Question 5: To what extent do you agree with the proposed policy for allocating sites? Please provide comments to support your answer.
No answer given
The Lodge Water Lane has an unspecified number of pitches, so we don’t know how many people will arrive or the impact on our community.
I would like to express a strong objection to the proposal for the site at C4S (008) The Lodge. The proposal for the site to be access via Water Lane is impractical, and will at times, be impossible. Water Lane has been identified on gov.uk (https://flood-map-for-planning.service.gov.uk/map?seg=sw,hr&cz=580687.3,155961.8,16.56) as being at a high risk of flooding, and you will see from the above map, that this risk applies to both sides of Water Lane, which will mean that access into or out of the site is not possible for tenants, including in the event of an emergency. The surrounding residential roads already experience issues with drainage and ground water, and increasing the number of occupants in this notorious flood zone, will only serve to exacerbate existing issues. In addition, Water Lane is a narrow, rural road, that is simply not appropriate for a volume of large vehicles, and it is certainly not suitable for pedestrians (I have witnessed firsthand the numerous times that the water has literally gushed down Water Lane into the village in heavy rainfall, and I have only lived here for a year!) It is not practical for public transport links, or amenities, and will result in a poor quality of life for the tenants, and presumably, be a total waste of money as an uninhabitable site. I wish to submit a comment in opposition to the proposed site in Bearsted / Thurnham. My main concern with the proposed development site is the location. This is a notorious site for flooding and surface water. I've attached two images, that both demonstrate that the site location is very likely to be completely inaccessible to vehicles due to surface water (Marked the highest rating for likelihood of flooding). This would put the tenants at great risk of not being able to leave or enter the site, as well as emergency services. Coupled with this, the area is rural, with few amenities around, and not suitable for pedestrians.
The Brishings has already been rejected several times for house building for various reason. Including inadequate access, flooding potential, proximity to the Leeds Road (very busy and dangerous), lack of local amenities such as schools, shops, public transport and doctors' surgeries. The Sutton Valence Medical Practice and the Orchard Practice in Langley are both full. In addition the influx of a large number of traveller families would overwhelm the local population.
The details of the site at Shenley Corner were submitted on behalf of my client in response to the Council’s previous Call for Sites back in February 2022. The decision of the Council to now propose it as an allocation is therefore welcomed. Indeed, I look forward on behalf of my client to working closely with the Council in order to deliver this site for its proposed use.
No answer given
I disagree with the proposed policy for allocating sites for Gypsy, Traveller and Travelling Showpeople accommodation. My concerns are based on material planning considerations: Infrastructure Capacity: No clear evidence that local roads, utilities, schools, and healthcare can accommodate additional demand. Risk of congestion and service strain. Environmental Impact: Policy lacks robust requirements for environmental impact assessments and mitigation measures to protect landscape character, biodiversity, and residential amenity. Transparency and Accountability: Criteria for site suitability are vague, creating uncertainty and risk of inappropriate development in sensitive rural and semi-urban areas. Community Safety and Cohesion: Policy does not address impacts on community safety or cohesion, which should be considered alongside infrastructure and service provision. Compliance and Enforcement: Weak safeguarding measures for permitted sites; no clear monitoring or penalties for non-compliance. Recommendation: The policy should include: Mandatory infrastructure and traffic impact assessments. Clear sustainability and accessibility criteria for site selection. Strong environmental protections and compliance monitoring. Transparent enforcement mechanisms.
There are concerns that this is just a way of land owners selling off land to Maidstone Council purely for their own financial gain.
C4S (008) and others have 'Not specified' beside them. NOTHING should be agreed to without this information. This proposed site is butting up to a conservation area, no mention of this has been documented or highlighted. Water Lane leads directly onto the junction of The Street and Roundwell - this is a dangerously narrow and busy road leading into a quiet village, not suitable for a cut through to the motorway.
I object to the proposed policy for allocating sites where it includes The Brishings (Site C4S-017). Allocating a site through this policy confirms it as an appropriate and acceptable location for development. In the case of The Brishings, the site does not meet this test and should not be allocated for Gypsy and Traveller accommodation. Firstly, The Brishings is an unsuitable countryside location. The site is located in a rural area where allocating land for permanent residential use would result in a clear and lasting change to the character of the countryside. The development associated with an allocated site – including caravans, hardstanding, access works, lighting, fencing and general domestic activity – would be visually intrusive and out of keeping with the surrounding landscape. Secondly, the site does not represent a sustainable allocation. The Brishings is poorly connected to services, facilities and public transport. Allocating this site would lead to high reliance on private vehicles for everyday activities, which conflicts with the plan’s stated aim to promote sustainable patterns of development. Thirdly, allocating The Brishings appears to be driven by the need to meet accommodation numbers rather than by sound site selection. There is no clear explanation of why this rural site is preferable to alternative locations closer to existing settlements where infrastructure, services and public transport are already available. Finally, allocation would make the impacts permanent. Once allocated, the principle of development is established and future decision-making becomes constrained. This would effectively lock in development in a location that is poorly suited to long-term residential use. For these reasons, I object to the proposed site allocation policy insofar as it includes The Brishings. Allocating this site would undermine the plan’s objectives for protecting the countryside and promoting sustainable development.
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
No answer given
Ensuring Appropriate Use of Designated Sites It is essential to implement a robust system to prevent the misuse of sites that have been granted planning permission under the Gypsy, Traveller and Showpeople regulations. Specifically, these sites should not be permitted to operate as rental properties for individuals who do not meet the criteria defined within this category. Current Concerns A growing concern is the increasing prevalence of gypsy ‘landlords’ who obtain planning permission for such sites primarily for financial gain, rather than to address a genuine and defined need. This trend undermines the intended purpose of the regulations and highlights the necessity for stricter oversight and enforcement measures.
I personally feel that the sites allocated have not been adequately looked at . In particular The Brishings C4S(017) due to dominance of site in area , suitably due to infrastructure , sustainability of site due to lack of local services and resources. . Ministry of Housing, Communities & Local Government dated December 2024 under Policy C clearly states that, “when assessing the suitability of sites in rural or semi-rural settings, local. planning authorities should ensure that the scale of such sites does not dominate the nearest settled community.
Very poor policy and no consideration for local people and infrastructure. The Brishings C4S(017) is completely unacceptable and will dominate the local community.the process needs to end now and this site needs to be removed . In the past planning for this field has been denied due to many negative reasons and needs to be denied immediately.
Strongly disagree with allocating sites. Especially in Bearsted water lane. We live near this area and worry for the safety of residents and the impact on our house prices- Also the area is not suitable for large vehicles - this is a danger.
C4S017 The Brishings. The allocation seems to have been made to meet accommodation numbers rather than sound site selection. Transport, health services, schools, shops, road access, environmental pollution. None of these have been considered regarding this site.
No answer given
1.New sites should only be allocated to areas away from existing settled communities. 2. Wherever possible, additional plots should be added to existing traveler sites. 3. No new site should not adversely impact on the local character, environment and amenity of the area. ( Objectives of the Policy Plan Objective 3) 4, The preference of both travelling Communities and settled Communities to have sites located close to but not within existing settlement. ( Spacial Strategy - The Countryside P 80) Site C4S(017) The Brishings. This site is a greenfield site within Langley Village envelope and has been used for agricultural purposes for many years. As stated in the NPPF, greenfield land should only be developed in exceptional circumstances . This is not an exceptional circumstance. Other, far more suitable sites, away from the existing settled community are available and would be far more suitable for this type of development. This greenfield site contributes significantly to the local rural character and the proposed development would significantly detract from the cultural and visual appeal of the area. It would also result in significant harm to the landscape and rural character of the area in contradiction to Policy DM15 of the MBC Local Plan. This site is bounded on three sides by residential properties and access to this site is via a single track country road with no pavements or lighting thus totally unsuitable for development. Policy DM15 states that planning permission should only be granted if the site can be safely accessed to and from the highway by vehicles using the site on a regular basis. This would not be the case because one end of the lane exists onto the very busy B2163 (Leeds Road) and the other end onto the very narrow Heath Road, within a built up area of many houses. The well-being of the existing residents whose properties bound The Bishings would be severely impacted if this proposed land use was allowed. Disregarding the preferences of the existing Community would create tensions and inevitably undermine the cohesion as it is viewed as a significant green space and agricultural resource. If the site was allowed to be allocated for use by the Travelling Community it would inevitably case a fall in the value of the houses bounding the site. This includes two Grade ll listed properties. This site has been refused numerous Planning Applications over the past 20 years and I believe that there is no reason to change that decision in this case. In conclusion, The Bishings ia a valuable agricultural, rural, environmental and ecological asset to the community of Langley and therefore it is imperative that this land continues to contribute to the local landscape in its present form.
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).
Para 109 states a preference for sites to be located close to facilities such as schools and health services. The Brishings site (C4S (017)) as proposed does not meet these requirements. The surgery is at full capacity, assess to the site is restricted by narrow roads, access to local schools is impossible unless personal transport is used i.e Car. Previous applications for Planning permission have all resulted in rejection on the grounds that the site is "Unsustainable". As such it is unsustainable now and should be removed from the site list.
Langley site of 20 pitches is entirely unsuitable. This site is not safe and accessible (breaching 96b) It is sandwiched between a quiet lane and the busy Leeds Road B2163. There would be no high quality public space (contravening 96c) and the land is a piece of agricultural land that should be safeguarded. This has, I believe, been left dormant creating a ‘brownfield appearance’ as the landowner has repeatedly applied for planning permission. All of which has been rejected. The Bishings is a large site in a semi rural location. This would dominate the settled community (breaking Policy C Planning Policy for Traveller Sites). The site has potential to ghettoise and enclave a community because of its position within Langley Heath, which would contradict Policy H 26d form Planning Policy for Traveller Sites. The village has limited community facilities (breach of 97a). There are no local shops within the village. Another area developed would NOT enhance the sustainability of communities nor the established residential environments. There is no school within Langley itself and many of the local schools do not have sufficient spaces to admit pupils, especially siblings. Because of the poor local transport links, this would increase the traffic further. The roads are gridlocked now; already the Leeds Road, Sutton Road and Willington Street struggle to cope with the increased developments that have already been established. The site would contravene 97b as this would absolutely not improve the health, social or cultural well being for either the established residents or Gypsy, Traveller or Travelling Showpeople. This proposed site will place further undue pressure on the medical facilities, already at crisis point for both Langley and Sutton Valence surgeries as there would be limited or no access to appropriate health services. The site is also within a flood risk area. In Policy C (g) it is stated ‘do not locate sites in areas at high risk of flooding, given the particular vulnerability of caravans’. This would also affect the welfare of animals in regards to exercise space and access to dry pasture. By developing a piece of agricultural land that will to a certain extent naturally drain, the potential for increased flooding and damage to established buildings and grade 2 listed properties within Green Lane and Langley Heath is huge.
My lack of knowledge of the local characteristics of the majority of these potential sites means I will only comment on the one site I have knowledge of, which I will do in the next section.
We are a non sustainable village according to the council in recent planning refusals.
TWBC supports the approach of there being a site allocation policy for each site, against which proposals will be assessed alongside relevant Development Management policies. We note that some sites have been allocated without an indication of the number of pitches that can be accommodated there. The number of pitches per site should be maximised and clearly stated so expectations are set for all interested parties and so that the unmet need through proposed allocations can be clearly identified. We agree with the approach to achieving high quality accommodation which is sustainable and minimises the impact of new pitches on the environment and local infrastructure. Site specific policies may benefit for including a site wide management plan for the new and/or additional pitches. Policies should state that essential infrastructure such as water or electricity provision should be sufficient to meet capacity. The sites carried forward from the Local Plan Review would provide a total of 22 pitches. The sites put forward as part of the call for sites total 175 pitches with five sites submitted with an unspecified number of pitches. This could therefore provide enough pitches to meet the 5-year net need for 176 pitches but this is not stated. I understand that further analysis of sites is required however a paragragh stating 'potential' to meet needs may be appropriate? Unmet need and how it is met needs to be stated clearly for years 6 – 10 and 11 – 15.
No answer given
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 locating permanent sites adjacent or near to existing assets could compromise Southern Water’s ability to continue to serve growth in the district. Requested wording: We request that the following wording is added to policies TR4 (and TR7): The utility network should be protected and permission for site proposals that would compromise existing utilities infrastructure, or encroach on future connections for utilities, will be refused. 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: We make these requests having noted the number of potential site allocations proposed within the DPD, and the policies proposed to allow for the future granting of planning permission for non-allocated sites. 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 strategic infrastructure necessary to sustainable development and support proposals to deliver additional infrastructure. 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.
My clients object strongly to proposed allocation C4S [019] The Meadow as follows: Gasson Planning & Projects [...] Consultation on Gypsies, Travellers and Travelling Show people Development Plan Document January 2026 Objection to Proposed site allocation C4S [019] The Meadow Introduction I write on behalf of my clients, Mr and Mrs James Theobald who live at [...] Their property is virtually adjacent to the substantial proposed site allocation reference C4S [019] The Meadow. My clients fully appreciate the need for this Development Plan Document and the obligation that rests on the Borough Council to accommodate the needs of Gypsies, Travellers and Travelling Show people. They do however believe that this specific allocation is inappropriate and indeed fails to follow the Borough Council’s own guidance. Hence they object strongly to this particular aspect of the DPD both in terms of its location and the scale of the site in relation to the surrounding community. Location The site in question lies outside of the built up confines of any settlement that appears in the Borough Council’s Settlement Hierarchy. Hence the site must be considered as lying in open countryside with the approved development plan policies applying appropriately. The area around Chartway Street is characterised by a not insubstantial number of existing dwellings sporadically clustered together. None the less the site is outside any settlement recognised in the Development Plan. Indeed the nearest facilities are to be found in Kingswood, where there is a convenience store and a primary school, or Sutton Valence where there is a Doctors’ Surgery albeit one that at present is not taking new patients. Both Kingswood and Sutton Valance are ten minutes away from the proposed allocated site by motor vehicle and, thus, significantly longer away by foot or cycle. There is no public transport. It is also important to note that whilst the site itself is not in an identified area of countryside protection it is close to, and within the setting of, an area of Local Landscape Importance being on the edge of the scarp slope. In addition I should draw to your attention that the site is crossed by a National Gas Pipe Line. Policy considerations Whilst it is appreciated that this draft DPD specifically relates to Gypsies, Travellers and Travelling Show people with policies drafted appropriately it is still important to consider this proposal in light of broader National and Local adopted planning guidance. The National Planning Policy Framework is the Government’s published position on planning matters. The latest update was issued in December 2024. Of particular significance to this proposal is the guidance in paragraphs 83 and 84 which, in dealing with development in rural areas, seeks to concentrate the limited development opportunities that there are to allowing existing settlements to grow modestly. Outside existing settlements [in open countryside] very specific exceptions are set out which do not include caravan sites. Hence the normal policy presumption on the proposed site is that development would normally be refused. It is also relevant to this case to note paragraph 135 which deals with the considerations that Local Planning Authorities should give to the impact of new proposals not least on existing residents. Especially the guidance states that new proposals should be “sympathetic to local character and history including the surrounding built environment and landscape setting..”. In addition sub paragraph f says that new development should “create places that are safe, inclusive and accessible and which promote health and well being with a high standard of amenity for existing and future users..” The broad national guidance is carried through into the Maidstone Local Plan Review not least in policy LPRSS1 which, as a strategic imperative states that protection is to be given to the rural character of the Borough and that development will generally be confined to the settlements identified in the plan [which, as previously stated, the proposed site lies outside]. Of particular relevance to the proposal in question is policy LPRHOU8, which deals with Gypsy, Traveller and Travelling Show people Accommodation. This states that permission would be granted for such uses if, inter alia, the following criteria are met: b] local services, in particular school, health and shopping facilities are accessible from the site preferably on foot, by cycle or by public transport c] the development would not result in significant harm to the landscape and rural character of the area. I suggest that the proposed site fails to meet either of the above criteria. In terms of consistency it is important to note previous decisions made by the Borough Council on proposals for gypsy sites in the countryside. Just one example is 2024/0962 which proposed five caravans on land south of Pluckley Station and which was refused as “an intrusive and incongruous form of development that would cause demonstrable harm to the character and appearance of the rural locality”. It is worth noting that this site is in a far less conspicuous location than this proposed site at Chartway Street. Gypsy, Traveller and Travelling Show people DPD I turn now to the draft Development Plan Document which is the subject of the current consultation. As previously stated my clients understand the need for this DPD and broadly accept its thrust. Policy TR1 sets out the spatial strategy to be applied to allocated sites and new proposals. This again relies greatly on the settlement hierarchy but with regards to sites in the countryside states that sites will be provided in accord with the following criteria: 1. Through appropriate intensification, reorganisation or expansion of existing authorised sites 2. Through the redevelopment of previously developed land 3. As a rural exception site. With regard to the last point policy TR6 requires such a proposal to [amongst other points]: 1. be justified by a local accommodation needs survey, 2. be of a scale which is in proportion to and does not dominate the nearest settlement community 3. be suitably located in terms of access to local facilities by foot, cycle or public transport I suggest that this particular site fails to satisfy any of the above criteria and therefore its allocation would be in fundamental conflict with the policies in the DPD which guide site allocation and permissions. Proposed Allocation C4S [019] The Meadow is included in the Draft Plan as a result of a Call for Sites submission rather than having been identified by the Borough Council through its own survey and investigative work. No site capacity is suggested but it is of substantial size. In relation to the scattered dwellings in the vicinity it will be overwhelming and significantly out of scale with its surroundings.. Chartway Street is currently a well integrated community, and imposing a significant new community on to the area will fail to meet the NPPF guidance of ensuring that new proposals will provide a high standard of amenity – in its full sense, and wellbeing - for existing and proposed residents. Integration of many new residents on the proposed site with existing residents just will not happen. The resulting situation will be to the detriment of all now and in the future. To include a specific proposed allocation of this nature in the DPD will risk undermining the confidence that one may have in an otherwise sound and well meaning document. Conclusion Generally the draft DPD provides a reasoned and soundly based approach to accommodating the needs of Gypsies, Travellers and Travelling Show people in Maidstone. However as is clearly demonstrated above, the proposed specific allocation of The Meadows site is clearly not in accord with National guidance, the Council’s own Development Plan Review and indeed the strategic policies in the DPD itself. Should this proposal remain in the DPD it will be to the detriment of local residents, the character of the countryside, potential occupants and the integrity of the overall DPD document. I therefore ask that site C4S [019], The Meadows, be removed from the DPD before it progresses to the next stage. Trevor Gasson January 2026
No answer given
My comments are in regard to the following proposal; C4S (017) The Brishings (20). This site is in the middle of Langley village with extremely limited access. Primary access is via a two-way, single lane track (Green Lane) with minimal opportunities for cars to pass each other when travelling in opposite directions. The lane is not suitable for large vehicles. There are no retail outlets or direct employment opportunities in the village so the regular use of vehicles would be essential for the users of the 20 proposed pitches. The occupants of the proposed pitches would, necessarily, significantly increase the traffic flow and congestion in, and around, the village. A part of the site is known to be liable to flooding. This site has had planning applications for traditional housing on previous (recent occasions) which have been rejected. For these reasons I believe the policy for allocating sites is fundamentally flawed as this site should not be included for consideration.