Heathlands Garden Settlement SPD

Comment

Representation ID: 781

Received: 15/12/2025

Respondent: Kent County Council

Highways and Transportation
The County Council recognises that the Heathlands Garden Settlement forms a site allocation within the Borough Council’s adopted Local Plan Review covering the period 2021-2038.
The requirement for an SPD to be produced, is embedded within site allocation Policy LPRSP4(A) of the Local Plan. Its inclusion reflects the scale and complexity of a new Garden Settlement.
The SPD is founded on a vision-led approach to transport provision, which is aligned with the National Planning Policy Framework - Guidance - GOV.UK (NPPF) and Local Transport Plan 5 (LTP5). By identifying the key principles that should underpin sustainable, mixed-se development within the local context, it provides a valuable means of shaping the future planning applications.
The County Council, as Local Highway Authority, has actively engaged with the Borough Council, National Highways and site promoter throughout the preparation of the SPD and the supporting Transport Assessment.
This collaborative approach has ensured the content of the SPD is based on a shared understanding of the transport priorities and issues to be addressed in the future planning application. Importantly, a requirement for updated strategic traffic modelling using the Kent Transport Model has been included to inform the detailed assessment of impacts and potential mitigations.
The County Council is supportive of the vision and objectives of the SPD and how they aim to deliver a sustainable new community with walking, cycling and public transport connectivity provided within the site and to surrounding communities. Importantly, the provision of a new rail station is included as an integral part of the vision.
The County Council would ask that the vision and objectives should emphasise the imperative of all transport infrastructure, including the rail station, being delivered in a timely manner. Such delivery is fundamental to creating the connected, walkable, vibrant and sociable neighbourhoods the SPD describes.
The County Council would question what the likelihood is of this station being developed and in light of this would make the following comments:
•
The County Council understands that Network Rail has been engaged by the Lenham Heathlands development vehicle to develop proposals for a new station. Network Rail will likely be responsible for constructing a station for Lenham Heathlands, if funding is provided to them to do so.
•
The County Council understands that Network Rail has not objected in principle and the County Council is not aware that Southeastern trains has either.
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Southeastern will be responsible for agreeing with Network Rail the volume of services that can stop at a new station and requirements about the station’s facilities. It is important that Southeastern are engaged on the station delivery from this early stage.
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The DfT, as funders of Southeastern and Network Rail (both essentially government owned), will also likely have input about the station and its services.
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Creating new station stops on a route adds time into the timetable, meaning the train and train crew resources needed by the operator can increase. It is possible that works additional to station construction could be necessary if Network Rail and / or Southeastern deem it so, to offset the additional stopping time. This was the County Council’s experience with the delivery of the new station Thanet Parkway.
•
The development is expected to cover the capital cost of the station and should consider that it may be required to cover the operating cost of the station if its revenues are not sufficient.
•
The Maidstone Local Plan established a need for a station. No other need for the station had been identified prior to the Maidstone Local Plan proposing the Lenham Heathlands Garden settlement. The need for the station is entirely dependent on the development.
•
It is possible that Maidstone Borough Council (MBC), who are involved in the case for developing the station as part of their local planning authority role, may have an opportunity to seek funding support from government funds. The County Council’s expectation, however, is that the Government plans to end competitive funding routes such as were used for Thanet Parkway station. That would leave local funding sources as the only likely alternative to development-linked funding.
•
The County Council does not know how much the proposed station would cost as it is not privy to the extent of design work and surveys, risks identified etc. that have been determined for Lenham Heathlands station to date. The County Council’s experience and wider benchmarking nationally with station scheme delivery is that each station site can have unique challenges that drive costs. Planning permission and other approvals can add time and cost to station delivery. The overarching trend nationally is that stations are relatively expensive public transport improvements that frequently require grant funding support.
In light of the above and given the lack of information in the draft SPD, it is currently unclear as to what would occur if the Lenham Heathlands station suffers either significant delay or is not delivered at all. The County Council would therefore strongly advise that the SPD be revised to set out what mechanisms will be used to control development in relation to the presence of a new station, and also set out in the Monitor and Manage strategy, planned alternative mitigations and their cost and ensure it can be demonstrated that the station and alternatives in its absence can be funded.

Public Rights of Way (PRoW)
The Public Rights of Way and Access Service (PROWAS) is pleased that the existing PRoW network is acknowledged and that the ambition of the SPD is to integrate existing provision into greenspace, encourage connection to the network with new provision and to encourage its use for utilitarian journeys and recreational use.
The County Council would ask that the Rights of Way Improvement Plan - Kent County Council is referenced.

6.11 Movement and Connectivity
Highways and Transportation
The County Council is supportive of active travel modes being placed at the forefront of the layout and design, with priority being afforded to pedestrians and cyclists over other road users. Such an approach is essential to encouraging healthy and sustainable lifestyles in preference to car use.
The guidance reinforces the necessity of early delivery of the rail station in Phase 1, as already discussed above. The County Council agrees that the station must be operational at the earliest opportunity in order to maximise its influence on travel behaviours.
The inclusion of a route that enables buses to divert through the site via the District Centre, rail station, local centres and mobility hubs is welcomed. The County Council
supports the principle of all residential and employment buildings being within 400m of the bus route to aid convenience.
The guidance highlights the need for the early delivery of the bus route. This is supported in how it offers scope for a co-ordinated approach to public transport provision in tandem with the rail station, whilst also enabling bus services to be made available at the outset.
It is noted that the bus route will be designed to afford buses priority over other vehicles. The County Council agrees that priority of movement will assist service reliability, whilst also minimising the additional journey time for existing passengers on diverted services and potential additional operating costs.
The need for developer subsidy of bus services and free or discounted travel to encourage use is agreed. The inclusion of mobility hubs as focal points for travel interchange and goods delivery/collection is welcomed. The principle of vehicular access via the A20 corridor is supported.
The County Council is supportive of the ‘Monitor and Manage’ approach to off-site highway improvements, which is aligned with national policy and provides an ongoing basis for reviewing the extent and timing of required mitigation interventions.
The Transport Assessment has confirmed the suitability of the proposed improvements at key junctions along the A20 corridor, including M20 J8. These improvements will form part of the ‘Monitor and Manage’ process to determine whether they should be implemented to mitigate the impacts of the development, alongside potential interventions elsewhere on the highway network. This approach affords scope for alternative interventions to be identified that prioritise sustainable travel modes, subject to County Council agreement.
The guidance has also included a requirement for measures to discourage vehicles from using local minor roads. The County Council regards this as an essential component of the transport package, during both the operational and construction phases, in view of the potential implications of additional vehicle movements on highway safety.
It is noted that paragraph 6.11.12 acknowledges how delivery of the rail station will involve separate processes with rail stakeholders. The pace at which progress is made towards delivery is not therefore within the sole control of the site promoter or developer.
As discussed above, the SPD does not address the potential for delayed delivery of the rail station or set out what mechanisms could be enacted to control the build-out of the development in its absence. The Transport Assessment, whilst acknowledging that bus services to Lenham and Headcorn rail stations could be required in advance of delivery,
does not elaborate on how these could be made available in a manner aligned with the SPD vision.
The SPD must therefore confirm how the ‘Monitor and Manage’ strategy will include planned alternative mitigations. The SPD should also confirm that the cost of the station and alternative provisions in its absence can be funded.
The guidance should identify the need for the off-site sections of the bus route to be reviewed to identify whether measures are required to prioritise or assist bus movement. This reflects the importance of the door-to-door journey time of the service in comparison to that of the car, which has an overall bearing on the attractiveness of the service.
The SPD should clarify how the Mobility Hubs will be adequately funded and maintained by the developer(s) in perpetuity.

Comment noted.
The Vision is replicated from the Local Plan Review and includes references both to the importance of the rail station and to promoting sustainable movement.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure, including the need for a railway station as part of Phase 1, as set out in Figure 19.
The delivery of the station will be a matter that future developers and planning applications will need to address, and remains a key policy requirement. Officers do not consider it appropriate set out wider alternative mitigation approaches should the delivery of the rail station be delayed.

Comment

Representation ID: 782

Received: 15/12/2025

Respondent: Kent County Council

Waste Management
The County Council is the Waste Disposal Authority (WDA) in the area and as such has a statutory duty to provide Household Waste Recycling Centres (HWRCs) and Waste Transfer Stations (WTSs) with sufficient capacity to accept arisings from across the county. MBC is the Waste Collection Authority (WCA) in the area responsible for kerbside collection.
The County Council’s response to the SPD for Heathlands Garden Settlement remains in keeping with our response to the Maidstone Local Plan and IDP. The nearest HWRC within the Maidstone area is Tovil HWRC. Tovil HWRC experiences seasonal variation in demand (at 60% overall capacity in winter, at 80% overall capacity in summer), but it is often at 100% capacity at weekends. The projected housing growth for the Borough as set out in the Local Plan, which includes Heathlands, will place additional demand and therefore mitigation is required. While not within the Maidstone Borough, Ashford HWRC is the nearest HWRC for the development. Ashford HWRC is predicted to be at capacity in the medium term due to the allocated growth in both the Maidstone and Ashford Local Plans. Developer contributions will be required to mitigate these impacts.

Circular economy:
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The SPD should explicitly reference KMWLP Policy CSW 3: Waste Reduction and require that major development at Heathlands Garden Settlement is accompanied by a Circular Economy Statement. This should demonstrate how waste prevention, material re-use and design for adaptability have been embedded in the scheme, in both construction and operation.
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The Circular Economy Statement requirement should include the submission of a waste management audit which includes the following information:
o
Quantities and an explanation of how waste will be minimised and managed during construction, demolition and any refurbishment; and
o
Details of how municipal waste and recyclables will be stored, collected and managed during the occupation and use of the development, in accordance with the waste hierarchy.
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Until the County Council publishes specific guidance on Circular Economy Statements, the SPD should signpost the Greater London Authority’s 2022 Circular Economy Statement Guidance as appropriate interim guidance for the content of such statements.
•
The design and placemaking sections of the SPD should be strengthened to:
o
Require building and layout design that facilitates high recycling performance (e.g. sufficient, convenient on-site storage for segregated waste streams and appropriate access for collection vehicles); and
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Encourage design approaches that support repair, adaptation and re-use of buildings and the public realm over the lifetime of the settlement, consistent with circular economy principles.
The Circular Economy Principle:
The KMWLP also contains Policy CSW 3: Waste Reduction, that is relevant to proposals for major development, such as a new settlement. Such proposals should be submitted with a Circular Economy Statement that demonstrates how waste reduction and where possible material reuse have been taken into account as part of the design and implementation of the development. This will include a waste management audit setting out how waste is to be managed during construction (including any demolition and refurbishment) and during the occupation and use of the development. Guidance on the content of Circular Economy Statements will be prepared by the County Council, though in the meantime, circular_economy_statements_lpg_0.pdf published by the Greater London Authority in 2022 can be regarded as appropriate to address this SPDs objectives. The SPD should be explicit with regard to this policy and the principle of the Circular Economy.
Energy and Climate
The County Council supports the concept of a ‘sustainably planned neighbourhood’ and hopes ‘inclusive living’ includes affordable low carbon heating systems and optimises potential for renewables to reduce the cost of bills further for our residents, including roof mounted solar where practicable.
Consideration should also be given to ensure homes are resilient to severe weather. Adaptation measures can be implemented to reduce risk in this area, for example using tree canopy coverage to aid prevention of overheating. This could be considered within the ‘blue and green infrastructure’ and ‘sustainable design and addressing climate change’ sections.

Comment noted.
The SPD references at Chapter 2.2 that the Local Policy framework includes the most up to date Kent Minerals and Waste Local Plan.
Officers do not consider it necessary to duplicate specific policies or aspects of policies as they will apply in any event as part of the adopted policy framework.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure which is replicated in the SPD.
Future planning applications will set out more details around the proposed layout of buildings, uses, infrastructure and other mitigations in light of assessments of impacts.
All future applications will be the subject of consultation and future decision making.

Comment

Representation ID: 783

Received: 15/12/2025

Respondent: Kent County Council

Broadband
From a digital infrastructure perspective, given that this development represents an additional 5,000 homes, the County Council would wish to ensure that there is sufficient dialogue with the three mobile network operators (EE, Virgin 02 and Three/Vodaphone) to ensure there is sufficient mobile coverage and capacity to accommodate the additional demand for network coverage and capacity that sizeable developments generate.
Failure to plan and ensure that sufficient infrastructure is in place at the time of completion risks the community facing mobile connectivity issues, or the additional demand denigrating existing coverage in the area. Retrofitting mobile infrastructure can be difficult to accommodate so the County Council would strongly urge that these provisions are made upfront.
Whilst it is understood that the requirement for full fibre broadband connectivity is addressed through building regulations, opportunities to uplift connectivity, where required, in immediate adjacent areas should be utilised through this SPD. The County Council has been concerned that some major schemes have installed networks where there is limited consumer choice and no option to use the new fibre infrastructure (e.g. through passive infrastructure access) to benefit any adjacent properties that cannot currently access full-fibre broadband services.

Comment noted.
The delivery of appropriate broadband technologies will be a matter that future developers and planning applications will need to address.

Comment

Representation ID: 784

Received: 15/12/2025

Respondent: Kent County Council

Heritage and Archaeology
It is the County Council’s view that Heritage and Archaeology is appropriately considered within the SPD and it is welcomed that one of the Key matters raised via the informal engagement was “The need to consider and respect local heritage, archaeology and the historic environment.”
The Heathlands Garden Settlement scheme is located towards the southern foot of the Kent Downs close to the source of the River Stour. One tributary feeding into the main Stour runs through and along the western side of the SPD site. Recent archaeological investigations just east of Lenham village have indicated this area was a foci for prehistoric, Roman and Early Medieval activity including ritual and industrial. Further archaeological work has indicated a major Iron Age and Romano-British site on Chapel Hill, with an enclosure and associated activity spreading across the fields. Chapel Farm itself is a known medieval manorial settlement which includes both upstanding designated buildings and buried structures in the fields. There is considerable potential for significant archaeology to survive on this site.
The current Kent Historic Environment Record (HER), indicates some significant archaeological sites within and close to the SPD. There is therefore an urgent need for preliminary archaeological desk-based and fieldwork assessments to ensure that any application at this site fully considers the historic environment fully and appropriately. This should be secured through the SPD.

6.5 Protecting Heritage and Archaeology
Heritage and Archaeology
The County Council strongly welcomes the guidance set out in paragraphs 6.5.3 and 6.5.4 but would stress at this stage that the requirement to avoid significant archaeological sites will be essential. The SPD guidance will be more robust and provide greater clarity if a “safeguarded zone” for the Chapel Hill Iron Age/Romano-British site and significant remains associated with Chapel Mill manorial site is established at this stage. The protection of these known sensitive sites should be recognised prior to masterplanning commencing and then fully secured within the masterplan. The Chapel Hill Iron Age/Romano-British site and Chapel Mill manorial site safeguarded zones need to be fully informed and appropriate.
The County Council also recommends the Key Principles/Guidance – Heritage Design include the following:
a.
Scheme design and masterplanning must be fully informed by suitable archaeological assessments and adhere to an evidence-based approach to heritage assets and their settings and demonstrate how proposals avoid or minimise any potential harm. The masterplanning will include informed safeguarded zones for Chapel Hill Iron Age/Romano-British site and Chapel Mill manorial site.
b.
The County Council would ask that ‘Archaeological Impact Assessments’ must be undertaken prior to submission of any planning application. This should include consideration of the results of geophysical surveys, trial trenching and further archaeological mitigation, including safeguarding measures;
c.
Areas of archaeological and built heritage importance should include:
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The retention of designated and non-designated buildings and structures, as well as the retention of archaeological landscape features such as historic hedgerows and ragstone walls.
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Where considered necessary, the preservation of significant archaeological assets, such as through retaining certain important sites as part of the open space network, for example Chapel Mill Iron Age/Romano-British site and Chapel Mill manorial site. For areas outside archaeological safeguarded zones, archaeological assets will be mitigated by “preservation by record” through implementation of a phased programme of archaeological work. Consideration should be given to the informed interpretation of any significant assets, potentially
as part of community space dedicated to heritage as part of multi-functional community facilities.
Further preliminary archaeological fieldwork and historic landscape assessment is needed as the strategic site progresses through the planning stages. The County Council stresses that it is essential sufficient archaeological fieldwork is undertaken to ensure the master-planning process is fully informed and identify the archaeological safeguarded zones as soon as possible to provide clarity on constraints. It is at the strategic site-wide masterplanning stage that archaeological constraints and opportunities are fully understood and can be appropriately integrated into the layout and design of the Heathlands Garden Settlement scheme.
An informed programme of interpretation and community activities is required to ensure public access to the heritage with suitable integration of the heritage into the public realm.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which includes requirements for appropriate surveys and assessments, which have been replicated in the SPD.

Comment

Representation ID: 786

Received: 15/12/2025

Respondent: Kent County Council

Minerals and Waste
The Kent Minerals and Waste Local Plan (KMWLP) includes policies that safeguard potentially economically important mineral deposits. Policy CSM 5: Land-won Mineral Safeguarding establishes the presumption to safeguard. Policy DM 7: Safeguarding Mineral Resources sets out the criteria to be met to establish if there are any arguable exemptions to that presumption. The Mineral Safeguarding Area Policy (MSP) identifies allocations where mineral deposits are, in principle, acceptable for extraction to meet identified needs.
The following provides a summary of issues that the County Council considers should be addressed in the SPD, taking into account the observations and comments above:
Minerals safeguarding and mineral supply:
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The SPD should explicitly acknowledge that the Heathlands Garden Settlement lies within the Kent Mineral Safeguarding Area (MSA) and over safeguarded mineral resources and allocations, and confirm that relevant policies of the Kent Minerals and Waste Local Plan (KMWLP) 2024-39, in particular Policies CSM 2 (Supply of Land-won Minerals), CSM 5 (Land-won Mineral Safeguarding), DM 7 (Safeguarding Mineral Resources) and DM 9 (Prior Extraction of Minerals in Advance of Surface Development), will apply to development proposals in the SPD area.
• Section 6.4.2 (Minerals) should be amended to: “These comprise the Folkestone Formation (building and silica sands), Sandgate Formation (industrial sands), and the Hythe Formation (Kentish Ragstone) and River Terrace Deposits”.
The County Council would also request that the coloured “Geological source protection zone” on the SPD diagrams is the same as the Kent Mineral Safeguarding Area defined in the KMWLP.
•
The SPD should require that planning applications within the MSA are supported by a Minerals Assessment (MA) prepared in accordance with the Kent Minerals and Waste Local Plan Supplementary Planning Document (KMWLPSPD) to demonstrate whether an exemption from the safeguarding presumption under Policy DM 7 can be robustly justified.
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The SPD should make clear that, where an exemption under DM 7 cannot be justified, prior extraction of safeguarded minerals will be required in line with Policy DM 9, and that proposals must demonstrate that prior extraction can be achieved without unacceptable impacts on the environment or local communities, having regard to the “agent of change” principle (e.g. future amenity of residents versus quarry operations and HGV movements).
•
The SPD should explicitly recognise the Chapel Farm allocation in the adopted Kent Mineral Sites Plan as part of the adopted development plan for the area, and state that:
o
The phasing of the Garden Settlement must secure full extraction and restoration of Chapel Farm (and any other relevant mineral permissions) before incompatible built development proceeds; and
o
Any proposals that would change the approved restoration objectives for Chapel Farm must demonstrate that the aggregate landbank and the KMWLP’s soft sand supply strategy, will not be prejudiced.

6.4 Minerals
Minerals and Waste
The County Council is primarily concerned with the maintenance of a steady and adequate supply of the aggregates to meet identified needs from the Folkestone Formation (that is required by Policy CSM 2: Supply of Land-won Minerals in Kent of the KMWLP 2024-39). The purer fraction of this resource is called the ‘Silica Sands’; an industrial mineral that does not have a calculated landbank requirement. The aggregate fraction is of high importance. There is a planned need to secure the full extraction of both the permitted reserves and the allocation (3.2mt) at Chapel Farm. This will ensure that supply of soft sand aggregate will be sufficient to at least year 2035-6 of the KMWLP period with a 7-year landbank in place, and no total exhaustion by 2039 which is the end of the KMWLP 2024-39 period.
Though the reference to the need for phasing development with mineral extraction is correct at paragraph 6.4.3, there is no reference in the SPD to the basic presumption to safeguard all the identified safeguarded mineral deposits (Policy CSM 5: Land-won Mineral Safeguarding) in the Maidstone Borough area. It also important that the MSA proposals map is represented in the SPD area. The County Council would also ask that the SPD should include the requirement for a Mineral Assessments (MA,) to be carried out. This MA should follow the approach as set out in Policy DM 7: Safeguarding Mineral Resources of the KMWLP.
Furthermore, where prior extraction of any of the safeguarded mineral deposits is required because an exemption cannot be justified, regard should be had to whether this can be achieved without undue impact on the environment and local communities. This would more fully align with the KMWLP and NPPF 'agent of change’ principle, ensuring that, while development might be permitted to allow the extraction of mineral, the necessary mitigation to avoid risk of impacts (dust, noise, HGV movements etc.) affecting those living in the new housing which may result in constraints on operations will have been also assessed. The relevant policy in the KMWLP is Policy DM 9: Prior Extraction of Minerals in Advance of Surface Development. The SPD should also recognise the full status of the Chapel Farm allocated site in the adopted MSP, which forms a significant part of the Development Plan for the area.

Comment noted.
The SPD references at Chapter 2.2 that the Local Policy framework includes the most up to date Kent Minerals and Waste Local Plan.
Officers agree that the SPD should directly reference the Kent Minerals & Waste Plan which forms part of the local adopted planning policy framework.
Officers agree with the proposed amendment to paragraph 6.4.2.
Officers agree to amend references to the “Geological source protection zone” to align also with the Kent Mineral Safeguarding Area defined in the KMWLP.
Officers do not consider it necessary to duplicate other specific policies from the Minerals & Waste Local Plan as these will apply in any event as part of the adopted policy framework.

Comment

Representation ID: 787

Received: 15/12/2025

Respondent: Kent County Council

Waste management and Lenham Heath WWTW safeguarding:
•
The SPD should explicitly identify the Lenham Heath Wastewater Treatment Works (WWTW) shown on the diagrams as a safeguarded waste management facility under KMWLP Policy CSW 16 (Safeguarding of Existing Waste Management Facilities) and Policy DM 8 (Safeguarding Minerals Management, Transportation, Production & Waste Management Facilities).
•
The County Council would ask that the utilities / infrastructure section should be amended to state that:
o
The existing WWTW forms part of Kent-wide waste management capacity needed to ensure sustainable waste management within the county; and
o
There is a presumption against redevelopment or encroachment that would lead to the loss of permitted waste management capacity or compromise the facility’s viable operation or access, in accordance with Policy CSW 16 and Policy DM 8.
•
The SPD should also require that any planning application for development within the identified buffer around the WWTW is supported by an Infrastructure Assessment (IA) prepared in line with the KMWLP SPD, demonstrating that:
o
Odour, noise and other operational impacts of the WWTW have been fully assessed;
o
Appropriate stand-off distances, mitigation and design measures are incorporated so that new sensitive receptors (e.g. housing, schools) do not give rise to complaints that would unduly constrain the operation of the WWTW; and
o
Access for operational traffic and maintenance is safeguarded.

Comment noted.
The SPD references at Chapter 2.2 that the Local Policy framework includes the most up to date Kent Minerals and Waste Local Plan.
Officers agree that the SPD should directly reference the Kent Minerals & Waste Plan which forms part of the local adopted planning policy framework.
Officers do not consider it necessary to duplicate specific policies or aspects of policies as they will apply in any event as part of the adopted policy framework.

Comment

Representation ID: 789

Received: 15/12/2025

Respondent: Kent County Council

Please see below for further specific comments on the sections within the Supplementary Planning Document Consultation:
3.2.5 Ecology
Minerals and Waste
While the SPD (Figure 6: Landscape Context) identifies the WWTW accessed off Lenham Heath Road and proposes a notional ‘indicative’ buffer area to the new settlement development, it does not explicitly make reference to the relationship between the development of the new settlement and this facility. It also does not recognise that this facility is a safeguarded waste management site, and its continued operation is part of the adopted KMWLP waste management strategy. Policy CSW 16:
Safeguarding of Existing Waste Management Facilities defines the presumption to safeguard these sites as they all form the current stock of waste management facilities, whose continued viable operation is important to ensuring sustainable management of waste in Kent.
The loss of annual capacity at any existing permitted waste site could have an adverse effect upon delivering this waste strategy and so the protection of the existing stock of sites with permanent planning permission is as important to achieving the aims of the KMWLP as identifying new sites. Due to the apparent proximity (within 250m) of the development proposed in the SPD, there remains a need to assess, via a specific IA (following the approach as set out in the Kent Minerals and Waste Local Plan Supplementary Planning Document). The SPD should also address whether the proposed development can be implemented without compromising the operational viability and accessibility of the WWTW against the requirements of the second part of Policy DM 8: Safeguarding Minerals Management, Transportation Production & Waste Management Facilities. The County Council would ask that the SPD acknowledge this part of the Development Plan’s policy provision to safeguard sites to maintain the recognised waste management strategy.
3.2.7 Heritage and Archaeology
Heritage and Archaeology
The County Council recognises that there is consideration of the historic environment in the Heritage and Archaeology section (3.2.7 – 3.2.9) but it should be noted that this is extremely limited and does not reflect the knowledge about and importance of the archaeological resource for this site. It is essential that the SPD guidance for Heathlands Garden Settlement fully describes and appreciates the archaeological resource, clearly identifying the archaeological constraints and the opportunities at this early stage.
3.2.10 Transport and Connectivity
Highways and Transportation
It is the County Council’s view that paragraphs 3.2.10 to 3.2.14 of the SPD provide a concise overview of the current transport networks in the vicinity of the site. The main corridors for active travel, public transport and road traffic have been appropriately identified.
The highlighted opportunities include a network of pedestrian and cycle routes, enhanced bus provision, a new railway station and mobility hubs. These are appropriate
in how they promote sustainable travel behaviours whilst helping to minimise private car use.
The SPD acknowledges the constraint to movement across the site posed by the M20 and rail corridors. The inclusion of a commitment to overcome these barriers through the provision of new or enhanced bridges that prioritise pedestrians and cyclists is welcomed. It is noted that Figure 9 suitably captures the opportunity for direct vehicular access to be achieved via the A20.
The SPD notes the importance of the local minor roads in the vicinity of the site. These include routes that run through or adjacent to the site, such as Forstal Road and Lenham Heath Road. The Transport Assessment provides important additional detail on these routes in recognising how they will need to be accommodated and protected, and the County Council is supportive of the principle of active travel movement being prioritised.
3.2.15 Flood Risk and Water Management
Flood and Water Management
The County Council, as Lead Local Flood Authority, is pleased to note that the Flood Risk and Water Management is considered in paragraphs 3.2.25 to 3.2.16 and makes specific mention to Nutrient Neutrality requirements associated with the River Stour.
As part of any future application, the County Council will expect for the sequential approach to be applied to any layout design(s) with the most ‘at risk’ property types to be sited outside of any know flood zones or flow paths and this should be introduced in the SPD.
Whilst it is noted that consideration has been given to the inclusion of SuDS features and that the guidance of CIRIA should be followed with regards to SuDS, the County Council would also remind MBC that DEFRA published updated National standards for sustainable drainage systems (SuDS) - GOV.UK on the expected principles and standards to be applied to SuDS design earlier this year. It requires drainage strategies to demonstrate a full ‘SuDS Approach’ to surface water management and discourages the use of pipe-to-basin designs. The County Council would expect such features to be incorporated into any proposals.
The County Council would also remind MBC of the requirements of chapter 14 of the National Planning and Policy Framework, specifically paragraph 182.
SuDS should be considered from the outset of master planning, in order to distribute features throughout the development and integrate as effectively as possible with the wider landscape design. They should seek to maximise multifunctional benefits such as
source control, treatment of runoff, and amenity value from open SuDS features, while also reducing the need for large underground systems and tanks.
The County Council would be willing to attend master planning sessions going forward to advise MBC further if of interest.
3.3 Constraints and Opportunities
Heritage and Archaeology
The County Council notes section 3.3 on constraints and opportunities and reference to designated and non-designated heritage assets but suggests that limiting reference to historic field boundaries and stone walling is misleading and woefully inadequate. The site is known to contain a significant Iron Age/Romano-British enclosure on Chapel Hill which will be a constraint on any development at this site with preservation in situ an essential requirement. Remains associated with Chapel Mill manorial site nearby will also be a major constraint although positive consideration and mitigation could ensure the archaeology could inspire a unique design which enhances the sustainability and quality of the Heathlands Garden Settlement.

Comment noted.
Officers have considered the various issues raised at the relevant section of the SPD (blue infrastructure, minerals, heritage, transport).

Comment

Representation ID: 790

Received: 15/12/2025

Respondent: Kent County Council

5.3 Access and Movement Framework
Highways and Transportation
The County Council understands that the Access and Movement Framework has been developed with regard to a travel mode hierarchy that places the needs of active travel modes and public transport ahead of those of the private car. The County Council supports this approach, which aligns with the sustainable transport objectives within the NPPF.
The County Council considers that the framework covers the key elements of transport provision in how it features a network of pedestrian and cycle routes that extend across the site whilst also linking to surrounding areas. The inclusion of a route connection to Lenham and Charing along the A20 corridor is appropriate in helping to ensure walking and cycling are the modes of choice for local journeys.
The rail station is shown to assume a prominent role in the transport provision within the site by being made accessible by all forms of travel. This approach is fundamental to maximising how rail services will cater for longer distance journeys. The bus extension route through the site will provide further opportunities for travel by public transport. It is noted that bus movement will be prioritised over other vehicles, with regular bus stops and the mobility hubs providing convenient points of access to services.
Road access to the site via the A20 has been included, and forms part of the improvements that will be required along this corridor to achieve connectivity and
mitigate wider impacts. The need to facilitate ease of movement along the A20 is critical in discouraging the use of alternative minor roads, as acknowledged within the Transport Assessment.
The Access and Movement Framework should identify how suitable connectivity to Pilgrims Way (National Cycle Route 17) will be provided for cyclists.
5.4 Land Use Framework
Highways and Transportation
It is the view of the County Council that the Land Use Framework is appropriate in how it locates the District Centre and rail station at the heart of the development site. This will minimise distances to local facilities and rail services for residents, employees and visitors, thereby enabling many journeys to be undertaken by walking, cycling and public transport.
The positioning of the two local centres within the south-western and north-eastern parts of the site will enable them to complement the District Centre and affords convenient access to facilities for those residents closer to the periphery of the site. This also assists in enabling local trips to be made by walking and cycling.
It is noted that the school locations relate closely to the district/local centres and mobility hubs. This capitalises on the opportunity to make the schools accessible by active travel and public transport, whilst also facilitating multi-purpose trips.
The employment areas in the vicinity of the rail station and District Centre similarly have good potential for access via sustainable travel modes. They are also well-placed in relation to road access via the A20.
The employment areas located at the southern end of the site on the Land Use Framework are remote from the A20 corridor and are likely to require vehicular access through residential areas. This could result in an undesirable mix of commercial and residential road users. The placement of all employment areas in closer proximity to the A20 could remove this conflict.
5.5 Placemaking Framework
Highways and Transportation
It is noted that the Placemaking and Design Framework identifies the opportunity to position higher density housing close to the bus route. This is appropriate in how it maximises the number of houses within close proximity of bus services.
The opportunity for higher density housing to be located in the areas immediately surrounding the District Centre/Rail Station, local centres and mobility hubs is not adequately articulated in the Placemaking Framework. It is imperative that the number of residents in close proximity to public transport hubs and local facilities is maximised to realise the vision of a sustainable community.

Comment noted.
The SPD is setting principles and guidelines specific to the allocated Heathlands site.
The detailed design of transport measures and mitigation including consideration of options to integrate into wider the cycling network will need to be set out as part of the formulation and consideration of future planning applications.
Employment areas are proposed throughout the site. They will need to located sensitively to protect the setting of the Kent Downs National Landscape.

Comment

Representation ID: 791

Received: 15/12/2025

Respondent: Kent County Council

6.6 Placemaking, Density and Character
Highways and Transportation
The County Council is supportive of the principle of clustering the highest density housing around the public transport hubs as this will help deliver increased patronage for bus and rail services. This will, in turn, help to sustain these services in the longer term.

Comment (support) noted.

Comment

Representation ID: 792

Received: 15/12/2025

Respondent: Kent County Council

6.7.1 Housing Mix
Adult Health and Social Care
The County Council would encourage the Heathlands Garden Community developers and MBC to engage with its Adult Social Care (ASC) Team to ensure correct provision of certain housing and accommodation need types for adults.
The County Council would ask that there is inclusion in the SPD of more precise information around future ASC need i.e. currently there is an over-supply generally in the market of standard residential care, and a notable under-provision of dementia and nursing care, which are increasingly needed as the population ages and care needs become more complex.
To address these challenges, the County Council recommends the following for inclusion in the developing this SPD:
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Rebalancing Residential Provision: Rather than additional standard residential care, future provision should focus on:
o
Dementia care
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Nursing care
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Extra Care Housing – there is significant need for at least one extra care housing scheme in the district
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Accessibility Standards: All new housing developments should meet:
o
Part M4(2) of the Building Regulations (accessible and adaptable dwellings)
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A proportion should meet Part M4(3) (wheelchair user dwellings), based on local evidence of need.
•
Supported Living:
o
There is a need to increase the supply of modern, fit-for-purpose supported living schemes for working age adults, particularly for people with learning disabilities, mental health needs, and complex care requirement.
•
Modernisation and Cost-Effectiveness: Residential and nursing homes must be:
o
Modern and fit for purpose
o
Financially sustainable, including consideration of long-term affordability for local authority placements.
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Assistive Technology: All new specialist housing schemes should embed assistive technology from the outset, supporting independence and reducing long-term care costs.
These comments below are drawn from the (draft) KCC ASCH Market Position Statement (MPS) and the Report Kent Adult Accommodation Strategy Evidence Base 2025-06-23

Comment noted.
The Housing Chapter of the SPD (6.7) sets out some key principles including the need to provide a broad mix of homes across the site. This will need to be informed by the most recent Strategic Housing Market Assessment together with other relevant and recent information as well as considering market factors and the location and characteristics of the site.
Given the long term nature of the project, which is not expected to start delivering housing until around 2030/31, Officers do not consider it appropriate to be prescriptive around the housing and accommodation needs as part of the SPD.
The precise mix and types of housing units will be determined at the pre/planning application stage and involve discussions with all relevant stakeholders including Kent County Council in respect of Adult Social Care.
Appendix C of the SPD sets out anticipated planning application requirements which includes the need for applicants to provide a 'Housing Statement and Affordable Housing Statement' to address matters such as housing mix and tenures.