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
POLICY LPR (023) – LAND REAR OF CHART VIEW – SITE B was refused expansion for 5 additional pitches by the Council’s Development Control in Application 23/505684/FULL, for reasons which remain wholly valid and up to date for both this site and the adjacent site POLICY C4S (021) – CHART VIEW (rear of 1 CHART VIEW). Please refer to the attached delegate report, which sets out why these sites are inappropriate for further expansion and should not be allocated. Of particular note: 1) “The proposal would intensify the concentration of mobile homes and associated domestic paraphilia in this part of the countryside which would impose significant harm to the character and visual amenity of the area. Moreover, the scheme having regard to the lack of suitable, adequate, or practical outdoor amenity provision, levels of privacy, would diminish the standard of living conditions enjoyed by future occupiers of the mobile homes”. 2) “In this instance, it is not considered the granting of a temporary permission is appropriate given the circumstances of the site and the fact the proposal would have a significant adverse effect on the character of the valued landscape” 3) The proposal was also rejected on amenity and parking reasons, which would be material for any allocation. The Council Policy team has not presented any assessment to indicate that the proposed allocations overcome the material concerns of the Planning Officers or the Appeal Inspector and that the sites can actually be considered suitable or delivered in a policy-compliant manner. 4) The proposals will add to the imbalance between the settled community (currently seven dwellings at Rabbits Cross) and the Gypsy and Traveller community, contrary to the PPTS and the proposed new DPD policies. As highlighted by the planning inspector in Appeal APP/U2235/C/24/334802, which related to the adjacent site of Hawthorn Lodge. Extract below. 5) Application 25/503131/FULL POLICY LPR (022) – LAND REAR granted approval for 3 additional pitches and not the proposed 2 pitches, noting that community domination and landscape harm had arisen in the planning balance. Further pitch allocation in this location would intensify such impacts. 6) Specifically, it is extremely unclear how the site rear of 1 Chart View could possibly accommodate a further 20 pitches, noting the policy criteria and National requirements in PPTS, given that Site B, which is approximately half its size, was refused permission for 5 pitches on the grounds that it was insufficient in size, and could not provide adequate parking or amenity space. 7) An existing Public Right of Way (PRoW) KH562 is also a significant constraint. This runs directly through both sites proposed for allocation. It would not be appropriate for a PRoW to run directly through 2 private residential sites. No reference is made to the PRoW within the site-specific policy, and it would not be appropriate for the PRoW to be extinguished in order to accommodate these sites. The further allocation of the 2 sites at Chart View goes against Development Control assessments and earlier refusals where conflict with the Development Plan has been clearly identified, specifically surrounding landscape and domination of the nearest settled community. Allocation of sites at Chart View is therefore inappropriate and cannot meet the policy requirements as set out in the DPD. These sites should be removed from the allocation list. POLICY CS4(029) PEACOCK FARM Plot 6 at Peacock Farm was granted permission on 27 November 2025 for 3 additional static units, a facilities block, 3 no associated touring caravans, the provision of 6 no parking spaces and hard and soft landscaping for gypsy and traveller use. This allows for a total of 10 caravans: 5 mobiles and 5 tourers on this site. The plans also include 2 x day rooms, although there is no mention of these in the permission. Given that this site takes up the majority of the site shown in Policy C4S (029), it is hard to envisage how it would be possible to fit an additional 10 units into the remaining space, especially if the site layout and design criteria in TR07 and TR08 are followed, inclusive of a minimum pitch size and overall site size. Significant concern is expressed that the allocation would not meet minimum amenity, play space or parking requirements. Allocations must meet policy-compliant criteria. At Peacock Farm on another site adjacent to the one above, application 25/504652/FULL is outstanding for 5 mobile homes, 5 touring caravans and 4 dayrooms. Other sites with Peacock Farm have the following number of approved pitches: Plot 4 Peacock Farm 4 mobile homes and 2 dayrooms. Plot 3 Peacock Farm 1 mobile home, 1 touring caravan and 1 utility block Plot 2 Peacock Farm 1 mobile home Plot 1 Peacock Farm 2 mobile Homes and 1 utility block There are, therefore 13 approved pitches already at Peacock Farm and 5 pending approval. We contend, therefore that this location should not be allocated any further pitches as the traveller community already far exceeds the surrounding population's size and density.
This section does not give enough info to comment, really. No concrete information, just a lot of speculation and possibilities. It is interesting that even within this document, there is evidence presented of enforcement action being undertaken on 2 sites, due to activity on established sites within the borough.
There is not enough information to comment fully on this, plus with the 'Call for Sites' still open it is impossible to gauge the impact on each area.
As commented previously, extended existing and creating new sites within the rural community is not sustainable or practical. There is a lack of facilities, services and infrastructure in these areas and increases in the travel population leads to an imbalance between settled and travelling communities which negatively impacts all.
I can't comment on the majority of these proposed sites, however, I can comment on: The Meadows (Pitt Road), Leeds and Langley, Headcorn and Sutton Valence. These areas are already at saturation point with the Gypsy/Traveller sites, permitted and non-permitted. They are causing behavioural and cultural problems for the wider community and creating 'ghetto-like' areas which are intimidating and at odds with the county.
My problem is that you have not used the proposed policy for allocating sites. C4S 017 the Brishings. It is an unsuitabel site that has been subject to previous unsuccessful planning applications an appeal.
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.
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.
Most of the northern half of Maidstone Borough is underlain by principal and secondary aquifers that provide drinking water and base flow to rivers. Groundwater in these locations is at risk of pollution from potentially contaminative land uses if such activities are not managed appropriately. When identifying locations for gypsies and travellers, regard must be had for the sensitivity of the underlying groundwater and whether any proposed activities by site occupants presents a risk of pollution, for example vehicle maintenance. Sites should have available connections to the mains sewer network or amenity blocks, as discharges to sewage effluent to the environment pose a risk of contamination, and in most cases must be controlled under an environmental permit. For further guidance please visit Check if you need an environmental permit - GOV.UK or contact our National Customer Contact Centre on 03702 422 549. The applicant should not assume that a permit will automatically be forthcoming once planning permission has been granted, and we advise them to consult with us at the earliest opportunity.
Policy TR4 - Accommodation on Allocated Sites: Highways and Transportation It is noted that Policy TR4 identifies potential site allocations that will be the subject of further assessment and refinement prior to the Regulation 19 consultation. Pages 21/22 of the Strategic Land Availability Assessment (SLAA) confirm that this process will include site specific engagement with the County Council, as Local Highway Authority, on matters relating to site access, sustainability and cumulative impacts on the highway network. The County Council welcomes this future opportunity to provide input to inform the site allocations to be included in the Regulation 19 consultation.
1. Introduction 1.1. These representations are submitted on behalf of a group of local residents who live at the hamlet of Rabbits Cross to the east and west of Chart Hill Road, to the south of Chart Sutton and north of Staplehurst. They are submitted in response to Maidstone Council’s consultation in respect of the draft Gypsy, Traveller and Travelling Showpeople Development Plan Document (“the DPD”). 1.2. For context, on behalf of our clients we have previously objected to various applications and appeals concerning gypsy and traveller development within the local area. Most recently, this concerned appeal reference APP/U2235/C/24/3340802 which was allowed on the 29th November 2024, and planning application 25/503131/FULL which was granted planning permission on 3rd October 2025. 1.3. The focus of these representations will be draft Policy TR4 which, in part, proposes to allocate gypsy and traveller sites around Rabbits Cross at Site References C4S(021), LPR(022) and LPR(023). Policy TR4 also proposes to allocated the nearby site of Peacock Farm C4S(029) for development. 1.4. As will become apparent, our clients strongly object to these allocations and as such Policy T4 will be the main focus along with the relevant site-specific policy for the land, however other policies will also be referenced where relevant. 2. Policy TR4 2.1. As set out above, my clients’ primary concern with the DPD relates to Policy TR4. This is a Strategic Policy that proposes to allocate specific numbers of pitches on specific sites. Of specific concern to my clients are the following proposed allocations: • Chart View (rear of 1 Chart View) – 20 pitches – Site Reference C4S (021) • Land Rear of Chart View (Site A) – 2 pitches – Site Reference LPR (022) • Land Rear of Chart View (Site B) – 2 pitches – Site Reference LPR (023) • Peacock Farm – 15 pitches – Site Reference C4S (029) 2.2. In respect of site LPR (022), a footnote to the policy notes that the site is subject to planning application 25/503131/FULL which at the time of writing was awaiting a decision. It is noted that planning permission has now been granted for three pitches, one more than envisaged by Policy TR4. As planning permission has been granted we therefore do not object to this specific site, however we consider that this planning permission has implications for the other allocations as we will set out below. 2.3. The primary concern my clients have with Policy TR4 is the significant number of pitches that would result in the Rabbits Cross area as a result. The 3 pitches granted under planning permission 25/503131/FULL act as an infill site between two established gypsy and traveller pitches that border the site to the east and west. Further pitches exist further north on land on the eastern side of Chart Hill Road. The current number of pitches at Rabbits Cross, including those subject to planning permission, can be summarised as follows: • Chart View 1 – 7 pitches • Chart View 2 – 4 pitches • Old Oak Paddocks – 3 pitches • Hawthorn Lodge – 4 pitches (including those granted planning permission under 25/503131/FULL) 2.4. The area therefore already accommodates 18 gypsy and traveller pitches, including those subject to planning permissions that are expected to be implemented. Not including Site LPR (022), which has been granted planning permission and is therefore accounted for in the existing figure, the DPD proposes to allocate a further 22 pitches at Rabbits Cross. Including the site now with planning permission, the DPD will therefore result in a further 25 pitches at the hamlet. This does not include the 15 pitches proposed at Peacock Farm which are also within the locality (approximately 1km north of Rabbits Cross). | January 2026 | MR | P19-2242PL | 3 2.5. This will drastically and permanently alter the character and appearance of the area from one of agricultural fields with sporadic residential development to one characterised by gypsy and traveller sites which typically involve a number of buildings per pitch and substantial area of hardstanding. The below extract from the proposed policies map highlights this – there are four ‘bricks and mortar’ residential sites shown along with the existing gypsy and traveller sites (the site allowed by appeal A PP/U2235/C/24/3340802 is not shown), but with the additional pitches shown on the red hatching, the rural character of the area would be permanently altered to one dominated by gypsy and traveller pitches. See attached 2.6. The cumulative impact of the proposed pitches in addition to the established pitches would be drastic and would lead to a feeling of the established settled community being surrounded by gypsy and traveller development. Whilst all development – including that allowed under application 25/503131/FULL – has previously focused on the road frontages, the 22 pitches proposed at C4S (021) and LPR (023) would in effect be backland development that would surround the established settled community. 2.7. This would fundamentally and irreversibly alter the character and appearance of this quiet rural area, significantly increasing the number of residential plots in the area to the detriment of the rural character and appearance of the area and the quality of life of the existing settled community. 2.8. It is noted that in allowing appeal APP/U2235/C/24/3340802 at Rabbits Cross, the Inspector at Paragraph 25 agreed that there was harm to the area as a result of the visual impact of the one additional pitch proposed, including views from the lane and the adjacent Public Right of Way. Although he did not consider this harm to be ‘significant’, nonetheless harm was weighed in the planning balance as the development was not considered to conserve and enhance the Low Weald, within which the site lies, nor could it be said that the development took account of the Council’s Landscape Character SPD because the development harms the Beult Valley Landscape Character Area in which it sits. Consequently, the development was found to be contrary to policy in respect of its landscape and rural character impact. 2.9. It is relevant that these comments were made in the context of one additional pitch being proposed on the frontage with gaps remaining to the existing development and were also made before the three additional pitches were allowed under application 25/503131/FULL. The proposal to allocate a further 22 pitches in the area would lead to a substantial intensification of development in this rural area in comparison to previous proposals and effectively erode any gaps and set offs that exist at present. 2.10. The impact on the existing Public Right of Way (PRoW) is also a significant constraint. As highlighted by the below aerial photograph, this runs diagonally adjacent to the existing pitch at Hawthorn Lodge (the pitch allowed on appeal) but directly through both sites further north that are proposed for allocation. Whilst this could be potentially diverted to accommodate LPR (023), it would not be possible to divert the PROW to accommodate C4S (021). It would not be appropriate for a PRoW to run directly through a private residential site. No reference is made to the PRoW within the site-specific policy, and it would not be appropriate for the PRoW to be extinguished in order to accommodate this substantial development. See attached 2.11. The proposed 22 pitches to the rear of 1 Chart View would therefore result in an adverse impact on an existing Public Right of Way. Either views from the PRoW would be substantially altered and the footpath rendered inappropriate for use, or the PRoW will have to be extinguished. In either event, there would be a clear unacceptable adverse impact to users of this established right of way, further impacting the existing settled community. 2.12. Whilst the impact of one pitch at Hawthorn Lodge was not considered significant, the cumulative effect of the three further pitches at Hawthorn Lodge and the 22 listed to the rear of 1 Chart View proposed and the erosion of the gap would clearly result in significant harm to the landscape and rural character of the area, including users of the PRoW, and the quality of life of the existing settled community. The DPD proposes a significant intensification of gypsy and traveller pitches in an area where a substantial number of pitches already exist, and the DPD proposed a level of development that is disproportionate to the established quiet rural environment. 2.13. The substantial amount of development that would result is highlighted by draft Policies TR8 and TR9 which set specific requirements for allocated sites. Pitches are expected to accommodate an amenity block, a mobile home and a touring caravan as a minimum, therefore the allocation of 25 pitches would result in an additional 25 amenity blocks, 25 mobile homes and 25 touring caravans in the area; an additional 75 features overall. Whilst landscaping and biodiversity features will be required, it is clear from the examples given within the DPD that the pitches would likely be primarily comprised of hardstanding in order to accommodate the buildings and parking requirements. It is clear that what is proposed by the DPD would result in a substantial amount of development in a rural countryside setting. 2.14. In proposing these substantial sites at Rabbits Cross and Peacock Farm, the Council are contravening their own settlement hierarchy proposed at Policy TR1 which places the Countryside at the lowest tier of development (i.e., the part of the Borough that is least appropriate for development) below Maidstone itself, Garden Settlements, Strategic Development Locations, Rural Service Centres, Larger Villages and Smaller Villages. None of the sites at Rabbits Cross of Peacock Farm fall within any of these locations and are therefore Countryside. 2.15. The supporting text to Policy TR1 states that: “The countryside has an intrinsic rural character and beauty that should be conserved and protected for its own sake” 2.16. It is considered that the allocations at Rabbits Cross and Peacock Farm are directly contrary to the Council’s own Spatial Strategy set by Policy TR1. They would also be contrary to the visions and objectives of the plan which refer to ‘Putting People and the Environment First’ with various references to environmental enhancements. It is considered that these allocations do not put either people or the environment first and would adversely impact the local character of the area of quality of life of the existing community, contrary to the stated aims of the DPD. 2.17. In addition, we have previously raised concerns in respect of previous proposals at Rabbits Cross that the number of gypsy and traveller sites in the area now dominate the existing settled community. This consideration is made with reference to Planning Policy for Traveller Sites (PPTS) at Policy C and H as follows. Policy C: Sites in rural areas and the countryside 14. 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. Policy H: Determining planning applications for traveller sites 26. Local planning authorities should very strictly limit new traveller site development in open countryside that is away from existing settlements or outside areas allocated in the development plan. Local planning authorities should ensure that sites in rural areas respect the scale of, and do not dominate, the nearest settled community, and avoid placing an undue pressure on local infrastructure. 2.18. This was a matter that was discussed in some detail by the Inspector within appeal decision APP/U2235/C/24/3340802. In respect of this appeal, Pegasus Group argued that the development would be contrary to Policies C and H of PPTS drawing reference to the comments of a previous Inspector who, in allowing two single mobile homes on a site in Chart View in 20191, stated that the domination of the nearest settled community was “not an unfounded concern”, and that: “Further growth of the sites(s) here could well mean that this relatively sparsely populates area (notably the immediate locality of Rabbits Cross hamlet) would become dominated, to the detriment of its character and community mix.” 2.19. In the recent (November 2024) appeal decision the Inspector suggested that there were nine or ten pitches in total at Rabbits Cross, compared with seven ‘bricks and mortar’ dwellinghouses, stating at Paragraph 22: “There can be no doubt that the number of traveller pitches numerically dominates the number of bricks and mortar dwellings at Rabbit’s Cross, and it would seem likely that the number of individual traveller families would far exceed the seven families that live in nearby houses. I see no reason why an assessment of whether gypsy and traveller sites/pitches dominate the nearest settled community should exclude a hamlet like Rabbit’s Cross because its residents are just as capable of feeling ‘dominated’ as the residents of, say, Staplehurst, Chart Sutton or the local parish as a whole could be by traveller numbers exceeding the population of these settlements.” 2.20. Paragraph 23 explains that the whole thrust of government planning policy for travellers is to ensure fair and equal treatment in a way that facilitates their traditional and nomadic way of life while respecting the interests of the settled community, stating: “It seems to be that the adjacent caravan sites in Chart View (where the number of pitches are increasing) and Old Oak Paddocks already numerically dominate – in terms of numbers of families and dwellings- the settled community at Rabbit’s Cross.” 2.21. Paragraph 24 concludes on the issue, setting out that the appeal development infills land between Chart View and Old Oak Paddocks and that: “Although there is no reason why all the current travellers living in the immediate vicinity, including the appellant and her family, and the members of the settled community should not live peaceably together, it is understandable if the latter feel they are dominated by their traveller neighbours. To the extent that they do, and particularly in terms of infilling the physical gap between the two existing larger traveller sites, I consider the proposed development to be contrary to PPTS Polices C and H.” 2.22. These remarks are highly relevant to consideration of the proposals within the DPD. This Inspector considered that there was already numerical domination at Rabbits Cross which was then increased by the additional pitch that was subsequently allowed on appeal and has been further since increased by the recent granting of planning permission for three further pitches. This was acknowledged by the Council in their allowing of that planning permission 25/503131/FULL, stating within the Delegated Report that the domination was contrary to national planning policy for traveller sites, and that: “This proposal, which would intensify the use of the site, would contribute to a cumulative dominating effect, which is harmful to community balance and contrary to policy.” 2.23. The domination of the existing community was therefore already an established fact prior to the submission of this planning application and emphasised by the Officer within the Delegated Report. Nonetheless, the application was approved with the conclusion including the following remark: “While I acknowledge that the proposal would contribute to the cumulative dominating effect of traveller sites in the Rabbit’s Cross area, an impact that is harmful to community balance and contrary to Policies C and H of the PPTS, the scale of this particular development is limited in the wider context.” 2.24. We disagree with this view because, as domination has already been established, any number of additional pitches would add to this effect, regardless of size. Regardless of this, however, this established domination would be exponentially exacerbated by the addition of 22 further pitches at Rabbits Cross, resulting in an outweighing of the settled community by a substantial number. The settled community remains at seven dwellings, as with the time of the appeal, however the number of pitches has now increased to 18 with the granting of planning permission 25/503131/FULL, already doubling the number of pitches in comparison to ‘bricks and mortar’ dwellinghouses. Increasing this by a further 22 pitches to a total number of 40 would result in there being over five times more gipsy pitches than dwellinghouses in the local area. This would clearly be a disproportionate number of pitches compared to dwellinghouses in Rabbits Cross, substantially increasing the feeling of domination and clearly contrary to PPTS Policies C and H. 2.25. In addition, 15 further pitches are proposed nearby at Peacock Farm. It is noted that 3 pitches were recently granted planning permission under application 25/503191/FULL which are taken into account as part of the 15 proposed, however this would still mean a further 12 pitches on the site. From the Block Plan approved with that application there is clearly not sufficient space for an additional 12 pitches on that site. In general terms, an additional overall 15 pitches at Peacock Farm would further add to the domination of the settled population within the local area. 2.26. Whilst it is acknowledged that the Council has an undersupply of pitches and needs to find locations for them as part of the DPD, it is considered that Rabbit’s Cross and Chart Hill Road have already accommodated more than its fair share of pitches in comparison to the rest of the Borough. This remains a countryside location and its rural character will be entirely undermined by the proposed allocations. 2.27. The previous Inspector also expressed concern (see Para 24 above) about the one additional pitch at Hawthorn Lodge eroding the physical gap between two existing larger sites at Chart View and Old Oak Paddocks, a gap that will be further eroded following the granting of planning permission 25/503131/FUL. The proposed allocations would again further erode this gap by substantially expanding the Chart View site and bringing it much closer both to Old Oak Paddocks and the recently approved sites to the west of Old Oak Paddocks. 2.28. Although it is acknowledged that this appeal was allowed, this was on the basis that the personal circumstances of the Appellant were given a substantial amount of weight, with issues such as the welfare and education of their children under consideration. These issues have no bearing on the current proposals to allocate a substantial number of additional gypsy and traveller pitches at Rabbits Cross, however this is a relevant point because, as is evident from the above, the Inspector found harm here in respect of one additional pitch in respect of domination, eroding the gap between sites and landscape character. Whilst in this previous instance the Inspector found that the personal circumstances of the Appellant outweighed the harm, this remains a live issue for the area that needs to be considered. 2.29. The previous Inspector found harm in respect of these matters as a result of one additional pitch. The current proposals to allocate an additional 22 pitches at Rabbits Cross – which would be an additional 25 over and above what the Inspector was considering at that time – would clearly result in substantial harm to the amenities of existing residents of Rabbits Cross through a feeling of domination by gypsy and traveller pitches, including the erosion of the physical gap between larger traveller sites. The addition of a further 15 pitches nearby at Peacock Farm would further increase these adverse impacts. 2.30. For these reasons, the proposed allocations at Chart View and Peacock Farm are considered to be inappropriate development that would result in substantial harm both to the character and appearance of this rural area and the amenities of the residents of nearby properties. 3. Summary and Conclusion 3.1. Paragraph 36 of the National Planning Policy Framework (NPPF) states that local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements and also to assess whether they are sound. Plans are considered ‘sound’ if they meet four criteria, listed at a-d of Paragraph 36. Criteria d requires that plans are: “Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.” 3.2. It is our firm view that the DPD does not meet this requirement. The allocations at Rabbits Cross and Peacock Farm would result in harm to the rural character of the countryside including harm to users of an existing Public Right of Way, and adverse impacts upon the amenities of local residents through an over-domination of the area by gypsy and traveller pitches. The allocations would also be contrary to the Council’s own Spatial Strategy set out at Policy TR1 of the DPD. 3.3. For these reasons, the proposed allocations at Rabbits Cross and Peacock Farm do not represent sustainable development in accordance with the policies of the NPPF and is contrary to Paragraph 36(d) of the NPPF. As such the DPD in its present state is unsound.
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 nonallocated 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 3 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.
East Sutton is rural parish does not currently have a G&T population with no sites listed in the consultation document on MBC. There is currently one planning application for a G&T pitch in East Sutton, on the Sutton Valence boundary. The attached spreadsheet is a combination of data from tables 6.1 and 6.2 of the consultation document on MBC, it looks at the existing number pitches within the Borough by parish and the ‘potential net gain in pitches’ possible at each of those existing sites and some proposed sites; and assesses the impact of the potential intensification at those sites in a colour coded assessment. If you filter the data to list the parishes of the Borough surrounding East Sutton, (Broomfield & Kingswood, Langley, Ulcombe, Chart Sutton, Sutton Valence, Headcorn and Lenham); there is a very significant number (142) of existing pitches and an even more significant number (253) of pitches proposed as a potential net gain, on or very close to the East Sutton Parish boundary. 142+253 would give a total potential of 395 pitches surrounding the parish of East Sutton, a 278% increase. To put the 395 potential total pitches in context the 2021 census shows East Sutton with a population of 383 persons, in 116 households. The KALC draft response, calls doubt as to the validity of parts of the data used in the consultation document as such overestimating the need. As the ‘potential net gain in pitches’ is concentrated on existing pitches and areas surrounding East Sutton. Our parish would potentially bear the brunt of the impacts of this level of development / allocation of pitches. From KALC draft response , ‘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.’ That 5.4 times the national average, in Maidstone Borough, but that is further concentrated around the parish of East Sutton. From the ONS website. (See attachment) Nothing to add to the KALC draft response. The overall comment to make here is that East Sutton Parish Council recognises that the G&T community have a housing need, and that MBC must have a coherent and robust plan to identify and cater for that need. Whilst giving MBC the tools to make robust planning decisions to protect the environment and balance between the settled & G&T communities.
General Comments YPC fully supports the comments of The Maidstone Area Committee of The Kent Association of Local Councils. Existing sites YPC is led to believe that the map of current sites included within the consultation plan seeks to show the broad location of all existing sites in the borough regardless of their legal status. In terms of what happens to these sites once the plan is adopted, we are led to believe that any existing permanent authorised sites will remain as such. Any existing illegal or unauthorised sites will also remain as such, even if they are allocated. No sites will automatically gain planning consent by virtue of being included within the plan, an applicant would still be required to submit a planning application to Maidstone Borough Council for determination in the usual way. YPC feel that if and when the plan is adopted there needs to be a commitment to take enforcement action against the remaining illegal or unauthorised sites, some of these sites have been under enforcement for more than 15 years. They also form a significant number of pitches and therefore give rise to a misconception of the number of pitches required. Yalding Specific allocations - Policy TR4 Call for Sites submissions with nominated site capacities C4S (011) - Highlands Farm (East) – Site A- 8 pitches and C4S (012) - Highlands Farm (East) – Site B - 16 pitches. Both these sites are subject to enforcement action for the stationing of caravans without planning permission, this enforcement dates back to 2023, yet development continues. To allocate these developments would lead to a substantial over intensification in the open countryside. There have recently been a number of anti-social behaviour issues on Yalding Hill outside this development, primarily youths throwing eggs and rocks at passing cars. Call for Sites submissions without nominated site capacities - C4S (001) - Land at Kenward Road/The Cherry Orchard Yalding Parish Council have several concerns with the allocation of this site. This is a very large site therefore to state that planning permission for a none specified number of permanent pitches will be granted is unacceptable and make it impossible to achieve meaningfully consultation. A small number of pitches will have a very different impact to a large about of pitches. The site over looks an important listed building that is the home of Kenward Trust an alcohol and drug residential rehabilitation Centre. The development is located in an environmentally unsustainable rural location with no bus service giving a substantial unlit and unsafe walk to any public transport options in both directions. Future occupants would be reliant on the private motor vehicle for day to day needs, including access to goods and services, school, employment and health care. There are no bus stops or routes within 1100m and no Primary School, GP or Shop within 1500m. As such the development is not sustainable It would be almost impossible to get the mobile homes on site, there is a weight restriction on the Bow bridge in one direction, this is not an environmental restriction it is a structural 3.5T limit. In the other direction at the junction of Kenward Road and Yalding Hill, large vehicles cannot exit without mounting Yalding Village Green or hitting The Walnut Tree fence. Both have suffered from significant damage and Councilors have concerns with regard to the safety of the war memorial. 112 properties are approved for development on Kenward Road, closer to Yalding Village, in 2026. This development comes with no conditions to improve the highway at Kenward Road or Bow Hill. Of particulate concern is the heavily congested junction at Kenward Road and Yalding Hill, sight lines at this junction are poor and causes a buildup of traffic. Councillors believe that traffic generated by the new housing will be forced to go in the opposite direction to the junction of Bow Hill and Maidstone Road, past this site. No improvements have been allowed for at either of these junctions, therefore further development anywhere on Kenward Road would exasperate this. Kenward Road is used as a rat run to avoid Yalding Town Bridge, it is impassable in places and is heavily congested at peak times. At times of flooding Bow Hill becomes impassable, forcing all traffic into Yalding Village where the B2162 could also be impassable due to flood water. The single track lanes of Hunt Street and Small Profits is not a suitable or safe alternative.
Tony Harwood paints a romantic picture of the Gypsy/Traveller community. Unfortunately times have changed. In my day, we happily employed this community on the farm and have maintained close contact with these families over the years. These very same families are shocked and sickened at the way the "new" G/T communities behave. The crime level has soared amongst them and they are taught to laugh at authority and to disregard the law. We know this from the lovely Gypsy/Travellers who have maintained the old ways. This is why there are so many people against most of the new G/T communities. This attitude is leaking out into the settled communities - because it works! No need for good old-fashioned honesty if you get further by autocratic means. It is laborious to go through the planning system: just build what you want and wait for the over-stretched under-funded Council to allow retrospective planning - the quickest way for all. The crime level has risen amongst the hare-coursing and catapulting fraternity, laying bets on all this cruelty. They trespass mostly at night on farmland, cutting padlocks, driving across crops ruining farmers' livelihoods. Personally, as a female in her 60s, I was rammed head-on in my car by lampers. A female friend's car window was smashed by catapult ammo, a shop window, a train and a school bus attacked, all "just for fun". These are not apocryphal stories, these crimes are escalating amongst the G/T communities. It is well-known that the Police prefer not to enter these sites. In addition, most Councillors are from urban backgrounds and cannot imagine the problems faced by the rural community. It is only those with boots on the ground that have true knowledge and love of the countryside. Rumour is spreading that one MBC councillor actually referred to a part of the countryside as "featureless farmland" which explains it all. You state "Maidstone borough has the highest Gypsy and Traveller population by local authority area across England and Wales." We implore you, as much as is legally possible, not to allow any more spread of these sites across Kent.
No answer given
Disagree: The calculated need for G&T accommodation, as already stated, is overestimated and MBC need to review these figures. Each site needs to be reviewed on its merit, but we need to move to a position of not creating huge sites as this will be to be long-term detriment of G&T and the settled community. Instead, small G&T sites interspersed within settled community developments, including new developments is far more appropriate and will in the longer-term increase G&T social-economic status and mobility. Sites should be located within or on the edge of towns to facilitate on foot access to amenities and encourage advancement of much needed opportunities for G&T communities.
Q5 – Policy TR4 (Site Allocation) Additional Comment • Avoid overcrowding existing sites that are unsafe or poorly served by amenities. • Consider brownfield or greenfield sites
Headcorn Parish Council will provide its assessment of the specific allocations set out in Policy TR4: Accommodation on allocated sites, in its response to question 6 below. In general terms, Headcorn Parish Council supports an approach that meets the identified need for gypsy and traveller accommodation through site allocations within the Local Plan. It considers that site allocations, rather than a reliance on other options such as the intensification and expansion of existing sites, should be the preferred route to meeting identified need. In particular, Headcorn Parish Council considers that any development that would meet the threshold of a major development set out in the NPPF (namely that it would involve a “development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more”) should only be permitted where it comes forward as an allocated site within the Local Plan. This would allow for proper scrutiny and an assessment of the relative sustainability of different options. In considering whether a site would constitute a major development, Headcorn Parish Council considers that existing development on the site as a whole should be included, to avoid creating major developments by stealth. Headcorn Parish Council notes that: the sites carried forward from the existing LPR would result in 22 new pitches; if accepted, the sites that have come forward through the call for sites with nominated site capacity would create an additional 175 pitches; and 5 additional sites have been proposed through the call for sites with unspecified capacity. For the reasons set out elsewhere, Headcorn Parish Council considers that the calculated need for pitches is likely to have been overstated. However, as set out in the Table following paragraph 50 of the dDPD, the short-term need for pitches amongst households meeting the PPTS definition of gypsy and traveller is for 251 pitches. Furthermore, the dDPD identifies that 75 new pitches have been granted permission since 2023, meaning only 176 additional pitches are now needed to meet demand from gypsies and travellers over the first 5 years of the plan period (2023-2027), with an additional 56 pitches needed for the next 5 years. Therefore, for the first 10 years of the Plan period, 232 additional pitches are needed. Even without any contribution from the five sites that did not quantify potential capacity, assuming the sites that have come forward are acceptable and are allocated as part of the final Plan, the identified capacity is for 197 pitches. This more than meets the identified demand for the first 5 years of the Plan. Combined with potential capacity on the five unspecified sites, as well as any further suitable sites that come forward through the call for sites, the identified sites are also likely to meet demand for the first 10 years of the plan period. As Local Plans will need to be reviewed every 5 years, Headcorn Parish Council considers that this eliminates the need for the proposed blanket approach supporting site expansion and intensification proposed elsewhere in the Plan. Putting stricter criteria on when site intensification, expansion and reorganisation would be allowed would still be compatible with meeting identified need. On a separate point, Headcorn Parish Council considers that it would be useful to list the site according to parish, rather than ward boundaries. This would make it easier to identify where sites are located and their likely proximity to local services and jobs markets.
We agree that new sites should be found, however, they are best if they are public sites owned by Maidstone in, or close to, the urban area, where needs can more easily be met. Expanding existing sites is fraught with problems. The Water Lane site in Ulcombe was the only G&T site in Ulcombe when established. We now have 74 mobile homes and about 30% of our village population are already G & T. The land around the Water Lane site is Ancient Woodland dating from Henry Vlll and is now protected by TPOs. The Consultation document says on page 30 that development proposals will protect natural landscapes, including Ancient Woodland. Given this pledge, expanding the Water Lane public site should be a non-starter. We oppose any expansion into the protected Kingswood. We are against any expansion of this Water Lane site for the reasons of unsustainability mentioned above and because it would be against MBC's spatial policy of discouraging developments which need many cars to access facilities.
I write on behalf of Stockbury Parish Council in relation to the recent consultation on the Gypsy, Traveller and Travelling Showpeople Development Plan Document. At its meeting on 21 January 2026, the Parish Council considered the consultation material in detail and resolved to formally raise concerns regarding the accuracy of the Gypsy and Traveller pitch figures currently attributed to Stockbury Parish. Stockbury Parish Council recognises and supports the need for Maidstone Borough Council to plan positively and responsibly for the accommodation needs of Gypsy and Traveller communities. However, it is essential that the baseline data used to inform the Development Plan Document is accurate and reflects the true level of existing provision in each parish. From reviewing the consultation documents, it is not clear that the current level of authorised and unauthorised provision within Stockbury Parish has been fully or accurately represented. The Parish Council is concerned that this may lead to an incorrect understanding of the contribution already made by the parish and could result in inappropriate future allocations. Local Evidence Held by Stockbury Parish Council The Parish Council holds detailed information regarding existing Gypsy and Traveller sites within Stockbury Parish. This information is based on the most recent bi-annual caravan count undertaken in January 2025, provided by Maidstone Borough Council. For clarity, the Parish Council’s current data is summarised (Please see attached): The figures above indicate that Stockbury Parish currently accommodates the equivalent of: • Approximately 63 authorised pitches, and • Approximately 25 additional unauthorised pitches, Resulting in a combined equivalent of around 88 pitches located within Stockbury Parish. This represents a very significant level of existing provision within a small rural parish and demonstrates that Stockbury is already making a disproportionately high contribution toward meeting borough-wide Gypsy and Traveller accommodation needs. The Parish Council is concerned that if the full extent of existing authorised and unauthorised provision is not properly reflected within the evidence base, there is a serious risk that: • Future policy decisions could be based on incomplete or inaccurate information; • Additional allocations could be directed towards Stockbury Parish in the mistaken belief that current provision is limited; • Unsustainable pressure could be placed on a parish with limited infrastructure, services, public transport and highway capacity; and • Community confidence in the fairness and balance of the planning process could be undermined. Position of Stockbury Parish Council on Future Allocations Based on the evidence set out above, Stockbury Parish Council considers that: • The parish already hosts a high and disproportionate number of authorised and unauthorised pitches in comparison to many other parishes within Maidstone Borough; • Existing provision within Stockbury is already well above what would reasonably be expected for a small rural parish; and • The infrastructure and environmental capacity of the parish to accommodate further sites has already been exceeded. The Parish Council therefore strongly believes that no further Gypsy and Traveller sites or pitch allocations should be made within Stockbury Parish through this Development Plan Document or any future reiterations of it. Any additional need arising within the borough should be met in locations that do not already carry such a substantial concentration of provision and where infrastructure, services and sustainability considerations are more appropriate. Stockbury Parish Council respectfully requests that Maidstone Borough Council: 1. Reviews the pitch figures currently attributed to Stockbury Parish within the Gypsy and Traveller Development Plan Document and all supporting evidence papers. 2. Cross-checks these figures against the most recent caravan count data, enforcement records and site monitoring information. 3. Amends all future consultation documents, maps and evidence tables to ensure that the true level of existing provision within Stockbury Parish is accurately reflected. 4. Recognises within the Development Plan that Stockbury Parish already accommodates a high level of provision and that, as a consequence, no further Gypsy and Traveller site allocations should be directed to Stockbury Parish. 5. Confirms in writing how this local evidence and the Parish Council’s position will be taken into account prior to the Regulation 19 stage of the Plan. The Parish Council understands that the formal consultation period has now ended but would be grateful if the concerns and evidence set out in this letter could still be taken into consideration as part of the ongoing preparation and refinement of the Development Plan Document. Please acknowledge receipt of this letter and advise how Maidstone Borough Council intends to respond to this request for review.