Heathlands Garden Settlement SPD

Comment

Representation ID: 809

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

I write on behalf of my fellow Harrietsham, Lenham and North Downs Ward Councillors and I, to submit our comments on the above document

Whilst we remain steadfastly opposed to the concept of building effectively a new town in the beautiful Kent Countryside, we do recognise the need to engage constructively in the SPD review process. To that end, our comments are contained in the attached spreadsheet. I can briefly summarise our key concerns as follows:

The criteria for SPD adoption appear to be target date based rather than meeting quality of content and fit for purpose criteria to ensure that the document contains all the relevant information and provides enough clarity for residents to be able to evaluate the viability and impact should the project proceed.
Significant gaps and shortfall are evident, which we believe need to be filled before the document should be considered suitable for adoption.
It is argued that the SPD needs to be adopted quickly so that developers cannot submit planning applications 'doing what they like' because there is no SPD. However, if the SPD fails to contain the relevant detail, this would still be the case.
When the LPR was carried out, many concerns over the viability of the project were raised (including many by the inspector). Many of these have been raised and tracked through the Stakeholder Steering Group (SSG) but insufficient progress has been made for the SPD to be considered as a viable document rather than a meaningless milestone.
The LPR and SPD promise considerable infrastructure improvements, which will not be provided by, nor budgeted for, by MBC. Without necessary commitment from other agencies, these serve as nothing more than a simple 'wish list' which cannot be guaranteed and may never get delivered.
Considerable work needs to be completed to demonstrate that the development would be anything at all close to 'self-contained'.
The lack of reliable transportation modelling is of particular concern.
No evidence based market research appears to have been carried out to ascertain housing need nor demand for affordable or other housing in this location, or industrial units. There is further concern whether providers of affordable housing may show a lack of interest, preferring instead, more viable opportunities.
The viability work assumed an infrastructure budget requirement of £100m. It is suspected that this figure may have been a massive under-estimation. Further, the SPD gives no confidence how the infrastructure will be budgeted for, nor the budget underpinned by commitment from other bodies.

It is noted that Lenham Parish Council (LPC) holds the view that the SPD consultation should be paused until a document of the necessary quality can be produced to give residents a clear understanding of what the proposals are and how viable the project is. We as Ward Councillors fully support this view, or at least ask that the consultation period be extended until a clearly identified and agreed set of criteria are met to ensure that the document is fit for purpose, is unambiguous and leaves little opportunity for commitments to rescind or developers to exercise undue freedom to develop what they want. In addition, we remain concerned about the level of public money being spent on a project that hasn't been clearly demonstrated to be viable. It would be totally irresponsible to not manage this situation.

In the absence of the SPD meeting the necessary agreed criteria other than an arbitrary 'close date', and failing to progress long-standing concerns, the document will not serve it's intended purposes of informing residents of the Heathlands Proposals, nor restricting developers to operate within the LPA's intended constraints. In short, if the document fails to meet it's intended purpose, then it's production will only serve as a 'box ticking exercise', and the consultation will not have been under any circumstances, 'meaningful'.

Having studied the lack of detail in the proposals and how certain requirements have already rescinded over time, we share LPC's concern that ambiguous requirements that are not underpinned by real commitment will only lead to further disappointment and a dumb-down of requirements and delivered infrastructure. This appears to have already been the case regarding the originally intended M20 junction. It is absolutely essential that development without the supporting infrastructure does not go ahead.

Whilst we commend the hard work and dedication that has gone into the preparation of the document, we feel that it is far from ready for adoption until all outstanding concerns are adequately addressed and that commitment and funding match the promoter's aspirations.

SPD finalisation
Given that MBC has announced a 6 week consultation, this implies that the SPD finalisation and adoption is being driven by dates rather that meeting a defined set of quality criteria.
There is a threat that the SPD may be adopted without meeting essential"

"Steering Group
We would like to see output from the Steering Group showing progress against criteria identified to demonstrate creditability and viability of the project

Risk Register
"We would like a Risk Register to be included as appendix to the SPD together with an associated Mitigation Plan
We would expect the Risk Register and Mitigation Plan to be base lined on adoption of the SPD and thereafter updated and maintained as any proj"

Inspector Recommendations
Lenham Parish Council have noted with concern that an number of critical areas for additional work identified by the Inspector have not been closed. It is essential that this addressed to improve confidence in the viability of the project and assurance t

Dependence on external bodies
"The SPD promises such infrastructure as healthcare, education and transport for which MBC will not be directly responsible. The SPD should contain appendices showing commitment and guarantees that dependencies and funding is agreed.
The SPD should also c"

Long Term Viability
There is concern that Heathlands could be partially delivered before it is realised that there is no long term viability or sustainability and the result is a number of dwellings are delivered without the promised infrastructure. This risk must be mitiga

Phased Delivery
It is important that local residents can see how infrastructure is being delivered inline with the delivery phases

Infrastructure Delivery Detail
The level of detail in the SPD is not sufficient. Much finer detail should be provided before the SPD can be considered fit for adoption

Phasing and Delivery
The SPD does not provide further clarity on phasing than that contained in the LPR. This is not acceptable and could allow considerable development without supporting infrastructure

Developer Contributions
It needs to be clarified what assumptions have been made in terms of infrastructure being funded from developer contributions and what the impact would be if development doesn't proceed at the anticipated rate

Infrastructure Budget
The Inspector's report estimates that £100m will be required to provide infrastructure to make the Heathlands project viable. The SPD should include a detailed study showing a true representative figure, the cost breakdown and crucially how the costs wil

Viability
Given that the Inspector noted 'I acknowledge that the viability of Heathlands in marginal', The SPD should build on the Inspectors remarks and should contain an updated and detailed viability report including a sensitivity analysis.

S106 Conflict Of Interests
As MBC will be acting as LPA and promoter of the development. This leads to complications as to how a 106 agreement will be put in place and how the two separate functions of MBC can be maintained

Timely Delivery of Infrastructure
The NPPF and LPR, both contain clauses to ensure timely delivery of infrastructure to support development. The SPD provides no assurances or guarantees in this respect

Land Availability
There is no clear statement on what land has been secured (particularly for phase 1), what is required to secure the remaining land and what contingency plans are in place to it not prove possible to obtain the land required.

Criteria For SPD adoption
"We are concerned that the criteria for adoption of the SPD appears to be 'time related'; that consultation time is fixed and assumedly that MBC has responded to all comments before adoption.
One cabinet member. responding to objections that the SPD wasn't"

Sustainable Design
The SPD states 'Pedestrians, cyclists and public transport will be prioritised providing sustainable travel opportunities' yet there is no clear plan or commitment to deliver the railway station, no clear plan to support required bus routes and the origin

Nutrient Neutrality
Nutrient Neutrality appears not to have been considered

Light Pollution
This massive development will have a devastating effect on light pollution reaching current local residents and the North Downs

Viability
The Inspector noted that Heathlands was 'marginal at best' in terms of viability. As the SPD is considered a Master Planning Stage, viability should be re-tested. The SPD should therefore contain or refer to an updated detailed viability report

Use Of Public Funds
We are concerned at the level of public funds being spent of a project that has not been proven viable. We do not feel that the risk being taken is proportionate

Guarantees Of Supporting Infrastructure
MBC is requested to include a statement in the SPD how a situation will be avoided where the 'low hanging fruit' of phase 1 is delivered and then infrastructure delivery is abandoned or scaled back as 'undeliverable' or 'too expensive' leaving the first r

Greenbelt or Buffer Zones
The SPD should contain details of how greenbelt or buffer zones will be protected to ensure separation between Lenham and Heathlands on a persistent basis

Evidence of commitment
Where external agencies have committed to support required infrastructure, we request that evidence is made available as far as possible, particularly to Ward and Parish Councillors

Public Spend
Can MBC please clarify how much public money has so far been spent on Heathlands and provide a forward budget projection against commitment milestones both for MBC and third parties

Comment noted.
Officers consider that the SPD is supported by an appropriate evidence base, and sets out a wide range of requirements that future planning applications will need to consider and address.
The SPD sets out 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 takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure.
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.
Paragraph 7.2.5 of the SPD sets out that infrastructure will be secured at the appropriate time as the development comes forward through the use of planning conditions and legal agreements.
Chapter 9.2 sets out that the Council sets out that Section 106 and Section 278 agreements will be the means to secure the necessary policy and infrastructure requirements for the Garden Settlement.
Appendix B of the SPD sets out the anticipated developer contributions to be secured by legal agreements.
The viability of the proposal was considered during the examination of the Local Plan Review and is not a matter needing to be revaluated to prepare the SPD.
Ideas and initial proposals to be included in the SPD were the subject of informal public engagement in May 2025, with several in person engagement events held in Lenham. The Council have included a 6 week consultation period, in excess of the statutory minimum of 4 weeks to provide stakeholders including local communities time to consider the SPD and supporting documents. In person events were held again in Lenham as part of the current consultation process on the draft SPD. All comments made are being considered by Officers and amendments are being made in light of feedback received.

Comment

Representation ID: 810

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Railway Station
There is no commitment from Network Rail to build a new station
There is little or no detail on the build or operational costs and how it will be funded
There is no indication that the Department of Transport has been consulted
At the examination of the L

Sustainable Transport Measures
KCC requested that sustainable transport measures be put in place earlier during development phasing. There is no commitment to this in the SPD

Transport Model
"KCC as Highways Authority will be publishing a new transport model in the spring of 2026. The SPD should be delayed until this has been considered and residents have been given a better understanding of the impact of Heathlands
The SPD states that furthe"

Traffic assessment
The SPD states that traffic assessment will be carried out on routes to the North and South of the site as well as through Lenham in respect of any outline planning application. This is unacceptable and needs to be considered now in relation to the overa

Commuting from Headcorn
The rail service from Headcorn to London is superior to that from Lenham. Many commuters from Lenham and Harrietsham already drive to Headcorn as a result. This needs to be considered in any traffic modelling

Impact on highway safety
The NPPF states that a proposal should be refused if highway safety risks cannot be mitigated. There are currently no mitigation plans assessed or published for comment

Bus Network
"The impact on bus services between Ashford and Lenham with additional journey times needs to be considered
There needs to be an assessment on proposed changes to bus services, the suitability of local roads being used as bus routes and the resulting impac"

Improvements To Road Network
The SPD refers to 'improvements to the local road network' yet other than access to the A20, there is no clear plan on how local roads will be 'improved' to support increase in traffic, Quarrying of sand, sewage lorries or changes to bus routed. This all

Existing Lenham Rail Station
The existing railway station at Lenham is clearly shown on the plans. Can MBC please confirm that this will remain operational and that rail services to this station will not suffer degradation of services as a result of heathlands?

Transport Model
"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 ava"

Operation Brock
The SPD makes no mention of and fails to consider the additional traffic congestion along the A20 when Operation Brock is in force which is far from an uncommon experience

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure, and Section 6.11 sets out principles and guidelines including relating to promoting active travel, assessing and mitigating impacts across the local and strategic road layout.
The SPD is supported by a Transport Annex and Assessment and sets out additional guidance on the approach to transport assessment and mitigation (Chapter 8) as has been agreed between Maidstone Borough Council, Kent County Council and National Highways.
The detailed design of transport mitigation measures will need to be set out as part of the formulation and consideration of future planning applications.

Comment

Representation ID: 811

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Health Provision
There is inadequate detail on healthcare provision and whether Len Valley Practice will be expanded or a new surgery will be provided.
There is inadequate detail on how additional healthcare will be provided and funded

Social and Community Facilities
The SPD highlights the need for such considerations but lacks detail on how these will be provided, funded or supported

Infrastructure Commitment
The Heathlands proposal is simply not credible nor viable without commitment for infrastructure and other dependencies. We would like to see all dependencies clearly identified and a plan identifying when commitment and budgeting for those dependencies n

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope and phasing of infrastructure, which included the requirement for a new health facility and other community facilities.
The SPD set out principles and guidelines relating to 'Community Facilities and Social Infrastructure' (6.6) which sets out further guidance.
The requirement is replicated within Figure 19 at Section D. Paragraph 7.2.5 sets out that infrastructure will be secured at the appropriate time as the development comes forward through the use of planning conditions and legal agreements.
The delivery of appropriate local facilities will be a matter that future developers and planning applications will need to address through further engagement with the relevant stakeholders.

Comment

Representation ID: 812

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

"Waste Water Treatment
Lenham's current waste water treatment plant is already in serious need of enlargement/updating/replacement. It is understood that removing sewage in lorries is being considered. This is not only a woefully inadequate solution but will add to the antici

Fresh Water Supplies
Kent already suffers water supply issues leading to frequent hosepipe bans. The SPD contains no provisions for addressing this

Blue Infrastructure
The SPD gives no detail nor budgetary information on waste or foul water management

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure for the Heathlands site, including the need for new/improved wastewater treatment as part of Phase 1, as set out in Figure 19.
The guidelines and principles at Chapter 6.3 of the SPD in relation to 'Blue Infrastructure and Wastewater Treatment' require development proposals to demonstrate how foul water will be appropriately managed, including provision of an improved or new wastewater treatment facility.
It is the responsibility of the relevant utility providers to ensure that future development is provided with safe, reliable water for domestic and commercial use, as per statutory obligations and relevant legislation.

Comment

Representation ID: 813

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

"Affordable Housing
"Although Heathlands is intended to provide a degree of affordable housing, a rural location such as Heathlands is not an ideal location for families seeking affordable housing and require access to urban jobs and efficient transport links.

The SPD should"

Market Analysis
The SPD contains no market analysis to show anticipated demand for housing, the prices that houses may be expected to achieve not if any employment generated from the project will pay salaries anywhere near that required to afford the housing

Number of Homes
"5000 homes is the number given for the allocation but, in design terms, how was it established this
number is appropriate?"

Land For Housing And Density
The SPD highlights open spaces, parks and woodland but is unclear exactly which land will be used for housing nor what the resultant density will be

Accessible Housing
The SPD could make previsions for accessible housing to be available for retired and disabled people. This may reduce the traffic impact and allow MBC to increase availability of social housing nearer town centres

Comment noted.
The SPD takes forward the requirements of the Local Plan Review which considered matters related to overall housing need and supply, and identified and allocated the Heathlands Garden Settlement to address future needs.
The SPD sets out principles and guidelines in relation to ""Placemaking, Density & Character"" at Chapter 6.6 which explains the approach to site capacity and density, and an indicative breakdown of land uses is set out at Figure 12 and shown as part of Figure 13 the Land Use Framework.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure, and Section 6.11 sets out principles and guidelines including relating to promoting active travel, assessing and mitigating impacts across the local and strategic road layout.
Officers agree that additional principles should be added to ensure that active travel routes are safe and accessible to all.

Comment

Representation ID: 814

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Climate Change And Air Quality
Although 5000 jobs is an 'aspiration' for the project, there are no guarantees this is viable, nor that salaries available will be sufficient for workers to buy the houses. As a result, it cannot be guaranteed that traffic in and around Heathlands would

Comment noted.

Comment

Representation ID: 815

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Employment Sensitivity Modelling
What sensitivity modelling has MBC undertaken should 5,000 jobs not be achievable and Heathlands residents commute?

Employment
To be a viable proposal Heathlands must provide sufficient employment to be 'self contained'. Th SPD should contain an up to date, evidence based market report on the sustainability to provide the level of employment needed to provide the required level

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
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: 816

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Design Code
There is currently no Design Code detailed for Heathlands in the LPR or SPD. Leaving this to the Outline Planning Application stage will allow developers to define piecemeal Design Codes for each part of the development

Comment noted.
The principles set out at Chapter 10.1 require that a site wide Strategic Masterplan and a Strategic Design Code must be submitted as part of the future outline planning application.
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.
All future applications will be the subject of consultation and future decision making.

Comment

Representation ID: 817

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

Landscape Led Approach
By it's very nature, a 'landscape led approach' facilitates bringing experienced landscape professionals in from the very start ensures developments are smarter, more adaptable, and deliver maximum benefit. Can the SPD please clarify how this 'headline'

Comment noted.

Comment

Representation ID: 818

Received: 15/12/2025

Respondent: Maidstone Borough Council

Number of people: 3

District and Local Centres
The SPD refers to District and Local Centres but doesn't clarify what these are, nor how they will be funded or supported. As a result, viability has to be questioned

Comment noted.
The SPD contains a range of topics including (at 6.8) the approach to the proposed District and Local Centre which must include a wide range of services and facilities including appropriate community facilities, retail and leisure to meet the needs of residents.
The delivery of appropriate local facilities will be a matter that future developers and planning applications will need to address.