Question 3: To what extent do you agree with the proposed policy for meeting accommodation needs? Please provide comments to support your answer.
No answer given
We do not agree with the proposed policy for meeting accommodation needs. Many of the allocated sites listed are above the DCLG Good Practice Guide recommended limit of 15 pitches and are all located in rural locations, which the Council itself recognise as being the least sustainable location for such development. As this is a Borough-wide approach it is important to consider the allocation of sites (of which the Council has most control) in a spread across the Borough, in the same way that bricks and mortar development is assessed. This takes in account site designations, access to services and facilities, limiting pressure on local medical and educational services (noting most GRT development is not CIL liable) and also ensuring that sites individually or cumulatively do not dominate the nearest settled community. PPTS 10d states that allocated sites should “relate the number of pitches or plots to the circumstances of the specific size and location of the site and the surrounding population’s size and density”. It is also too simplistic to say that all existing sites and adjoining land in the same ownership should be considered suitable as ‘broad locations for growth’. PPTS 10b requires specific, developable sites to be reviewed and identified. Intensification without very stringent criteria would simply give the green light to overcrowded sites, with poor amenities, outdated and undercapacity sewage and drainage provision, no parking and a lack of adequate circulation space, as their owners look to maximise occupiable space and potential rental income. This would, in turn, give the occupants of such sites very poor living standards, which have been shown to have significant negative impacts on both physical and mental health. This does not align with the Council's objective of putting people first, or the NPPF objectives, seeking for planning to create clean, liveable, healthy places. Furthermore, blanket support for intensification of existing sites will encourage unauthorised development via ‘doubling up’ in advance of retrospective applications for consent, whilst fettering the Council's ability to oppose such development where it does not align with policies TR7 & TR8. Strict clarity on the criteria for any intensification or expansion proposals is therefore critical. As indicated above, a 320m2 minimum pitch size and a maximum 15 pitch site size is requested.
Kent, and Maidstone in particular, already provide more than their proportional percentage of accommodation, as documented above. Maidstone residents, all those with or without protected characteristics, often have to compromise where they live and their proximity to family for many different reasons. Disproportionate weight should not be given to this issue within this strategic plan.
It seems against the vision to just extend existing sites as this will lead to an imbalance between the settled and travelling community which will not aid social cohesion. Also many of these rural sites such as those in Ulcombe do not have the appropriate infrastructure and availability of services to cater for large increases in population.
This approach may be suitable in some areas/in relation to some sites. However in certain areas such Pye Corner the number of sites already exceeds an appropriate balance between thenumber of pitches and thenumber of settled residences, and this approach would likely lead to substantial further sites in the area. Traveller sites are dominating the landscape in the area, for example on the Lenham Road between Headcorn and Eastwood Road
You must, as the authority, as mentioned in my previous answer, have balance and thought for the needs of the wider community. Their needs matter too. New pitches must not be allowed to become overbearing within the local community. You run the risk of creating 'ghetto-like' areas where non Gypsy/Travellers fear to go. There have been examples of this type of behaviour in Headcorn and you see it with the trotting carts and the behaviours of a significant number of the 'riders' who display scant regard for the safety of other road users and are frequently abusive. That is especially evidenced in the behaviour of Gyspy/Traveller children/young people. The 'windfall' allocation appears to be disproportionately favourable to Gypsy/Traveller applications.
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.
It is not clear from the policy TR2: Approach to Meeting Accommodation Needs what number of pitches broad locations are expected to deliver. However, for promoters to incorporate G&T provision within broad locations the DPD needs to provide surety on the number of pitches required. This should be proportionate to the scale of the development and overall unmet need and take into account development timeframes of the overall schemes.
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. 2 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.
No answer given
Strongly disagree. For the reasons set out in KALCs, Headcorn and Ulcombe Parish Councils’ responses to Consultation 18b – the proposed G&T accommodation need figures are too high and the calculations are inaccurate. I, and most of the settled community, strongly oppose MBC’s proposed approach to the intensification, expansion, and reorganisation of existing G&T sites. Expanding existing huge sites is against national policy – it amounts to domination – and serves to increase tensions between the settled and G&T communities. It does not facilitate tensions between the G&T and settled communities to ease. Intensification does not allow G&T the opportunity to have the socio-economic opportunities to increase and improve their educational achievements, employment, and social mobility. Instead, MBC is creating huge G&T ghettos – condemning G&Ts to limited socio-economic and mobility. This is to the detriment of G&T in the long-term. The existing huge sites, like the Meadows on Lenham Road in Headcorn, is sprawling, over-crowded, not a pleasant place to live and one that we should not be encouraging in 2026. Having recently walked the full length and breadth of the site, the current accommodation arrangements do not comply with MBC site plans. It is a dense, over-crowded, noisy site without a blade of grass in sight – it is not a place for the young, old, sick, or vulnerable. It is not a site we should be seeking to expand in 2026 and beyond
Q3 – Policy TR2 (Meeting Accommodation Needs) Position • Support review of numbers. Reason / policy justification • PPTS requires robust, realistic assessment (para 9); current methodology may overstate need by counting births but not deaths. • NPPF para 31 emphasizes sound evidence for plan-making. • Figures in the supporting evidence are false. Additional Comment • Over-reliance on expanding existing sites increases isolation, ethnic homogeneity, and separation from settled communities. • Smaller, integrated sites promote community cohesion and avoid reinforcing marginalisation or prejudice.
Strongly disagree. For the reasons set out in its response to Maidstone’s Regulation 18b consultation, Headcorn Parish Council considers that the estimated need is too high. Headcorn Parish Council also strongly opposes Maidstone’s proposed approach to the intensification, expansion and reorganisation of gypsy and traveller sites. It considers that the proposed carte blanche approach to intensification, expansion and reorganisation of sites is neither justified nor consistent with sustainable development. In particular, Headcorn Parish Council considers that it is likely to encourage (not discourage) unauthorised development, with all the detriments that brings, and will result in overcrowded sites with poor amenities that erode the living standards of existing residents. It is also likely to undermine integration between the settled and gypsy and traveller communities, as large sites are typically more closed off. 4 Headcorn Parish Council notes that the proposed approach, far from identifying “broad locations” for development, would effectively permit development anywhere within the Borough. Furthermore, under the policy, any future unauthorised development that takes place and is given retrospective planning permission will then be allowed to expand, creating perverse incentives. In addition, to avoid creating both social and environmental harms, it is important to avoid overdevelopment. This is particularly true as many sites with existing permission were only given permission retrospectively, often not because they were acceptable in planning terms, but because no alternative sites to accommodate occupants were available. Expansion on these sites would exacerbate existing harms and would be contrary to the principles of sustainable development. Headcorn Parish Council notes that the proposed approach is also flawed, as the dDPD suggests only 45% of existing sites are likely to be suitable for intensification or expansion, but does not make clear that permission will only be given where the site is suitable. There is a strong presumption that any existing site can opt for expansion, given it is classified under this policy as a “broad location for growth”. This policy will also add to the concentration of gypsy and travellers in individual parishes with existing high concentrations. This will exacerbate tensions. In addition, given the complex needs of many in the gypsy and traveller communities, Headcorn Parish Council considers that the resulting development pattern would only be sustainable, if it were supported by significant investment in infrastructure and a commitment to increase funding upfront for education, health, police and social services. This commitment is lacking from this dDPD. Headcorn Parish Council considers that in order for the dDPD to be judged as positively prepared, justified and enabling sustainable development, the proposed approach should be changed so that MBC instead looks to allocate sufficient sites, while allowing small windfall developments that otherwise meet Development Plan policies (ie to meet the requirements of both the MBC LP and relevant Neighbourhood Plans). Such windfall developments could be on either existing or greenfield sites, but the key would be that they would otherwise meet the requirements of the Development Plan, in other words that they were acceptable in planning terms, not simply that they were on existing sites.
As mentioned in Q2 above, UPC disagrees that 82% of new accommodation “needs” can be accommodated by expanding existing sites in areas like Ulcombe, which are unsustainable according to MBC's own designation, and because the current G & T population is probably closer to 30% of our village population, which is vastly greater than any other village in Kent or even in the country. Making existing sites larger just increases the self-sufficiency of G&Ts on such sites and worsens the chance of integration. Family sites are an unworkable concept when the families get larger in number and travellers, like the settled community, should therefore adjust to the real world and accept that living within a few miles is an acceptable option. The alternative is that ever increasing large families could always move to another area in Kent, or to elsewhere in the country, where space is more readily available, and land is cheaper. If MBC thinks it cannot allocate sufficient suitable, available and deliverable land for the disputed “need” for 529 pitches, then it has to be much more robust in questioning the claimed “need” and defend the borough, and its countryside, by declaring we cannot accommodate this level of new pitches.
I am writing in response to the above consultation. Firstly, thank you for agreeing to allow an extension of time for Ashford Borough Council (ABC) to comment. The Council has previously commented in detail on the overall scope of MBC’s emerging GT&TS Plan (see response to Regulation 18b consultation). In this instance ABC wishes to comment specifically on need more generally. ABC understands the significant challenges faced by Maidstone Borough Council (MBC) and continues to support the efforts being made to seek to accommodate as much of its GT&TS accommodation needs within their own administrative area. As MBC will be aware ABC also recently consulted on a Regulation 18 draft of a new Local Plan for Ashford covering the period up to 2042. The Regulation 18 version of the emerging Local Plan highlights the Council’s own challenging need for GT&TS accommodation (111 pitches and 4 plots). A call for sites was undertaken between September and November 2023 and August and October 2025, however only 4 sites have been put forward for consideration. Based on our emerging work and taking into account strategic environmental constraints (including the restrictions imposed on new residential development within the river Stour catchment due to the condition of the designated Stodmarsh lakes), it is clear accommodating our own identified GT&TS need will be extremely challenging. Having reviewed the Regulation 18c draft of MBC’s emerging GT&TS Plan I note that MBC are still exploring options with regard to the overall strategy. I also note that the emerging Plan does not identify any proposed site allocations at this stage. As such, there remains a lack of clarity within the Plan regarding the extent of any potential future shortfall. Therefore, at this stage ABC cannot see what planning judgements MBC is making regarding the suitability of potential sites being considered for allocation, intensification, and/or expansion. Consequently, and ahead of any formal request from MBC, whilst ABC understand that MBC have significant challenges, the Council wishes to clarify that it is not in a position to assist in meeting your GT&TS accommodation need and currently cannot envisage a scenario where this position will change. Irrespective, ABC remain committed to cooperating with MBC to discuss any strategic cross boundary issues under the duty to cooperate. If you have any questions regarding the content of this letter please contact