Question 3: To what extent do you agree with the proposed policy for meeting accommodation needs? Please provide comments to support your answer.
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Water lane is not an appropriate location for pitches
Sites should not be in local villages. The Brishings is one of the potential sites and is vulnerable to floodings. It has has very poor access and is very near the Leeds Road. This is a very busy road and thus it would be dangerous to have a site situated so close.
As stated above, if needs are not provided for, the result will be uncontrolled use of land by the gypsy and traveller communities.
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I strongly disagree with the proposed policy as it lacks a balanced and sustainable approach. The policy prioritises meeting accommodation needs without adequately addressing the cumulative impact on local infrastructure, public services, and environmental quality. There is insufficient evidence that roads, schools, healthcare, and utilities can absorb the additional demand created by these allocations. Furthermore, the policy does not provide robust safeguards to prevent harm to rural landscapes, biodiversity, and residential amenity. The reliance on broad locations and non-allocated sites introduces uncertainty and risks inappropriate development in areas that are neither sustainable nor accessible. A sound policy should ensure infrastructure capacity, environmental protection, and transparent site selection criteria before committing to such significant growth.
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I object to the proposed policy for meeting accommodation needs where it relies on Site C4S-017 – The Brishings. While I recognise the Council want to provide accommodation for Gypsies and Travellers, this must be done in appropriate locations. In my view, The Brishings is not a suitable place to meet this need and should not form part of the policy. Firstly, the site is in open countryside and its use for permanent residential pitches would significantly change the character of the area. The introduction of caravans, hardstanding, lighting, fencing and day-to-day residential activity would be visually intrusive and out of keeping with the rural surroundings. This type of development would cause lasting harm to the countryside and does not sit comfortably with the Council’s aim to protect rural character. Secondly, The Brishings is not a sustainable location. It is poorly connected to local services, schools, healthcare and employment, and there is limited access to public transport. As a result, future residents would be heavily dependent on private vehicles for everyday needs. This conflicts with the plan’s stated objective of promoting sustainable development and reducing the need to travel. Thirdly, using The Brishings to meet accommodation needs appears to prioritise meeting targets rather than selecting the most appropriate sites. There is no clear justification for why this rural location is preferable to sites closer to existing settlements where services and infrastructure already exist. For these reasons, I object to the proposed policy insofar as it includes The Brishings as a means of meeting accommodation needs. The site is unsuited to this purpose and its inclusion undermines the overall credibility and sustainability of the plan.
Dear Alison, I am writing to formally raise my objections to the following sites currently under consideration by the Council as part of the Call for Sites exercise for Gypsy, Traveller and Travelling Showpeople accommodation. Policy C4S (008) – The Lodge I am concerned that the Council has not specified the number of pitches being proposed for this site. Regardless of scale, The Lodge is accessed via a very narrow country lane, which would be wholly unsuitable for development of this nature. In addition, there are strong local concerns that development would have a detrimental impact on the Kent Downs National Landscape. The site also contains several important oak trees that are protected by Tree Preservation Orders, which could be negatively affected by any development. Policy C4S (017) – The Brishings This site is extremely unpopular with local residents, to the extent that a petition has been organised in opposition. It is important that the Council gives due weight to the strength of local opinion when making planning decisions. Having recently purchased a house in [...] had I know about the proposal I would never have purchased the house. [...] The proposed development for the travellers site has purposefully been withheld from anyone purchasing in Lilk meadow which is dishonest, I know none of the residents in the new Lilk meadow development would have bought their house had they know about this proposal. Furthermore, as with The Lodge on Green Lane, access to this site is via a single-track country lane. This road would be entirely incapable of accommodating the level of traffic that a development of approximately 20 pitches would generate. I trust these concerns will be carefully considered as part of the ongoing assessment of sites. I look forward to your response
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In the south East we have the most sites Nationally
Accommodation needs in this area of Langley are not supported by local people and I do not believe that these needs are needed at all . The development of the area of Langley recently is overwhelming the over crowding the area to an extent that roads and infrastructure cannot cope . Why oh why are you not understanding that the area can no longer cope with anymore development .
Requirements are too high based on historical figures and should be reduced in line with with national averages not historcal norms.
I don't agree that there should be a growth measure included within this policy. It is just attracting others from outside of Maidstone tto move here.
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I strongly disagree to the proposal of the C4S(017) The Brishings location as a proposed site. This will have major impacts on the surrounding area which is already struggling with road usage (there would be no safe access road to the site), impact on utilities, lack of local public transport. The use of this location will impact the historical nature of the village, impact to nature from light pollution, increased flooding risks, wasted aquacultural use of the land, impact to the wildlife that live on the land (foxes, badgers, bats, owls and birds of pray to name a few).
The policy is acceptable but implementation is the problem. Defining what makes a site suitable is not covered and no guidance as to where comment can be made has been given.
Legal rights for gypsy, traveller and showpeople seem to be prioritised over the rest of the working population.
Whilst I am in general agreement with this policy, and acknowledge that family groups wish to stay together, I raise again my concerns of over-intensification of pitches in the southern rural part of the borough which could create tensions within the G&T community and reduce availability of work within traditional areas. Additionally, over-intensification of pitches in the south of the borough could create tensions with the settled community, and make community cohesion more difficult to achieve. The issue of the high concentrations of G&T communities in Maidstone Borough must be highlighted with Government for this reason, and over-intensification should be carefully considered when allocating pitches
The assessment of accommodation needs is a ‘point in time’ exercise. The consultation notes that some of the identified need has been met through the granting of planning permissions between 2023 and now. Since 2023 the Council has granted permission for 75 new GTTS pitches. This takes the net need for pitches for households in the first 5 years down from 251 to 176 pitches. No plots for travelling showpeople have been permitted over the first 5 years, so the need remains for 2 plots. The DPD needs to be clear at points 1 and 2 about the number of pitches and plots required in the first five years taking account of existing permissions. This also needs to be reflected in point 1 for the whole Plan period 2023 to 2040. TWBC notes that several proposed allocations are proposed without specifying the number of pitches, that could be accommodated. This is essential to establish the resultant supply and any residual unmet need – any Unmet need needs to be clearly stated. (Appendix 2 has a map of the location and lists the identified sites for provisional allocation to accommodate need. TWBC notes that none of the proposed allocations are close to the boundary between the two Boroughs).
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Southern Water is the wastewater service provider for the Maidstone district and supplies water to part of the district. As such we are responsible for a range of utilities assets, including strategic sites, that perform an essential function to the district. In addition to assets having ongoing access needs for maintenance to ensure continued operation, the essential function these assets perform will at times need to expand in capacity in order to support future growth. We therefore request additional wording in this policy, as allocating sites adjacent or near to existing assets could compromise Southern Water’s ability to continue to serve growth in the district. Requested wording: In consideration of parts (4) and (5) of this draft policy in particular, we request that the following wording is added to part (1) of policy TR2: The utility network should be protected and sites will not be allocated in cases that would compromise existing utilities infrastructure, or encroach on future expansion needed to support growth. The needs of new and improved utility infrastructure will be supported to meet the identified needs of the community subject to other policies in this plan. This is in line with the intention of paragraphs 60 (objective 4, page 19) and 126 of this draft DPD. Further explanation: Southern Water may have to provide additional wastewater infrastructure to serve new and existing customers and continue to meet stricter environmental standards. It is likely that there would be limited options to locate infrastructure as it needs to connect to existing networks. Planning policy should help to safeguard the infrastructure necessary to sustainable development. The NPPF (December, 2024) paragraph 7 states that: The purpose of the planning system is to contribute to the achievement of sustainable development, including the provision of homes, commercial development and supporting infrastructure in a sustainable manner. Paragraph 9 explains further that sustainable development objectives should be delivered through the preparation and implementation of plans. The National Planning Practice Guidance also makes clear that ‘Adequate water and wastewater infrastructure is needed to support sustainable development’. Also, it is important to note that existing public sewer infrastructure (that Southern Water is responsible for) can sometimes run beneath sites proposed for designation as local green spaces or as green gaps. It is reasonable to assume there will be examples like this within some of the sites proposed in this DPD. At times this infrastructure will require essential maintenance and/or reinforcement/replacement. The National Planning Policy Framework (NPPF) (December 2024) sets out the intention to protect the countryside and prevent settlement coalescence through its Green Belt policies, for which it establishes: • The intention in paragraph 153 of ruling out inappropriate development ‘except in very special circumstances’ that exist if the potential harm of a development proposal is clearly outweighed by other considerations. • In paragraph 154 that 'certain other forms of development are also not inappropriate' including 'engineering operations'. • Also in paragraph 108 of the NPPF that Local Green Space policies should be consistent with those for Green Belts. Southern Water considers that should the need arise, special circumstances exist in relation to the provision of essential wastewater infrastructure (e.g a new pumping station) required to serve new and existing customers. This is because there can be limited options available with regard to location, as the infrastructure would need to connect into existing networks. The draft National Planning Practice Guidance recognises this scenario and states that ‘it is important to recognise that water and wastewater infrastructure can have specific locational needs (and often consists of engineering works rather than new buildings). This means exceptionally otherwise protected areas may have to be considered, where this is consistent with their designation.’ It is also worth noting that wastewater treatment works (WTW) with environmental permits to manage controlled wastes fall within the legal definition of waste management sites. An important strategy of the Kent Minerals and Waste Local Plan (2025) is the safeguarding of such sites. Similarly, the protection of WTW assets and their ability to continue to meet future wastewater treatment and recycling needs is of primary importance to Southern Water.
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