 that (our highlighting): However, the most common reason identified concerned the assumed perception that the Travelling community have of Maidstone Borough Council, and its current Gypsy & Traveller policies. It was suggested that Travellers come to the area as Maidstone Borough Council are seen as being receptive to having more sites, and therefore readily accepting of applications and more likely to approve most. Furthermore, it was also suggested that costs associated with enforcement and appeal action prevent the council from upholding its countryside policies, which further encourages Travellers to settle in the area For some reason, those words have not been carried into the April 2025 Final Report, despite offering important issues that require MBC’s attention. 10. In essence, our Borough is seen as a soft touch, accentuating unfairness across our Borough. 11. Since the adoption of 2017 Local Plan Review, planning approvals for pitches have massively exceeded the assessed needs that formed the basis for the allocation of G&T sites in that plan. 12. It is clearly evident that the situation is out of control and we noted possible reasons for that at Reg18B. 13. MBC needs to work in a determined manner, with the benefit of robust policies, to remove its apparent reputation for “ ….being receptive to having more sites, and therefore more readily accepting of applications and more likely to approve most”. (ED76, page 18) Societal Considerations 14. Paragraphs 19-30 in Reg 18C state MBC’s perspective on the matter. Its latter paragraphs contain (our highlighting): For everyone – regardless of ethnicity or type of home – having no permanent accommodation can have adverse effects on quality of life and life opportunities generally. Providing permanent or even temporary accommodation significantly improves a person’s ability to meet other primary needs, especially access to healthcare, education and employment opportunities. Providing culturally appropriate accommodation also enables Gypsies, Travellers and Travelling Showpeople to continue to live a nomadic way of life should they wish. Evidence shows that ethnic Gypsies and Travellers in particular suffer from some of the most extreme health disparities in our society. This is highlighted in the Kent ‘Gypsy, Roma and Traveller Populations’ Joint Strategic Needs Assessment (June 2023)1. Having ‘nowhere to go’ and living on unauthorised sites or encampments can also have a direct effect on mental and physical health. This in turn can add pressure to other public services, such as the NHS. This plan can contribute to improving health, education and social outcomes through meeting accommodation needs on lawful, high-quality, well-planned sites. It can also ensure that sites have a minimum standard of basic amenities. The Plan seeks to improve social cohesion by providing both the settled and the travelling communities with security and certainty about their future, knowing where and when homes are likely to be provided. This in turn can help to reduce documented social tensions and allow everyone an equal opportunity to thrive in the borough. 15. We fully agree that all members of our Borough’s community should have reasonable access to appropriate accommodation and that the underlying causes of health disparities, educational disadvantages and any disadvantageous social outcomes should be analysed and, wherever possible, remedied; that is what should happen in a civilised, lawful country. 16. Not to pursue such remedies to the disadvantage of a particular section of our community might be construed as racist, and should not be condoned. Population Numbers 17. Paragraphs 41-44 in Reg 18C give various statistics (our highlighting): There are approximately 71,200 households7 in Maidstone borough, but only approximately 576 Gypsy, Traveller and Travelling Showpeople households. In response to the 2021 Census, 5,405 people in Kent (0.3%) identified themselves as being from Gypsy and Irish Traveller ethnic groups, while the corresponding figure for England was 0.1%. Maidstone borough has the highest Gypsy and Traveller population by local authority area across England and Wales, at 1,009 ‘usual residents’ 9. The Gypsy and Traveller population per 1,000 residents in Maidstone equates to 5.74. The national average is 1.06 per 1,000 of the population. Although the borough’s ward boundaries have since altered, the 2021 census data shows that within Kent, the wards of Marden and Yalding, Coxheath and Hunton, and Headcorn10 ranked in the top five of England local authority districts with the highest proportion of people from the Gypsy or Irish Traveller ethnic group. At a Parish level, Linton, Hunton and Ulcombe have high populations of Gypsy and Irish Travellers communities. 18. These statistics are compatible with our Borough being seen as a soft touch. 19. It should also be noted that these figures imply a ratio of just under 2:1 for “usual residents”:households and will be referred to below. (Note: “usual residents” is found in Table TS021 that refers to the Census 2021 dataset for Ethnic Group in England and Wales, provided by the Office for National Statistics (ONS)). Assessed Needs 20. Reg18C, page 15, contains: Please see attached table 21. That table is a direct read-across from Figure 19 in page 49 of the report from ORS. 22. The figures for 0-5 years include pitches for: Gypsy & Traveller Needs: Households on unauthorised developments 49 Concealed households/Doubling-up/Over-crowding 98 5 year need from teenage children 98 Undetermined Gypsies & Travellers: Households on unauthorised developments 19 Concealed households/Doubling-up/Over-crowding 32 5 year need from teenage children 31 Total: 327 of the above 333 23. If it were an analysis of bricks & mortar requirements for the general population, “unauthorised” would be addressed by enforcement and concealed households and the needs of teenage children would probably not give rise to assessed needs being met within five years, but, rather, spread over a longer period, if not the whole plan period. 24. Fairness across the whole community would remove much of that 333 from the assessed needs in the first five years and spread it over a much longer period, if not the whole plan period. 25. It must be noted that, of the 333 in the first five years, some should be, or should become, available at existing sites. ORS states that number to be zero, which stretches credibility Pitch Turnover & Mortality 26. ORS’s report contains in paragraph 3.36 (our highlighting): Pitch Turnover West Oxfordshire Council relies on a GTAA published in 2013. This identifies an immediate need for 6 additional pitches. However, the GTAA methodology treats pitch turnover as a component of supply. This is only the case if there is net outward migration, yet no such scenario is apparent in West Oxfordshire. Based on the evidence before me I consider the underlying criticism of the GTAA to be justified and that unmet need is likely to be higher than that in the findings in the GTAA. 3.36 Some assessments of need make use of pitch/plot turnover as an ongoing component of supply. ORS do not agree with this approach or with making any assumptions about annual turnover rates. ORS consider that this approach frequently ends up significantly under-estimating need as, in the majority of cases, vacant pitches/plots are not in fact available to meet any local need. The use of turnover has been the subject of a number of Inspectors Decisions, for example APP/J3720/A/13/2208767 found a GTAA to be unsound when using turnover and concluded: 27. In that decision, “only the case if there is net outward migration” would appear completely to ignore mortality, which is examined below. 28. Further, ORS’s report contains in paragraph 3.37 (our highlighting): In addition, Best Practice for Assessing the Accommodation Needs of Gypsies and Travellers5 produced jointly in June 2016 by organisations including Friends, Families and Travellers, the London Gypsy and Traveller Unit, the York Travellers Trust, the Derbyshire Gypsy Liaison Group, Garden Court Chambers and Leeds GATE concluded that: Assessments involving any form of pitch turnover in their supply relies upon making assumptions, a practice best avoided. Turnover is naturally very difficult to assess accurately and in practice does not contribute meaningfully to additional supply so should be very carefully assessed in line with local trends. Mainstream housing assessments are not based on the assumption that turnover within the existing stock can provide for general housing needs. 29. That conclusion and logic do not appear consistent. It states: “involving any form of pitch turnover in their supply relies upon making assumptions, a practice best avoided”, when, in fact, making assumptions is the foundation of forward projections. And as for not including turnover in mainstream housing assessments, that is because in- and out-migration are implicitly considered. 30. ORS’s report then continues (our highlighting): 3.38 As such, other than current vacant pitches/plots that are known to be available, annual pitch/plot turnover has not been considered as a formal component of supply in this GTAA. However, natural turnover of pitches/plots on public and private sites/yards should continue to be monitored by the Council. In particular, the natural turnover of pitches/plots can help to meet future need over time from new household formation. 31. Mortality is a fact of human life. Why should such monitoring not give rise to reasonable assumptions on pitch/plot turnover? 32. A very sensitive subject but ORS’s report, in paragraphs 2.15-2.16 of Appendix D, contains (our highlighting): Death Rates 2.15 Although the above data imply an annual growth rate through births of about 2%, the death rate has also to be taken into account. Whereas the average life expectancy across the whole population of the UK is currently just over 80 years, a Sheffield University study found that Gypsy and Traveller life expectancy is about 10-12 years less than average (Parry et al (2004) ‘The Health Status of Gypsies and Travellers: Report of Department of Health Inequalities in Health Research Initiative’, University of Sheffield). 2.16 Therefore, in our population growth modelling in 2013 ORS used a conservative estimate of average life expectancy as 72 years – which is entirely consistent with the lower-than-average number of Gypsies and Travellers aged over 70 years in the 2011 Census (and also in ORS’s own survey data). 33. The following table then appears in Appendix D (our highlighting): Figure 24 – Age Profile for the Gypsy and Traveller Community in England 2011 and 2021 (Source: UK Census of Population 2011 and 2021) Please see attached table 34. Assuming our Borough has the above profile, the above indicates that over the first five years of the period covered by Reg18C (to 2040), some 2.5-5% of individuals may not require ongoing accommodation. While it is recognised that not all resultant accommodation may be available to others, for the consultant to ignore mortality would appear to be difficult to defend. 35. With our Borough having, from above, 1,009 ‘usual residents’, annual national population growth statistics for Gypsies & Travellers of circa 1.5%p.a. would imply some 75 additional persons over the first five years (with mortality having been netted off). At occupancy of 2 (or more), that implies a need for less than 40 pitches over the first five years, far less need for additional pitches than the 333 from above (PPTS definition, plus Undetermined). 36. For the remainder of the plan period, ORS uses population increase statistics based on national averages. Those statistics offset birth and death rates and not to do similar in the first five years gives rise to a higher, false “platform” at the end of the first five years from which to project forward. That gives a sustained over-estimate of needs over the plan period. Sustainability 37. For Reg18C, a Sustainability Appraisal of the Maidstone Gypsy, Traveller and Travelling Showpeople Development Plan Document 2023-2040 (date October 2025) has been prepared by Lepus Consulting for MBC. 38. After reviewing MBC’s identified 158 “reasonable alternative sites” using its “receptor-led methodology”, then applying mitigation measures in an endeavour to overcome unsatisfactory impacts to optimise sustainability performance, 27 potential sites remain for possible allocation at Reg19, as illustrated in the table below from the SA report (with the colour coding below): Please see attached table 40. The colour coding is: Please see attached table 41. As can be seen, none of the 27 meets “negligible” or better judgement across all criteria. 42. The assessment of each of those 27 includes the words: “Select, subject to more detailed assessment prior to Regulation 19 draft submission plan”. 43. If the assessed need from the ORS report is accepted, there will be pressure to identify more sites for review and also to tailor the “more detailed assessment” to allow many of that 27 to be selected. Windfalls 44. Page 7 of the Strategic Land Availability Assessment (November 2025) contains the table to the right; 45. Some of those windfalls may have arisen because MBC had not got sufficient, or sufficiently strong, policies to refuse and then perhaps chose not to defend, or failed, at any appeal. 46. On the face of it, a significant proportion of any assessed needs might be met by future windfalls. 47. Over the 18 years’ period of the DPD, windfalls might amount to some 500 pitches, almost equivalent to the currently assessed needs (see paragraph 20 above). Policies 48. Paragraph 4.197 of 2017 Local Plan Review states (our highlighting): The Gypsy and Traveller and Travelling Showpeople Accommodation Assessment (GTTSAA) revealed a need for 187 permanent Gypsy and Traveller pitches to be provided in the borough during the period October 2011 and March 2031. A further 11 plots for Travelling Showpeople will be required over the same period. 49. Paragraph 3.64 of MBC’s Authority Monitoring Report (2022-23) states (our highlighting): The Local Plan outlines a 187-pitch target over the plan period. Since 2011, the base date of the Maidstone Borough Local Plan, a total of 312 pitches have been granted permanent consent (Table 21). At the 1st April 2023, the rate at which permanent permissions have been granted exceeds the target. ………… 50. That would indicate a failure either to apply policies or inadequate policies that led MBC to conclude that it would be unsuccessful when defending appeals and therefore just approved applications, whatever their merits. 51. That points to a need to ensure that policies within 2024 Local Plan Review or in the eventual DPD are robust to challenge, particularly when considering development in the countryside and close to small and large villages. 52. Whatever the Examination of this DPD determines for the numbers in the Trajectory of allocated pitches, MBC has to ensure that relevant policies are sufficiently tight to withstand appeal against any refusals. Policies to-date have clearly been inadequate, encouraging MBC more-or-less to wave-through applications as they did not expect to be able to withstand appeal. 53. Existing policies require review and, as necessary, strengthening and perhaps new policies defined to avoid a repeat of the above situation after 2017 Local Plan Review. 54. In support of that, MBC must allocate a sufficient budget to resist all appeals and to deter future applications for pitches beyond Trajectory. 55. That would serve to dispel the “soft” reputation referred to above. 56. As an important detail, presumably it should be ensured that all approved sites and pitches are retained for use only by those for whom they were approved. If existing or draft policies are not strong enough to ensure they are not occupied by those who do not qualify for such approved sites and pitches, we urge MBC to correct the situation so that, as necessary, enforcement would be able to ensure occupation only by those who qualify. Monitoring Regime 57. The monitoring regime laid out in pages 64-66 of Reg18C has been added to since Reg18B, but still leaves considerable gaps in capturing a full picture of the evolution of the matters covered by the DPD, particularly applications for, and approval of, new pitches and level of success in resisting appeals. 58. It needs to be further expanded, as indicated in our submission to Reg18B. 59. MBC then needs to demonstrate sufficient determination, with sufficient budget, to resist appeals so that the pitch Trajectory determined at DPD Examination is adhered to. Consultant’s Questionnaire. 60. The questionnaire used by ORS has 35 questions, with some of those being “leading” questions, such as: • Q5a. Is this site/yard suitable for the needs of your household? • Q14a. If anyone currently living with you needs their own separate accommodation, how many pitches/plots are needed for them now, and how many will be needed within the next five years? 61. That questionnaire compares unfavourably with that used by the consultant for Tonbridge & Malling Borough Council’s current Reg18 Local Plan – the consultant arc4. 62. Its 58 questions are laid out later in this submission and are more neutral / objective than ORS’s and, if used, would be likely to have arrived at significantly less “needs” for our Borough. Summary – General Points 63. ORS’s questionnaire is less rigorous and objective than the one used by the consultant for Tonbridge & Malling Borough Council, therefore probably assessing needs greater than they actually are. 64. ORS ignore mortality during the first five years. 65. ORS assume that all need derived from all “Households on unauthorised developments”, “Concealed households/Doubling-up/Over-crowding” and “5 year need from teenage children” are met in the first five years. Whether the first category should be planned for is a moot point, but the latter two should be treated in a parallel manner to bricks & mortar accommodation for the overall community i.e. spread through the plan period. 66. The situation that arose after 2017 Local Plan Review must be avoided by reviewing / strengthening / adding policies, establishing sufficient budget to resist appeals and having the willpower and means to engage enforcement. MBC must generate the means and willpower to counter its current “soft” reputation. 67. All sections of our Borough’s community should be addressed fairly and treated equally. Summary – Needs & Trajectory, Five Years’ Supply 68. From paragraph 20 above: Please see attached table 69. From paragraph 19 above, it is noted that, at present, the ratio of “usual residents”:households: is just under 2:1. 70. That implies that either the extent of “Concealed households/Doubling-up/Over-crowding” stated in paragraph 22 is very much exaggerated or otherwise there are many currently vacant pitches that might be available for future use. 71. Allowing about 50% for that exaggeration or exclusion of vacant pitches, then spreading the balance across the full plan period, while adjusting for mortality in the first five years would derive a very different picture of the Trajectory when compared with the table in paragraph 68 – see Revised Profile to the right: 72. It is to be noted that, as laid-out in paragraph 44 above, windfalls could more than meet that revised profile. 73. With respect to the NPPF’s requirement to maintain a Five Years’ Supply, the calculation methodology allows the inclusion of an allowance for windfalls, where evidenced by history. 74. To the extent that evolving “history” starts to reduce the number of evidenced windfalls, perhaps because of the factors outlined above, MBC would need to call forward some of its above list of 27 potential sites (or other identified sites), if they pass sustainability criteria, after further mitigation. 75. There is no argument for now identifying specific sites / pitches, but, rather, challenging the assessed needs (as above), re-profiling the Trajectory, as in the table above, and then including windfalls to meet the requirement for Five Years’ Supply, with a reserve list of candidate sites for calling forward in the event of a shortfall against that requirement. Conclusion 76. The assessed needs within the ORS report is not defensible for reasons outlined above and in our Reg18B submission (which is attached). 77. Even if the figure for assessed needs within the ORS report is accepted, which we do not, the current trend of windfalls should suffice and no further sites or pitches should be allocated within the Reg19 DPD when it is published for consultation and examination. 78. However, if MBC: 78.1. strengthens policies relevant to all candidate sites; and 78.2. adheres to the sustainability criteria documented by Lepus Consulting; and 78.3. maintains and, as necessary, uses a substantial budget to resist appeals and to carry-through any resultant need for enforcement, there is the probability that the number of windfalls would reduce. 79. Should that happen and the number of available pitches not meet the revised and reduced assessed needs, some of those 27 sites identified by Lepus Consulting for further analysis (after mitigation) or other candidate sites would presumably be progressed, but only after evidence that windfalls are coming forward at significantly below historic rates. 80. That approach would then dispel Maidstone’s “soft touch” reputation. The questions below are likely to be answered in depth by those Parishes with direct, real-life experience of the current situation. We ask that MBC gives full consideration to such knowledgeable submissions, as necessary using them to supplant desk-analysis, such as appraisal against sustainability criteria. At overarching level, we see no value in answering the questions below. They are designed to attract a blizzard of submissions by making the process of submission less time-consuming; in essence, it could just be treated as a tick-box exercise, with little additional comment. That “blizzard” can then be used to outnumber, dismiss or devalue more rigorous and detailed submissions if they are not favoured by MBC. The questions make no effort to seek input on the merits of the foundations of Reg18C; that is, the Opinion Research Services assessment of need.