Question 9: To what extent do you agree with the proposed policy for accommodation on non-allocated sites? Please provide comments to support your answer.
Think the Gypsy/Traveller community need to deal with all the things the 'settled' community have to. No favouritism for anyone. Some of the above reads as utter nonsense.
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.
Accommodation on non-allocated sites Policy TR7 (D) flooding We would encourage development to be placed outside flood zone 3a and 3b due to flood risk. The applicant will need a specific flood risk assessment to be approved by the EA to address the flood risk concerns in the area. Also, a sequential and exception test will need to be passed where necessary.
Policy TR7 - Accommodation on Non-Allocated Sites: Highways and Transportation The inclusion of criteria relating to site accessibility and the availability of sustainable transport links to local facilities is supported.
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.
No answer given
Slightly disagree. Strongly oppose the policy of encouraging and agreeing intensification, expansion and reorganisation of existing sites proposed in other parts of the DPD. This policy is highly inappropriate and needs to be dropped. Existing sites need to be removed from the supporting text (para 125). Many of the existing sites were established via retrospective planning permission (after enforcement) despite being unacceptable in planning terms purely because alternative accommodation was not available. Many of these sites are in open countryside, in LLVs and are highly unacceptable. Many of these sites have grown exponentially, are huge, sprawling, unregulated and associated with crime and disorder, they dominate the local settled community and increase tensions between G&T and the settled community. Cumulative size of sites needs to be taken into consideration – e.g. the vast number of sites along the Lenham Road in Headcorn, which is highly inappropriate. This sheer number and scale of these sites dominate the handful of properties along the Lenham Road – this is not right, balanced, or fair. Domination of the settled community (neighbouring houses) needs to be a key consideration. Domination of the settled community needs to be considered not to the nearest village or town but too the nearest house or handful of houses in the immediate locality of the G&T site. Implementing such a policy would demonstrate fairness and contribute to alleviating ongoing tensions between the G&T and settled communities. The situation on Lenham Road is out of control and cannot be seen as anything else but domination of the settled community, and systematic destruction of open countryside in an LLV.
Q9 – Policy TR7 (Site Design and Layout) Proposed amendment • In criterion (1)(i), define “nearest settled community” so that properties in the immediate vicinity are assessed independently of wider administrative boundaries such as parish areas. • • Enhance design standards for health, safety, and integration. Reason / policy justification • PPTS paras 13 & 26 emphasize avoiding dominance over settled communities and ensuring integration. • NPPF paras 8, 130, and 174 require safe, accessible, and visually appropriate development. Additional Comment • Health and Safety: traffic calming, lighting, signage, emergency access, and separate pedestrian/vehicle access. • Security: design out crime and social exclusion; office/management presence visible but non-intrusive. • Regular monitoring of layouts to ensure safety and accessibility for children and vehicles.
Headcorn Parish Council is broadly supportive of Policy TR7: Accommodation on nonallocated sites. However, Headcorn Parish Council strongly opposes the proposed approach of encouraging the intensification, expansion and reorganisation of existing sites proposed elsewhere within the dDPD and does not consider that the proposed approach is sound. It would therefore like to see the explicit reference to existing sites removed from the supporting text (paragraph 125). Proposed changes to existing sites could still come forward under Policy TR7, but they would be judged in the same way as other sites, without a presumption in favour. This is particularly important as many sites obtained retrospective planning permission despite being otherwise unacceptable in planning terms, purely because alternative accommodation was not available. Judging all sites in the same way would therefore help prevent otherwise unacceptable sites expanding further. Headcorn Parish Council supports ensuring development will not dominate the local settled community and is particularly pleased to see reference to the cumulative size of development on multiple sites within the setting in Policy TR7 Part 1.i. However, where development is taking place in the countryside, Headcorn Parish Council considers that dominance should be judged relative to the settled community in the immediate vicinity of development proposals, not the community in the nearest village. The approach to site size set out in Policy TR7 Part 1.i, is ambiguous as to what is meant here, as it refers to “the nearest settled community”, which could refer to a village. Headcorn Parish Council would like to see the clarification either within the supporting text, or within the policy itself, that the nearest settled community refers to housing in the immediate vicinity of the development (not the local village). It considers that without this clarification the proposals on site size are meaningless, as it is highly unlikely that gypsy and traveller development will ever be larger than a village, and as such without clarification this part of the policy would not be justified. More broadly, Headcorn Parish Council would like the policy on site size for unallocated sites to be strengthened further to ensure that major developments of 10 or more pitches in the countryside (to be counted including any existing pitches on site) would not typically be permitted. Headcorn Parish Council, notes that the NPPF seeks to avoid development in the countryside, except in a relatively few circumstances, and considers that permission for major development would run counter to this. Headcorn Parish Council considers that major development should only be permitted on sites that have been allocated through the Local Plan process, rather than unallocated sites, to allow for proper scrutiny and an assessment of the relative sustainability of different alternatives. The supporting text at paragraph 127 refers to the need comply with Policy LPRSP9 within the MBC LP. However, the MBC LP is not the only relevant policy within the Development Plan for Maidstone, particularly where there is a Neighbourhood Plan in place, as is the case for Headcorn. Headcorn Parish Council would therefore like to see the final sentence of paragraph 127 expanded to refer to “and any other relevant Development Plan policies”. Finally, while broadly supportive, Headcorn Parish Council considers that the parts of TR7 dealing with “Living environment” (Part 1.e) and “Landscape character” (Part 1.f) would be better located in Policy TR8, as the considerations are relevant to both allocated and unallocated sites.
We mainly agree with Policy TR7, especially when referring to sustainable access to community facilities, that sites should not result in significant harm to the landscape and character of an area, sites should be of a scale not to dominate the nearest settled community and consideration given to the cumulative size of multiple sites.