Lidsing Garden Community SPD

Comment

Representation ID: 694

Received: 15/12/2025

Respondent: Natural England

Thank you for your consultation on the above dated 03 November 2025 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

To inform our comments we have reviewed the following documents made available to us during the consultation period:
•Lidsing Garden Community Supplementary Planning Document (October 2025)
•Lidsing SPD – Design Topic Paper
•Liding SPD – Green & Blue Infrastructure Topic Paper

We would like to thank your authority for your work in developing this SPD however, we feel that further detail is required to ensure that the development meets the criteria set out in LPRSP4(B). In our view, the SPD should incorporate a Strategic Masterplan and Design Code to ensure that good quality design is implemented from the outset, rather than attempting to embed these at the later planning stages. A good example of this in practice is the work that has been undertaken for Medway’s Innovation Park which is also in close proximity to Kent Downs National Landscape.

Please note that we have not provided comments on all aspects of the SPD, only those which are relevant to our remit. Our answers to the specific questions posed can be found in Annex 1 and further comments can be found in Annex 2.

We have set out further comments on the Draft SPD and associated documents in Annex 2

Comment noted.
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme and taken collectively provide sufficient clarity around design expectations and that of a design code. The code coming forward prior to reserved matters will still ensure good quality design aspects are embedded when the site is delivered.
Future planning applications will have to consider and demonstrate how they have addressed all stated requirements.

Comment

Representation ID: 1470

Received: 15/12/2025

Respondent: Natural England

Given the location of the site both within the Kent Downs National Landscape (KDNL) and within the
immediate setting, as well as the quantum of development proposed, we not only agree with the
principle of producing a SPD but feel it is central to delivering a truly landscape-led development
which protects and enhances the KDNL by ensuring good design, appropriate location of buildings
and natural screening.

1.5.4
'Given the anticipated timescales for the
overall build out of the Garden Community, it
is envisaged that a design code will be
produced following an outline planning
application but prior to reserved matters...'
We are concerned that a design code has not been produced as
part of this SPD to ensure that any development that comes
forward will incorporate good design from the outset. While we
acknowledge that the design code should be completed prior to
any reserved matters applications, certain elements will need to
be decided at outline stage and the approach does not recognise
that development could come forward as part of a hybrid
application.
We therefore strongly recommend that a design code is
produced prior to outline planning stage and highlight Innovation
Park's Design Code as an exemplar. A design code produced at
earlier stage will help to guide the design of the Garden
Community to ensure that it meets the requirements and
aspirations of the Local Plan and SPD.

2.3
'There is a range of design guidance that
informs the framework for the SPD and this
is set out in the following paragraphs'
Given the development's location we are surprised that the
KDNL's planning publications have not been used to inform the
framework of the SPD and recommend that they are included
here.

3.2.7
'The emerging Kent Local Nature Recovery
Strategy, Medway Green Infrastructure
Strategy and Maidstone Green Infratructure
Strategy acknowledge existing habitats of
importance and recognise their existing and
potential connection to the surrounding
landscape...The LNRS should inform the
consideration of the creation and
enhancement of new and existing habitats as part of emerging proposals for development'
While we agree that the LNRS should inform the creation and
enhancement of habitats on site, it would be helpful to
understand how the referenced documents have informed the
framework plans set out in the SPD and ultimately how the
development will contribute to the delivery of the strategy.
We would also like to highlight that the Kent LNRS was published
on 28 November 2025 and should therefore no longer be referred
to as 'emerging'.

3.2.9
'This area is characterised by the following
landscape features:
Setting of KDNL,
Level to gently sloping plateu,
A mixture of arable fields, paddocks,
remnant orchards and small to
medium blocks of woodland.
Mixed of historic and recent buildings,
traditional materials and narrow lanes
in addition to the M2 Motorway'
For completeness, we recommend that the full list of 'Key
Characteristics' for the Bredhurst and Stockbury Downs LCA are
listed from the Maidstone Landscape Character Assessment
(2013).
In addition, we suggest that the SPD outlines the special qualities
of the KDNL, considering whether they are exhibited on site
currently and how these could be protected/enhanced. This is
particularly important for the southern parcel located within the
KDNL given the need to 'seek to further the purpose' of the
landscape as required by s245 of the LURA 2023.

Figure 20
We are pleased to see that areas of existing priority habitat,
ancient woodland and other habitat have been mapped though it
is unclear why these have not been included within Figure 23.

Comment noted
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme and taken collectively provide sufficient clarity around design expectations and that of a design code. The code coming forward prior to reserved matters will still ensure good quality design aspects are embedded when the site is delivered.
The Council agree that references to the KLNRS should be updated to reflect it being published.

Comment

Representation ID: 1471

Received: 15/12/2025

Respondent: Natural England

Yes, we agree with the opportunities and constraints identified on page 42 of the SPD and welcome
the identification of the sites location within/adjacent to KDNL as both an opportunity and a
constraint.

Comment Noted

Comment

Representation ID: 1472

Received: 15/12/2025

Respondent: Natural England

Natural England supports the Vision for Lidsing Garden Community, in particular the focus on
enhancing the natural environment of the location and the sites relationship with the Capstone
Valley. We are pleased to see reference to providing strong north-south links from the country park
through to the KDNL, thereby connecting both existing and new residents with the landscape.
With regard to the Objectives, we welcome the requirement for the development to deliver a
landscape-led place and the prioritisation of active travel throughout the site

Comment Noted

Comment

Representation ID: 1473

Received: 15/12/2025

Respondent: Natural England

Given that ‘pockets of Ancient Woodland’ and ‘areas of ecological value and habitat’ are both
identified as key constraints, we are surprised that there is no reference to the retention and
enhancement of existing ecological features in the Vision nor any reference to the importance of
green infrastructure in connecting these areas in either the Vision or Objectives.
We therefore recommend that a new section is added on page 49 of the SPD which outlines the
overall vision for the ecology, biodiversity and green infrastructure at the site.
In addition, paragraph 4.2.3. (Landscape-Led Exemplar) begins by outlining the need for any
development to be ‘genuinely landscape-led’ but then moves on to discuss the challenges and
opportunities of climate change. In our opinion, this feels like two separate parts of a vision with the
climate change aspect more suited to paragraph 4.2.5. We recommend that paragraph 4.2.3. is
amended to be solely landscape focused and highlight the opportunity to reference KDNL here.

5.2.4
'It is expected that the residential area of the
site will be defined by key character zones,
each zone with a range of densities and
mixture of typologies and tenures. Further
detail on this will be established through a
Design Code that is to follow the SPD as part
of the planning application process'
In our view the design code should form part of the SPD, given
that the SPD is being produced to shape the delivery of the
garden community. This will guarantee that any development that
comes forward will be in line with agreed design principles. Of
particular concern is the development proposed along the M2
corridor given its location in the setting of the KDNL.

5.3.4
'The semi-natural and natural green space is
to be consolidated at the eastern and
western sides of the site to enhance
ecological connectivity. This work is to evolve
through the design code as more evidence
emerges in that process'
As mentioned in our comments on the draft SPD in May 2025, it
is unclear what is meant by consolidating semi-natural and
natural green space 'at the eastern and western sides' and we
therefore recommend that this is clarified.
It is also unclear how this has followed through to the Green &
Blue Infrastructure Framework (Figure 23), as seminatural/natural green space is not marked and 'public open
space' is evenly spread out across the site.

5.3.5
‘Proposals should start with the landscape
responding to the site being in the setting of
the KDNL and the Capstone Valley. As such
open space buffers to the south of the site
should be created that conserve and
enhance the KDNL and reflect that the site
sites within the setting of it as per the site
policy’
We are pleased to see the requirement for open space buffers to
conserve and enhance the KDNL, however we recommend that
these are in accordance with both the KDNL Management Plan
and special qualities to ensure they are delivering against the
aspirations of the National Landscape.
In addition, we ask that these buffers are clearly marked on
Figure 23 and that a minimum acceptable width of open space
buffer is agreed as part of the SPD.

Figure 23 & 5.3.7
‘The site has distinct pockets of biodiversity
value with habitats located across the site
but also wider connectivity as suggested
through the LNRS. Open space corridors
seek to reflect this and should be maintained
in the development’
We recommend that the ‘distinct pockets of biodiversity value’
are clearly marked on Figure 23, as they have been in Figure 20,
to promote both their retention and the potential for these to
connect with new green infrastructure.

Figure 24
While we welcome the focus on providing active travel routes
through the development to encourage sustainable journeys, we
are concerned that the bridge connection to the southern parcel
does not appear to be highlighted as an active travel route.
Though we acknowledge that connectivity is required for vehicles
exiting the M2, it is important that a safe and enjoyable route is
provided for pedestrians who want to access the proposed
recreational space in the southern parcel.

5.5.2
In terms of heights it’s also proposed to have
higher buildings towards the centre of the
site around the local centre with smaller
buildings on the edges, especially adjacent
to the M2 Motorway to minimise impact on
the KDNL’
While we support the use of lower building heights on the
southern boundary of the northern parcel, it should be recognised
that other design elements such as building orientation, massing,
form and colour will also help to minimise impact upon KDNL.
Ideally these design elements would be agreed as part of the
SPD through a Strategic Design Code embedded within the
document, similar to the work that has been done for Innovation
Park Medway.

Figure 25
Despite stating in paragraph 5.5.1 and 5.5.2 that density will
taper from the edges and lower building heights will be used on
the southern boundary, the majority of development parcels in
this area are marked for medium density (30-40 dph).
Higher density development can be more visually intrusive and
make it harder for mitigation to be effective. We therefore
recommend that buildings in the immediate setting of the KDNL
be lower in height and density to ensure a sensitive transition.

Figure 26
Given that 'all planning applications must conform to the
framework set out by the masterplan' (paragraph 5.6.3), we are
concerned that the location of the green bridge has not been
indicated on Figure 26.
The provision of a green bridge across the M2 is required by
LPRSP4(B) 3.h.iii and is key to creating a sensitive transition
from the KDNL to the development site, as well as provide a high
quality experience for recreational users accessing the public
open space to the south of the M2. In our view, the green bridge
should be incorporated into the new M2 connection at Junction 4
to maximise benefits for both people and nature, as modifying the
existing bridge connections will limit what can be provided.

Comment noted.
The Vision is replicated from the Local Plan Review.
Officers agree that the relationship to KDNL should be acknowledged within the objectives.
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme and taken collectively provide sufficient clarity around design expectations and that of a design code. The code coming forward prior to reserved matters will still ensure good quality design aspects are embedded when the site is delivered.
Officers agree that reference to existing wildlife corridors should be included and that expectations for future planning applications should be further clarified in relevant sections of SPD (this is dealt with under the open space section)

Comment

Representation ID: 1474

Received: 15/12/2025

Respondent: Natural England

We have provided our comments on the framework plans in Annex 2 below

Comment Noted

Comment

Representation ID: 1475

Received: 15/12/2025

Respondent: Natural England

6.2.2
'This [design codes] can provide greater
certainty for communities about the design of
development and bring conversations about
design to early stages of the planning
process rather than the end'
Though we agree with this statement, in our view delaying the
Design Code to after outline permission does not constitute
bringing conversations about design to the early stages of
planning. As advised above, we believe that the Design Code
should be developed and agreed as part of this SPD and
definitely prior to the submission of an application for outline
permission to ensure good quality design across the site and
particularly in areas adjacent to KDNL.

Key Principles/Guidance Pg 65
'(a) ...The Design Codes shall be broadly in
accordance with the Lidsing Garden Community SPD’
‘(f) The preparation of Masterplans and
Design Codes must be informed by the
appropriate design review and assessment
frameworks such as the National Design
Guide, National Model Design Code, Building
for a Healthy Life and Building for Nature, or
similar’
It is unclear what is meant by point (a) as, in our view, there is
limited guidance provided in the SPD with regard to design, other than deferring this to post-outline consent stage. We believe that
the Lidsing Garden Community SPD should include a detailed
design code to ensure clear design parameters are agreed prior
to a planning application being submitted. We therefore
recommend that either the SPD is revised to incorporate a
detailed design code or a separate design code is drafted and
agreed prior to the submission of application for outline consent.
In addition, we would expect reference to the relevant KDNL
planning publications and design guidance under point (f).

The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
The SPD sets out guidance and principles across a number of key themes and topics, especially within 'Section C: Placemaking & Design Guidelines'. Each theme has a clear section which sets out 'Key Principles/Guidance' specific to each theme and taken collectively provide sufficient clarity around design expectations and that of a design code. The code coming forward prior to reserved matters will still ensure good quality design aspects are embedded when the site is delivered.
In terms of specific references to KDNL, the Design code will need to take into account the SPD and local plan policy which provides sufficient reference to KDNL.

Comment

Representation ID: 1476

Received: 15/12/2025

Respondent: Natural England

6.4.3
‘A sensitive transition between the
development and the KDNL must be
provided. Mitigation will be carried out by
generous appropriate planting, a minimum
15m buffer zone and appropriate use of
scale and form of adjacent buildings.’
We strongly support the inclusion of wording requiring a sensitive
transition between the development and KDNL, and suggest that
this is included within the ‘Key Principles/Guidance’ section given
its importance.
While we are pleased to see a minimum buffer zone being
proposed, it is unclear where this applies as it is not referenced in
requirement (c) of the Key Principles/Guidance but is referred to
in requirement (a) in relation to ancient woodland.

Key Principles/Guidance Pg 69
‘(c) Landscape buffers shall be provided to
the major transport corridors of the M2 and to
the KDNL to the south. The form of planting
and landscaping shall be informed by noise
surveys and discussions with KDNL and
adhere to the following:
• Prioritise structural planting to the
south along the boundary with the M2
motorway using species of trees that
create large crows such as oak or
beech.
• Allow opportunities for community of
access.
• Building design should be diverse in
order to break up the massing along this boundary'
As mentioned above, it is unclear from this wording whether the
proposed landscape buffers will be required to be 15m in size as
inferred in paragraph 6.4.3.
We are also concerned that little detail on top of what is required
by LPRSP4(B) has been given on the form of planting and
landscaping at this stage. We recommend that further detail is
given on the landscape buffers to the north of the M2, similar to
what has been provided in Figure 29.
In addition, we ask that the word should in the final bullet point is
changed to must.

Comment noted.
The requirement for a landscape buffer along the M2 is included in the guidelines and principles for Landscape at Chapter 6.4. Officers agree that the need for a buffer along the M2 should also be made clear on Figure 23: Green & Blue Infrastructure Framework.
Officers agree that an additional principle should be added to Chapter 6.4 (Landscape) to more clearly relate to criterion (H)(V), (VI) and (VII) of Policy LPRSP4(B).
It is not considered appropriate for more detailed guidance on planting to be included within the SPD, this can come forward through the planning application and design code process.

Comment

Representation ID: 1477

Received: 15/12/2025

Respondent: Natural England

Figure 30
As discussed in our comments in row 8, the relevant framework
plan(s) should clearly indicate where pedestrian access is
expected to be provided so that both existing and future residents
can access the green space south of the M2

Key Principles/Guidance Pg 73
‘(e) Sports provision is to be located to the
periphery of the site to enable its use by
existing communities in Medway and
Maidstone Boroughs’
We note from Figure 30 that some sports provision is planned
within the employment area to the north of the site. It should be
highlighted that any sports provision in this area should consider
impacts to KDNL, in particular from lighting (e.g. floodlights).

Figure 31
We are pleased to see an indicative plan for the Land South of
the M2 (Junction 4) has been included in the SPD however our
comments from the draft SPD consultation (May 2025) still stand.
We have included them below for ease of reference:
In order to deliver policy LPRSP4(B) 3 c, e, h. iii., and vi there
could also be a strong GI and active travel element by connecting
the north and south buffering of the M2 with a green bridge.
It would be helpful if clarity can be provided as to the reason for
the location of the SuDS detailed on Figure 31.
We also recommend that the scale of the propoed woodland in
Figure 31 and how the proposed woodland has been informed by
the landscape character of the area are clarified.
Natural England suggests it would be helpful to have more than
one cross section for Figure 29, for example in a southeast to
northwest direction i.e. the direction of the view from a higher
elevation of the KDNL to the M2 Junction 4. This is to better
understand what the view of the landscape from higher up in the
KDNL following mitigation will be.

6.5.7
‘The definition [of a green bridge] boils down
to the following:
‘an artificial structure over road or rail
infrastructure which is either vegetated or
provides some wildlife function’.
It can take the form of a modified bridge or
new structure and can be used by a range of
modes or none.’
Instead of focusing on technical definitions of a green bridge, we
recommend that your authority utilises the Landscape Institute’s
Green Bridge Technical Guidance Note to expand upon what
your authority expects from the green bridge and include this
within the SPD. This will enable certain design considerations to
be pinned down at the strategic level, which should result in
better outcomes once delivered.

Key Principles/Guidance - continued Pg 77
‘(a) The land to the southern of the M2
junction 4 is to follow several key principles:
• Land to be used for highway
improvements is to be screened by
trees.
• The remaining land is to be
accessible by the community,
especially walkable from Bredhurst
Village and maintained as open
space.
• Respect the setting of listed buildings
within the vicinity’
We recommend that the following is added as an additional bullet
point:
• Land should integrate with the KDNL and
demonstrate how it is achieving its key objectives.

Key Principles/Guidance - continued Pg 77
‘(c) access from the development to the
Capstone Valley shall be provided in two
ways:
• Via active travel (walking and
wheeling) to be provided from the site
towards the Capstone Country Park.
• Wildlife connections as identified in
the Green and Blue Infrastructure
Framework Plan.’
We are pleased to see that access to Capstone Valley Country
Park has been considered within the SPD and encourage your
authority to work with Medway on the following:
• Potential for linking the development with the country park
via other proposed developments in the area.
• How any increased visitor use from Lidsing will be
accommodated and whether any additional funding will be
required.
We strongly support wildlife connections through the landscape
but recommend that these are more clearly shown on the Green and Blue Infrastructure Framework Plan, for example highlighting
areas of existing green space that must be retained and where
connections can be made.

Key Principles/Guidance - continued Pg 77
‘(e) a green bridge connection shall be
developed over the M2 motorway connecting
the site to the KDNL:’
Though some principles have been established, we are
disappointed that the plans for the green bridge have not
advanced much further from the Local Plan Review stage. In our
view, the M2 Junction 4 improvement works provide an ideal
opportunity for an exemplar green bridge to be provided that not
only boosts ecological connectivity but encourages a sensitive
transition to the KDNL, thereby providing additional mitigation for
the improvement works, and engages people with the landscape.
We strongly recommend that the location of the green bridge is
determined as part of the SPD as a minimum and further detail
provided on what the green bridge should include (e.g. what
modes of transport will have access, are there particular
habitats/species that should be targeted etc.).
We would encourage a design which provides a high quality
pedestrian experience, allowing those who want to, to access the
new open space in the southern parcel and the wider KDNL
without the need for a vehicle. This will enable users to
experience the natural environment and a continuity of seminatural habitat from the KDNL into the development site.

Comment noted.
Officers agree that reference to existing wildlife corridors should be included and that expectations for future planning applications should be further clarified.
Further acknowledgement of proportionate contributions to secondary education should be included however it should be noted that the SPD can’t result in additional financial burdens beyond those already identified in the Local Plan.
Further detail on the location of the SUDs is provided in the Green and Blue infrastructure background paper.
The height parameters identified within the SPD are consistent with the Local Plan. Further consideration of impacts on the KDNL, with associated drawings and cross-sections will will come forward through subsequent planning applications.
The Framework Plans set out at Chapter 5 of the SPD capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site, including specific details for the Green Bridge and the technical guidance is referred to in para 6.5.7.officers agree that criterion a of the open space guidelines can be updated to refer the KDNL.

Comment

Representation ID: 1478

Received: 15/12/2025

Respondent: Natural England

Key Principles/Guidance Pg 81
Active Travel: (a)-(e)
While we agree with each of these principles, we recommend
that they are strengthened to replace the word should to read
either must or shall.

Key Principles/Guidance Pg 81
‘(q) …The primary street should be designed
to support ecological linkages across the site
including allowing for wildlife movement’
As above, we recommend that the word should is replaced with
either must or shall.
In addition, it should be noted that there are opportunities for
secondary streets to provide ecological linkages for example
through the provision of street trees and/or living verges. This is particularly important as there appears to only be one primary
street proposed on site which is located more towards the north
of the site when, ideally, ecological linkages would be provided
throughout.
While ecological linkages maximise biodiversity across the site,
they provide multiple benefits for example, climate change
adaptation through natural cooling and flood risk management.

Comment noted.
Officers consider that the guidelines provided sufficient clarity to inform development proposals