Question 10: To what extent do you agree with the proposed policy for general site design and layout? Please provide comments to support your answer.
It is important for everyone to be in positive surroundings and having a well-planned site will benefit all residents, whether they are temporary or permanent. I do think, however, that for some sites brick road boundaries (to main roads) may be more appropriate eg for safety and security of children and animals. Many rural 'bricks and mortar' properties have brick frontages, so in some places it may be in keeping with the location. Green spaces and adequate facilities should be a basic expectation of any new development, whether Gypsy or Traveller, or settled.
The same rules that apply to the 'settled' community should apply here.
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.
Whilst the Co-Promoters support the inclusion of site layout guidelines at Policies TR8 and TR9, we recommend that consideration be given to limiting the number of pitches on each site. Finally, experience shows that long term management of sites that are provided through larger developments needs careful consideration. Therefore the DPD needs to provide clarity on the future management and responsibility of any sites provided through the broad locations. In summary, whilst we welcome the consultation and the Council’s ambitions to meet the full needs of its GTTS community, the draft DPD as set out requires further clarity in terms of pitch provision in broad locations. The Co-Promoters would be happy to discuss further the potential to meet an appropriate level of need within Heathlands, having regard to Local Plan Policy LPR4a requirements and project deliverability and viability.
Policy TR8 – General Site Design and Layout: Flood and Water Management The County Council notes that under the Natural and Built Environment Section, item m requires any sites which come forward to consider the use of SuDS where possible. This is welcomed and the County Council suggests that MBC should also reference the requirements in DEFRA’s SuDS technical standards which set out how SuDS should be designed Highways and Transportation The inclusion of criteria relating to achieving suitable access, supplementing those already captured in adopted Local Plan Policy LPRSP15, is supported.
No answer given
Disagree. The number of pitches needs to be set out and enforced. Subdivision of pitches must not be allowed, as overcrowding is common and is associated with crime and disorder. Major developments e.g. 10 or more G&T pitches, needs to be supported by appropriate amenity space. High, closed board fences must (not should) not be allowed. Native hedgerows need to be retained (they exceedingly rare are) and established. Ecological guidelines must (not should) be adhered to. Lighting must meet the same standards as set for the settled community in the open countryside, with external lights on sensors. Hard standing that is not permeable must (not should) not be allowed. The disposal of foul wastewater needs to be addressed. Many current sites violate the law in this respect. Those that have fitted sewage treatment plants are too close to buildings and are emptying into dry ditches – which is unlawful. The disposal of wastewater needs immediate and urgent attention and sites should not be agreed unless they can meet all the necessary conditions – which apply to the settled community. Most of the sites are too over-crowded, have not got the space to ensure compliance with wastewater legislation and this is not properly considered when considering site and pitch layouts.
Q10 – Day Rooms and Amenity Blocks Additional Comment • Policies should address sanitation, wastewater management, and health standards.
In relation to Policy TR8: General site design and layout, Headcorn Parish Council notes that the MBC LP is not the only source of relevant policies within the Development Plan on issues such as design, landscaping, etc. For example, in Headcorn, Neighbourhood Plan policies should also apply. The NPPF makes clear that Neighbourhood Plans are designed to allow local communities to have a say on what and where development takes place. Therefore, to avoid undermining the role of Neighbourhood Plans within the Borough and to ensure the dDPD is justified, Headcorn Parish Council considers that in the parts of policy TR8 that explicitly refer to MBC LP policies (eg LPRSP15) should be amended with a reference to: “and other relevant Development Plan policies”. Headcorn Parish Council considers that any major development (of 10 or more pitches) should be supported by appropriate amenity space, which depending on a site’s intended occupants could be for adults, not just children. It notes that the current policy wording on site layout (TR8 Part 1.b) would make it easy for developers to avoid the provision of amenity space and considers that the drafting should be strengthened to: “Larger sites of 10 or more pitches should include appropriate amenity space, such as children’s play space.” Headcorn Parish Council would prefer to see Policy TR8 Part 1.g strengthened to explicitly include the avoidance of high fences and other boundary treatments that would restrict views across the countryside. Headcorn Parish Council considers that it is important that any plan to deal with wastewater infrastructure and surface water flooding should be acceptable, not just provided, and considers Policy TR8 Part 1.m should be strengthened to reflect this. Headcorn Parish Council considers that vehicle access arrangement to sites should be from a single access point, to avoid the suburbanisation/urbanisation of the countryside and other environmental and landscape harms and therefore would like to see Policy TR8 Part 1.o and the supporting text (paragraph 142) strengthened to reflect this. The supporting text for Policy TR8 mentions national policy and policies in the MBC LP and in other Boroughs (such as Leeds), but does not mention Neighbourhood Plan policies. Without the need to list all the relevant policies, Headcorn Parish Council considers that the supporting text should make clear that any relevant Neighbourhood Plan policies should also be followed. For the reasons set out in its response to Question 11 below, Headcorn Parish Council does not support the use of semi-detached dayrooms of the type envisaged. It therefore does not support the proposed site layout shown in the third example associated with paragraph 138. Headcorn Parish Council notes that the subdivision of sites into ever smaller pitch sizes is directly correlated with the likelihood of problems on the site. It would therefore like to see a policy requirement that sets out minimum acceptable pitch sizes. Headcorn Parish Council would like to see paragraph 152 on hardstanding strengthened to make explicit mention of the need to avoid creating or exacerbating flooding, including surface water flooding.
We agree with the broad aims of General Site Design and Layout. It is important to have effective, thick natural hedge and tree screening of any unattractive traveller sites in rural countryside, and in dark landscapes, as has happened in Ulcombe over the last 20 years. The control of excessive lighting, brick walls, closeboard fencing, excessive hardstanding etc is necessary to reduce the urbanising effect of these sites in quiet rural areas. The problem with large well landscaped sites is that there is a lot of vacant space which can accommodate unallocated additional mobile homes. Enforcement has great difficulty in doing anything about this, as with The Meadows site in Headcorn. The average recommended pitch size is twice the size of a large bungalow site. We consider this far too big in Kent where land is expensive and in short supply.