Heathlands Garden Settlement SPD

Comment

Representation ID: 636

Received: 12/12/2025

Respondent: Lenham Parish Council

Under the heading Employment /Commercial the Local Plan Review (LPR) policy LPRSP4(A)4(a) states that:

“Development should aim to provide for as close to 5000 new jobs as feasible and viable.”

To achieve this objective policies 4b and 4c stipulate that a new district centre should be provided and two new local centers on a phased basis including appropriate employment-based provision.

Policy 4(d) states that a minimum of 14 ha of dedicated new employment land should be provided. The phasing provisions simply state that phase 1 employment land should be delivered within the first phase 2031-2037 but does not specify the quantum of this first phase provision.

At paragraph 118, the Inspector in his report states that:
“One of the key tenets of garden communities is creating a level of self-containment including in relation to employment opportunities……”

The parish council is disappointed that the SPD does not contain an up-to-date evidence-based market report on the suitability of the Heathlands site to support anything like the amount of employment needed to secure a reasonable level of self-containment.

The parish council notes under the key principles/guidance section of employment in the SPD at page 71 paragraph a, the provision of 14 hectares a new dedicated employment land is downgraded to become only a mere “target”. This is just one example of the SPD “dumbing-down” the requirements in order to fit some perceived level of deliverability.

Throughout the Stakeholder Steering Groups (SSG) this was a concern the parish council consistently raised.

By comparison, the parish council notes that at Lidsing (LPR SP4(B)4) under the heading Employment/Commercial “14 ha of new employment will be provided in order to deliver 2000 new jobs noting that the Lidsing site has excellent connectivity to the Strategic Road Network” (M2). No such claim of connectivity is made in the corresponding section for Heathlands.

At Lidsing 14ha of new employment land is proposed to provide 2000 new jobs to support 2000 new homes. At Heathlands 14ha of land is proposed to support 5000 new homes. This obvious discrepancy is tantamount to an admission on behalf of the local planning authority that it will not be possible to provide anything like 5000 new jobs at Heathlands. The claim of self-containment necessary to achieve garden community principles as set out by the Inspector cannot and will not therefore be achieved.

The fact is that in mid Kent significant concentrations of new business and employment land are located on the major motorway junctions. The most obvious example of this is the new employment development which is being established at junction eight of the M20 (Loc8). The original concept was that Heathlands would benefit from a new access to the M20, this aspiration was quickly dismissed by National Highways and the resulting chaos of trying to mitigate the loss of this vital aspect is being postponed to any “outline planning application” to address.

The parish council regards the fact that the initial proposals for Heathlands included a new motorway junction as tacit acknowledgement on behalf of the local planning authority that such a new motorway junction would be the minimum infrastructure requirement in order to make a garden community at such an isolated location work in practical terms. That this is missing raises further concerns about viability and the potential creation of a future area of concern.

The parish council has and still finds this approach raises serious concerns about deliverability and viability.

Without an evidence-based review of the market demand for new employment land and the economic viability of its provision the parish council finds it very hard to accept that such significant employment land could ever be provided at a remote location such as Heathlands, which is a significant distance from any motorway junction.

The parish council considers that any attempt to provide employment land at Heathlands will simply become a burden on the economic viability of the project rather than an addition to the net incoming revenues.

The parish council has consistently maintained that without the provision of adequate employment provision, the proposed development at Heathlands would simply become a dormitory commuter settlement heavily reliant on commuting for essential journeys to work. The majority of these journeys would inevitably have to be by private motor vehicle.

Without a clear, evidence-based assessment of employment demand and viability, it is unlikely that Heathlands can provide the required level of employment. Consequently, the site risks becoming a predominantly commuter-based settlement, failing to meet the Garden Community objectives of self-containment.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established that the development should aim to provide for as close to 5,000 new jobs as feasible and viable. The wording is exactly the same as that in the Local Plan Review.
Section 6.10 sets out guidelines and principles for employment, and the types of new employment space to be provided.
Future planning applications will need to consider and address all issues and requirements.
Appendix C of the SPD sets out the anticipated planning application requirements which includes the need for an ""Employment & Economic Strategy"" to establish a strategy to consider commercial opportunities and business sectors in more detail.

Comment

Representation ID: 637

Received: 12/12/2025

Respondent: Lenham Parish Council

In the section on phasing and delivery Local Plan Review policy LPR SP4(A) states that infrastructure for transportation will be delivered in accordance with the following statement:

“Necessary off-site highway mitigation to align with Monitor and Manage Strategy”
As part of the preliminaries phase the infrastructure being delivered includes:
“Railway Station business case complete and Strategic Outline Business Case Approval and Approval in Principle for a new rail station”

As part of phase 1 2031-2037 up to 1,310 homes infrastructure to be delivered includes:
“Railway Station delivered”
“North-West access into development site from A20, enabling vehicular access including bus services”

Appropriate bus links to the District Centre and neighbouring villages is now delayed until Phase 3 to 2048 (3,758 homes cumulative total).

Under the heading “Phasing and Delivery” section 7 of the SPD declines to provide better definition or clarity on the issue of phasing simply stating that the LPR phasing requirements are carried forward into the SPD (paragraph 7.2.3). Paragraph 7.2.4 goes on to state that further definition of the timing-related triggers and thresholds for infrastructure will emerge at the planning application stage.

The parish council is deeply concerned that the SPD fails to provide any substantive detail on the phasing strategy set out in the Local Plan Review. As a result, the current framework would allow up to 1,310 homes to be constructed before the railway station is delivered and before the north-west access is in place to support the operation of effective bus services. This issue was raised repeatedly throughout the SSG meetings, yet it has not been addressed in the SPD.

In its letter dated 19 March 2024 Kent County Council (KCC) requested that sustainable transport measures should be put in place earlier during the development phasing in order to create a more sustainable pattern of transport use from the earliest establishment of the new community. Such early provision would be fully in accordance with established garden community principles.

The parish council fully shares the concerns of KCC, as Highway Authority, that the proposals do not support early delivery of public transport to establish sustainable transport patterns for residents to support the development.

The parish council is disappointed that the SPD has not taken the opportunity to provide sub phases for the development within the first phase and to more precisely link the provision of infrastructure to early sub phases within the development proposal.

Given that KCC, as Highways Authority, will not publish work on the new Transport Model until spring of 2026, the parish council believes that the SPD should be withdrawn, and more work should be undertaken in this critical area once this new model is available. That would allow local residents to understand the full impact of the development proposals and the implications of over 1000 houses being built over a minimum 12-year period before the necessary sustainable transport measures are put in place.

Moreover, the Heathlands SPD Annex-Transport is dated 10 September 2025. Paragraph 6 states that more work will be completed at Outline Planning Application stage at which time there will be greater certainty around the phasing and location of land uses within the development which will allow a more detailed assessment to be undertaken.

The parish council maintains this more detailed assessment should be included within the current SPD. Local residents are not able to understand the full impact of the proposal because greater clarity and detail of the distribution and location and quantum of land for development has not been included at this stage in the proposals.

Under the heading Highway Network, the Transport Annex at paragraph 17 lists only six junctions that have been assessed within the scope of the SPD TA. Paragraph 18 acknowledges that these 6 junctions generally operate with limited congestion currently, however the Annex states:

“…. It is understood from discussions with KCC and anecdotal evidence that some sections of the A20 experience extensive slow-moving traffic especially those closest to M20 junction 8”

The parish council is astounded at this admission.

Local residents are fully aware that the A20 operates with extensive and often daily slow-moving traffic and that the A20, in the vicinity of M20 Junction 8, experiences significant backlog and delays at the peak hours on a daily basis.

The highway network is incapable of operating when diversions are in place due to difficulties with Channel Tunnel, as well as during the implementation of Operation BROCK which turns the coast-bound carriageway of the M20 between Junctions 8 and 9 into a lorry park, a traffic situation which occurs frequently throughout the year. When the A20 is currently operating at or close to capacity it is inconceivable that the addition of 5000 houses and additional employment development at Heathlands would result in anything other than gridlock on the local highway network.

Paragraph 21 of the Transport Annex lists eight rural local lanes to the south of the site and states that these range from 2.5 m wide to 5.5 m wide. Paragraph 23 states that the roads to the north and south of the site and the routes through Lenham will be considered in greater detail as part of a comprehensive impact assessment within the TA which would accompany the outline planning application.

This work needs to be undertaken now, at this stage in the proposal, in order to try and reassure local residents that the overall impact of the proposal will not result in gridlock on the local rural lanes (which are acknowledged to be as narrow as 2.5 m).

Local residents are fully aware of the inadequate capacity of the network of local rural lanes and the desire-lines to travel to destinations to the north, for example Sittingbourne, Faversham, Whitstable and Canterbury, and to the south, to Headcorn and Tenterden. Unlike Lenham railway station, the station at Headcorn currently provides attractive and fast train journeys to both London and Ashford as well as ample parking provision.

Paragraph 26 of the transport annex acknowledges that the NPPF, at paragraph 116, states that development should be refused on highways grounds if there would be an unacceptable impact on highway safety or the residual cumulative impacts on the road network, following mitigation would be severe considering all reasonable future scenarios.

At this stage in the development of the proposals, the necessary mitigation has not been assessed and published for comment. It is therefore not possible to ascertain whether there will be an unacceptable impact on highway safety.

Without some overview of the overall impact of 5000 new houses and associated employment on the local highway network the SPD does not comply with government policy in that it does not consider “all reasonable future scenarios” when assessing development impacts. With that requirement in mind, the SPD does not take account existing sites, for example with the recent announcement by Panettoni of its additional location to the former Aliaxis / Marley site, north of the A20 at Lenham, and the additional impact on the road network this will generate.

Any work which has been undertaken on highway capacity is at best limited and sketchy. Bearing in mind the highly unlikely provision of the required 5000 new jobs, the extent to which the self-containment which has evidently been modelled being achieved in reality is highly unlikely, resulting in even more trips on a local highway network which is already acknowledged to be at or close to capacity.

The proposals require the delivery of a new railway station, nutrient neutrality mitigation, a country park, a new secondary and two primary schools and a new, or significantly upgraded wastewater-treatment facility complete with cordon sanitaire to provide an acceptable living environment.

At paragraph 134 of his report the Inspector states that the viability work included approximately £100 million for such infrastructure.

The parish council believes this estimate completely understates what the actual cost of provision of infrastructure is likely to be.

Even if that estimate was accurate in March 2024, when the LPR was adopted, the parish council is disappointed and concerned that the SPD has not taken the opportunity to provide better and up to date detail on the nature, scope, cost, location and land take of all these essential items of infrastructure.

The plans and timing of delivery of so – called “blue infrastructure”, that is addressing the issue of waste removal and foul water treatment and run off, is entirely absent in any reasonable form in this SPD.

Based on current experience of similar projects elsewhere the Parish council believes the cost of such infrastructure to be well in excess of £250 million.

If MBC and its delivery partner, Homes England, disagree with the parish council’s assessment, they are challenged to provide realistic, evidence-based figures, including clear sources for the substantial funding required. Experience from comparable developments in the surrounding area demonstrates the difficulty—and often futility—of relying on s106 contributions to meet such significant financial obligations.

Comment/Objection noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure.
Officers agree that additional wording should be included to also refer to infrastructure being required as early as possible within phases, and to establish both a 'Planning & Infrastructure Delivery Group' and 'Transport Steering Group' to oversee infrastructure delivery across the site.
Figure 19 at Section D of the SPD replicates the required phasing of development and associated infrastructure as was set out in the adopted Local Plan Review - nothing has been amended or delayed from that as set out in the adopted Local Plan Review.
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.
Infrastructure will be secured through the use of planning conditions and legal agreements, as part of the consideration and determination of future planning applications.

Comment

Representation ID: 638

Received: 12/12/2025

Respondent: Lenham Parish Council

It is proposed to construct 5000 additional new homes at Heathlands. The parish council fully accepts the need for additional housing to be provided both within England and within Kent.

However, the parish council is concerned that development might not proceed at Heathlands at the rate which is envisaged meaning that the necessary funds from developer contributions will not be available to provide essential infrastructure in a timely manner as envisaged in the LPR.

Over recent decades housing completions within Lenham parish have averaged in the region of 80 houses per annum. This is at a time when there has been good market demand and development sites have been available throughout this period.

The parish council is concerned that the SPD does not include any up-to-date market analysis of the demand for housing at this isolated location nor the rate at which sales might proceed. There have been significant changes within the economy since the LPR was first produced. Interest rates are now much higher, and construction costs are significantly higher than they were previously.

The parish council therefore regards the SPD as incomplete at this stage because it does not contain any market analysis of the current demand for housing, the prices which might be achieved and the rate at which the market houses could be sold. It remains unconvinced that the ambitious and untested claims for uptake as set out within the SPD carry any weight at all.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which allocated the site and required the preparation of the SPD.
Matters to do with housing need and supply and the viability of the proposal were considered during the examination of the Local Plan Review and are not matters needing to be revaluated to prepare the SPD. These issues will be considered through the preparation of the next Local Plan for Maidstone Borough.

Comment

Representation ID: 639

Received: 12/12/2025

Respondent: Lenham Parish Council

It is proposed that 2000 affordable houses should be provided within the development. The parish council supports in principle the provision of affordable housing. However, Lenham is a location remote from hospitals, larger shopping centers, employment and a range of educational facilities. Many of the occupants of affordable housing will be more used to an urban environment where such facilities would be within easy walking distance or a short and affordable journey by public transport.

The parish council therefore questions whether it is fair and equitable to provide 2000 affordable houses which, by definition, will be occupied by lower income families at a location which is both expensive and time-consuming in order to access the range of facilities which such families might be used to and might have reasonable expectation of securing access to in the future.

We have always maintained the need is for the right homes in the right place, Heathlands does not meet that requirement.

The parish council is disappointed that the SPD does not contain an updated analysis of the market requirement for affordable housing bearing in mind the changes in economic circumstances which have been experienced in recent months.

Therefore, it is not possible to understand whether the providers of affordable housing will be willing and able to take up the offer of housing at this remote and expensive location. It is generally acknowledged that the delivery of housing is currently being held back because of the requirement to provide affordable housing and because of the lack of providers of affordable housing with the capacity, funds and ability to take up the sites and deliver such housing. The policy requirement to provide 2000 affordable homes might, over time, turn out to be a significant barrier to the delivery and viability of the project.

Our assessment of this promise is that it is one which, most likely, will be quietly dropped due to the financial pressures needed to deliver it.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure, which includes new schools and health facilities and wider infrastructure.
The SPD contains a range of topics including (at 6.9) the approach to 'Social & Community Facilities' which must include a wide range of services including new schools and a health centre to address the needs of an increased local population.
Matters to do with housing need and supply were considered during the examination of the Local Plan Review and are not matters needing to be revaluated to prepare the SPD. These issues will be considered through the preparation of the next Local Plan for Maidstone Borough.

Comment

Representation ID: 1141

Received: 12/12/2025

Respondent: Lenham Parish Council

Please see attached Appendix 1 - Lenham Parish Council Technical Assessment of the Heathlands SPD

Various suggested amendments are noted in Appendix 1.
Officers would note that the incorrect reference to '3.1 Location Boughton Road' was an incorrect sub-title within the online version of the SPD only and will be correct within any final SPD.
Officers agree that the recognition that existing roads through the site are rural in character should be acknowledged.
Officers agree that the reference to the phasing of the rail station should be amended to align with the phasing set out in the LPR and at Figure 18.
Officers consider that the various other suggestions go beyond the policy basis as set by the LPR and therefore cannot be addressed by the SPD.