Question 12: To what extent do you agree with the proposed monitoring and review indicators? Please provide comments to support your answer.
No answer given
Monitoring is fine but would it be properly done and enforced if necessary if breaches have occured.
Monitoring and review are important aspects of the planning system. The question is, however, does the Borough Council have the capacity to undertake this work?
No answer given
I disagree with the proposed monitoring and review indicators because they lack robust enforcement mechanisms and fail to address critical risks. While annual monitoring is noted, the indicators focus on counting pitches and encampments rather than assessing infrastructure capacity, environmental impact, or community cohesion. There is no clear trigger for mandatory policy review when cumulative impacts occur, nor any requirement for independent audits. Without stronger compliance checks and transparent reporting, these indicators will not prevent overdevelopment or mitigate harm to rural landscapes and local services.
I object to the proposed monitoring and review indicators in relation to The Brishings (Site C4S 017). The site is unsuitable for development, and monitoring indicators cannot change the fact that allocating it would cause permanent harm to the countryside and rural landscape. Indicators related to occupancy, site management or compliance do not address the fundamental unsuitability of the site’s location, poor access to services, or impacts on sustainability. Simply setting out annual indicators and triggers does not ensure that policy outcomes will be delivered in practice. National research has shown that many councils with similar monitoring arrangements have failed to allocate or provide Traveller sites despite having monitoring frameworks in place, and unmet needs have persisted even where annual monitoring exists. If monitoring and review mechanisms have historically failed to prompt corrective action elsewhere, then relying on them here does not make the allocation of an unsuitable site like The Brishings any more acceptable. For these reasons, I object to applying the proposed monitoring and review policy to The Brishings, as the site is inappropriate for residential development and should not be included in the plan.
No answer given
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
There should be less of these sites near villages and other places where people live! There’s land up north where they wouldn’t cause problems for the locals!
No answer given
The Brishings. Indicators related to occupancy,site management or compliance do nothing to address the unsuitability of this location. This site is inappropriate for any residential development as previously addressed and should not be included in any plan going forward.
.
.
No answer given
No answer given
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).
No answer given
No answer given
It is very important that pitch provision is carefully monitored.
Monitoring as part of the AMR is supported. There should be reference to the annual caravan count. Consideration to unauthorised encampments subsequently authorised could be considered.
No answer given
Appendix A etc Reference should be made in the Glossary and elsewhere, as appropriate, to DfT Circular 01/22 as it comprises national policy for the SRN that sits alongside and carries the same weight as the NPPF. Gypsy and Traveller Call for Sites We have no comments on the exercise and have no suggestions regarding sites. However, we would welcome a conversation with you once the exercise is completed to discuss any sites that if allocated may have implications for the SRN for reasons the same/ similar to those described above regarding traffic and/or boundary matters. Next Steps National Highways is committed to working closely with all parties to facilitate this DPD commensurate with our obligations with regards the safety, reliability and operational efficiency of the SRN. We will work with the Council and its advisors seeking to address any outstanding or newly arising matters ahead of the DPDs submission, examination and adoption.
No answer given
No answer given
Please see comment below regarding question 1, which does not have a comments box: We agree with the objectives and vision of improving social cohesion between the settled and the travelling communities and of trying to reduce social tension. However, the development plan as drafted will have the opposite effect. It will risk decreasing social cohesion by housing all of the traveller community in rural countryside locations and all of the settled community in urban locations. Thus, segregate the two communities. It will increase the concentration of traveller sites in the southern half of the Borough in places with the highest proportion of people from the Gypsy and Irish ethnic group, rather than looking to evenly distribute sites throughout the Borough, exacerbating social tensions. It will support the expansion of existing traveller sites, without limiting the total number of pitches. This means there is a likelihood of small family sites, which peacefully co-existed, could expand into large conurbations of mobile homes, which dominate their nearest settled neighbours and create social tensions contrary to the requirements of PPTS. The DPD will look to fulfil the accommodation needs of the traveller community by placing them outside locations where they could more easily access healthcare and schools, and the other social amenities available to the wider community. This is in contrast to the policies which the adjoining Borough of Tonbridge and Malling are consulting upon, as they state that to be approved, a site must be “in a sustainable location and is either located within or adjoining a settlement confines boundary or within good proximity to a range of services including shops, schools and primary health care facilities accessible by public transport, to enable integration into the community” It is noted that PPTS accepts rural locations are acceptable in principle, but that they should be strictly limited in locations away from settlements. Sites should therefore be located within or close to a settlement. Paragraph 8 of PPTS states “Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. To this end, they should be consistent with the policies in the National Planning Policy Framework (NPPF), including the presumption in favour of sustainable development and the application of specific policies in the Framework, and this planning policy for traveller sites”. At present, the DPD does not achieve the Council's stated objectives of protecting the Borough’s natural heritage, enhancing biodiversity, promoting nature, ensuring that all new development is built to the highest standards of sustainable design and construction and has dependable infrastructure for the removal of sewage and wastewater.
Seems sensible. More action is required to stop unauthorised sites and they should not be given retrospective planning permission so easily as in the past. The planning rules should be fairly and equally applied regardless of background.
The plan seems reasonable but I believe 2 elements are missing: 1. Number of objections to planning applications (this could suggest disproportionate impact) and remedies to these (eg improved BNG plans, enhanced screening requirements) 2.enhanced action against unauthorised sites. Retrospective planning is not ideal, but does happen. However expansion/development without any attempt at a planning application should have substantial ramifications including robust and timely legal action.
As long as it happens in a fair and balanced way, I don't have any concerns. Annual or similar inspection of pitch numbers should be added to your list. This is to verify the number of pitches granted is what is actually there so site numbers remain legal and reasonable.
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.