Heathlands Garden Settlement SPD

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Comment

Heathlands Garden Settlement SPD

Q3: Are there any issues and elements which you feel are inaccurate or missing? 

Representation ID: 375

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

1.3.5 "Key matters raised via the informal engagement:
• That open space is included throughout the site to accommodate new wildlife, provide good walking
routes and buffers to sensitive areas.
• That proposals consider and address impacts on the local highways network including the A20, local
pinch points, and all surrounding local routes and lanes, some of which were considered to be
unsuitable for increased levels of traffic.
• The need to ensure that sustainable travel options are made available, including the provision of a new
railway station."
As explained above, provision should be made for equestrians as well as walkers and cyclists. Crossings and
other non motorised user (NMU) provisions should also include equestrians.

2.1 "National Planning Policy"
Please see also references to NPPF above.
2.1.4 "In relation to transport, Circular 01/2022 issued by the Department of Transport should be read in conjunction
with the NPPF. This sets out the Government's policy in relation to the Strategic Road Network and how National
Highways will engage with the planning system."
Please see also reference to DEFRA Circular 1/09 Rights of Wayii above

2.2.2 Garden City Principles
We note the references to “Accessible for All” and “Places that enhance people’s health & wellbeing”. The
inclusion of equestrians and not just “walking and wheeling routes” would make it truly accessible for all and
add to people’s health & wellbeing

2.3.2 Inclusion of equestrians can only add to the good design of Heathlands Gardens

3.1 Location Boughton Rd
There are two Definitive map modification orders for restricted byways within this area. One leads from close
to the Old Ashford Road junction with the A20 approximately south to Lenham Heath Road, close to Chapel
Farm. The second leads from this route approximately eastwards past Mount Castle Farm to Lenham Forstal
along to If these orders are confirmed, any proposals in this location will need to include these public rights of
way.

3.2.11 See the comment in respect of 3.1 above. Two further applications east of Lenham Forstal are also due to be
considered by the Secretary of State which may result in additional PROW.

3.3 "Constraints and opportunities
Key elements to be considered as part of the approach to delivering Heathlands Garden Settlement: […]
• Sustainable access and movement provision will be needed including a network of pedestrian and cycle
routes, enhanced bus provision, a new railway station and mobility hubs across the Garden Settlement to
promote sustainable movement choices and minimise as far as possible use of the private car"
.
AND equestrians
[…]
• "There will be a requirement for additional and/or enhanced vehicular and pedestrian cycle bridges to create
a permeable layout and adequately connect and integrate the site across key existing barriers such as the
railway lines and M20."
Not just pedestrian cycle bridges – any new bridges provided MUST include equestrian use.
• "Existing lanes running through and beyond the site will be respected and where possible protected from
additional traffic. Opportunities for traffic calming and minimising movement must be explored to make
them more pedestrian and cycle friendly."
AND horse friendly
Any provision for walking and cycling must include equestrians for safety, equality and health & wellbeing reasons (see statistics in Appendix 1 below)

Attachments:


Our response:

Comment noted.
Officers agree that additional commentary should be added to Section 3.3: Constraints Opportunities to acknowledge the existence of routes suitable for horse riders.

Comment

Heathlands Garden Settlement SPD

Q5: Do you suggest any changes to the Vision & Objectives?

Representation ID: 376

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

4.1.3
"Heathlands Vision
As a new Garden Settlement rooted in garden village design principles, Heathlands Garden Settlement will become a new sustainably planned place with connected, walkable, vibrant, sociable neighbourhoods for the residents of Heathlands, Lenham, Lenham Heath and Charing in which to live and work."
AND rideable
AND horse riding See appendix 1 below for statistics
Horse riding and carriage driving ARE sustainable transport and so must be included

“4.2 Objectives
Sustainably designed
Pedestrians, cyclists and public transport will be prioritised providing sustainable travel opportunities with convenient and safe linkages within Heathlands, to surrounding communities and to community facilities, jobs and leisure.”
This needs to include equestrians

“Well connected
With improvements to the local road network, enhanced bus services, a new and expanded network for walking and wheeling and a new Heathlands Rail Station to achieve a comprehensive approach prioritising sustainable movement.”
Walking and wheeling provision needs to include equestrians whether by higher status PROW or other means.

“Promoting health and wellbeing
To facilitate healthy lifestyles, there will be spaces for exercise, sport, play, walking, cycling, and leisure, alongside initiatives to support new residents, create a sense of community and neighbourliness, and provide a broad range of local services and facilities”
Including equestrians promotes health and wellbeing (see statistics in Appendix 1)

Attachments:


Our response:

Comment noted.
The Vision is replicated from the Local Plan Review, and Officers do not consider it necessary to specifically refer to horse riding.
The Council propose to refer to horse riding as part of additional guidelines later in the SPD to ensure that there is appropriate provision within the site.

Comment

Heathlands Garden Settlement SPD

Q7: Please set out any changes to the framework plans, and which plans these changes should relate to?

Representation ID: 377

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

5 “Spatial Framework
"A series of 'Framework Plans' provide an overall anticipated approach to the development of the Garden Settlement.
5.1 Introduction
[…]
5.1.4 Four key spatial framework layers collectively sets the overall approach to the development of the site. These layers establish the approach to:
Green & blue infrastructure, landscape and open space;
Access and movement;”
To include equestrians.

5.2 “Green and Blue Infrastructure Framework
5.2.1 In keeping with a 'Landscape-led' approach, the starting point the approach is the 'Green & Blue Infrastructure Framework' which sets out key spatial aspects of the overall open space and landscape strategy for the Garden Settlement.
5.2.2 The approach will create a network of open spaces throughout the site, providing a range of characters and uses to create a varied and attractive environment accessible to new and existing residents.
5.2.3 Over 50% of the site area is intended to consist of a network of green infrastructure, with a variety of local parks, retained and enhanced woodland and other semi-natural habitats, extensive new tree planting, and green and blue corridors to comprehensively meet the needs of local people.”
We support this approach provided that it includes equestrians

5.2.8 “A network of green corridors must be provided to relate to the topography, existing areas of woodlands and other semi-natural habitat across the site and surrounding countryside. Green corridors will help to break the Garden Settlement into neighbourhoods and smaller character areas while providing opportunities for new leisure routes, enhanced ecological connectivity across the site and beyond. Varied new wildlife habitats along and additional to these corridors will link existing and new habitats and create an interconnected network.
These green corridors can also accommodate a variety of types of recreational space, including play space, both formal and more informal "play along the way" features. Planting within the green corridors will be predominantly naturalistic with an emphasis on creating diverse habitats for a range of animal and plant species.”
Any multi use routes or green corridors providing access for walkers and/or cyclists also needs to include equestrians

5.2.12 “A new semi natural in character Country Park must be provided in the south of the area for the benefit of both the local community and for visitors from the wider area to enjoy. A new Town Park will also be provided to provide quality open space within the Settlement.”
We support this provided that equestrians are included within larger spaces

5.3 “Access and Movement Framework
Heathlands Garden Settlement must incorporate a comprehensive movement network of streets to ensure permeability and connectivity to all parts of the development.
Streets will be designed as places for everyone with priority for pedestrians and cyclists. They will include trees, SUDs and diverse planting to contribute to biodiversity.”
Streets must also have priority for equestrians

5.3.3 “Walking and wheeling must feature strongly through the provision of an extensive network of high quality, direct segregated and shared pedestrian and wheeling routes linking all parts of the site to key destinations within the Garden Settlement and further afield ensuring walking and cycling is the mode of choice for these journeys.”
AND horse-riding and, wherever possible, carriage driving. See Appendix 1 for stats on health and wellbeing benefits

5.3.4 “There are numerous Public Rights of Way (PRoW) providing connections across the site, including existing PRoW connections into the centre of Lenham, Charing Heath, Charing and Pilgrims Way. A new network of attractive pedestrian and cycleways will enhance existing local networks and positively support active and healthy lifestyles.”
New networks must include horse riding and, wherever possible, carriage driving. See Appendix 1 for stats on health and wellbeing benefits

5.3.6 “Access points into the site for all modes must be provided from the A20. Wider improvements along the A20 will be required to achieve connectivity and mitigate impacts where necessary.”
These access points must include equestrians, especially where provision is intended for non motorirised users.

5.3.10 “The layout of primary routes will create an overall internal circuit formed by an attractive tree lined street with priority routes for buses, pedestrians and cyclists to efficiently connect residents to places in a beautiful, safe and appealing environment.”
Priority routes for pedestrians and cyclists must include equestrians. See Appendix 1 for health & wellbeing and safety statistics.

5.3.11 “Layouts must be designed and measures included to limit vehicular movement along local routes in the vicinity of the development which are considered unsuitable to accommodate additional traffic, directing vehicles to the most suitable routes.”
We welcome this but it must accommodate equestrian use (horse riders and carriage drivers)

5.4 “Land Use Framework
The new neighbourhoods and wider land uses will be connected both by green corridors and active travel routes. Additional green open spaces will be provided throughout the site.”
Green corridors and active travel routes need to include equestrians

5.5 “Placemaking Framework
Key to creating a successful Garden Settlement will be through the successful design of the place, the co-location of uses, creation of a high-quality open and public spaces and good connections both within the site and to the surrounding area.
Given the size of the site and scale of development proposed, development will come forward in phases and via the creation of a number of separate neighbourhoods. These must come forward in accordance with subsequent more detailed masterplanning and design coding to secure a high standard of buildings, open spaces, public realm and key streets & active travel corridors.”
It is essential that the provision of off road routes for ALL users (including equestrians) needs to be kept connected at every stage and, ideally, laid out and agreed in advance of any future planning.

Attachments:


Our response:

Comment noted.
Figure 11: Movement & Connectivity Framework sets out the key routes and connections for active travel.
Principles and guidelines relating to active travel are set out at Chapter 6.11 which requires a well connected network of pedestrian and cycle routes.
Officers agree that an additional principle should be added to refer to bridleways and equestrian movement through the site.

Support

Heathlands Garden Settlement SPD

Q17: Please set out any changes that you think should be made to the principles & guidance for "Placemaking, Density and Character".

Representation ID: 378

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

6.2.6 “Section C: Placemaking and Design Guideline
6. Placemaking Guidelines
6.2.6. Land for open space, green & blue infrastructure and linking corridors should exceed the quantitative, qualitative and accessibility standards set out by Policy LPRINF1, with an overall target to provide greater than 50% of the total site allocation area. AND
6.2.8. The network of new green spaces and green corridors will link with the open countryside beyond the Garden Settlement.”
We support this approach provided that it includes equestrians

Attachments:


Our response:

Support noted.
Officers agree that a reference should be added to acknowledge the need to cater for horse riders and equestrian movement through the site.

Comment

Heathlands Garden Settlement SPD

Q9: Please set out any changes that you think should be made to the principles & guidance for "Green Infrastructure and Landscape".

Representation ID: 379

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

6.2.15 “Country Park
The proposed new Heathlands Country Park will be a beautiful and ecologically rich multifunctional semi-natural green space, delivering extensive new wildlife habitats and biodiversity net gain, while providing high-quality leisure and amenity space for residents and visitors to the area.
The Country Park will include walks, a range of natural and semi-natural green spaces and areas for recreation that discourage disturbance to more ecologically sensitive areas. It will have good accessibility by walking and wheeling, alongside other facilities including some disabled and other car parking provision where appropriate.”
AND for horse riding

6.2.17 “Key Principles/Guidance:
Green Infrastructure and Landscape
Landscape, Views and Open Space
f) In accordance with LPR Policy LPRSP4(A) and the Framework Masterplan no built development will be located within 350m of the Kent Downs National Landscape boundary with the exception of the new road, pedestrian and cycle accesses from the A20.”
Pedestrian and cycle accesses from the A20 must include equestrians
"g) Existing ancient woodlands must be protected and be off set from any proposed new development by a minimum 15-metre landscape buffer within which no buildings will be permitted. Wider buffers and linkages to other semi-natural habitats should be provided wherever possible, and can incorporate other open space typologies, landscaping and active travel corridors beyond the 15 metre zone."
Active Travel corridors to include horses
"Country Park
q. The new Country Park must:
• Improve and enhance existing public footpaths through the park, along with the provision of new routes to expand the network of internal leisure routes to explore the wider countryside."
The above must include provision for equestrians as well as walkers and cyclists
• "Include the delivery of supporting infrastructure, prioritising foot and cycle improvements to promote and enhance active travel connectivity and direct accessibility to the park. Provision should be made for private vehicles, including disabled car parking and associated facilities for users of the Country Park. Such facilities must be created using natural materials such as permeable parking and surfaces, and be screened by planting and soft landscaping."
The above must include provision for equestrians as well as walkers and cyclists

Attachments:


Our response:

Comment noted.
Officers agree that a reference should be added to acknowledge the need to cater for bridleways and equestrian movement through the site.

Comment

Heathlands Garden Settlement SPD

Q23: Please set out any changes that you think should be made to the principles & guidance for "Social & Community Facilities".

Representation ID: 380

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

6.9 “Social & Community Facilities
Community and Health Facilities
The Garden Settlement will create an active environment that promotes health and wellbeing and builds a strong community. The conditions for a healthy community will be provided through the pattern of development, good urban and public realm design, access to local services and facilities, opportunities for local employment, high quality open space and landscape design and safe places for active play, biodiversity and food growing, and which are all accessible by walking, cycling and public transport. Proposals must take account of the healthy new towns principles, the developing integrated neighbourhood model of working, as well as Sport England's Active Design principles.”
Good connectivity for all users including equestrians by means of PRoW, Active Travel routes, etc. will improve the health and wellbeing for all users and provide better value for the tax payer (See appendix 1 for the benefits of equestrian inclusion)

6.9.14 Key Principles/Guidance:
"Community Facilities and Social Infrastructure
Health, Sports and Community Facilities
l) Sports facilities (including built facilities) must be provided aligned with new open space and playing pitch requirements and as per the most up to date policies and standards produced by Sport England (or equivalent)"
This must be whilst ensuring that other user groups are not adversely impacted.

Attachments:


Our response:

Comment noted.
Officers agree that a reference should be added to acknowledge the need to cater for horse riders and equestrian movement through the site.

Comment

Heathlands Garden Settlement SPD

Q25: Please set out any changes that you think should be made to the principles & guidance for "Employment".

Representation ID: 381

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

6.10 Employment
Equestrianism is the second largest rural employer after agriculture. Ensuring that there is good provision for people to keep and ride their horses helps to boost the local economy. With the North Downs and Pilgrims Way nearby, safe connectivity between the main routes within the area and over the A20 is of benefit to all.

Attachments:


Our response:

Comment noted.
Officers do not consider that the equestrian sector needs direct referencing in relation to employment, but agree that references should be added elsewhere in the SPD to acknowledge the need to cater for horse riders and equestrian movement through the site.

Comment

Heathlands Garden Settlement SPD

Q27: Please set out any changes that you think should be made to the principles & guidance for "Movement and Connectivity".

Representation ID: 382

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

6.11 “Movement and Connectivity
The approach to transport and movement and an overview of additional transport assessment work that has been undertaken is set out is set out in the accompanying Transport Annex.
The vision for Heathlands Garden Settlement is clear that pedestrians, cyclists, and public transport must be prioritised, to establish sustainable travel principles from the outset, with convenient and safe linkages within Heathlands, as well as to surrounding communities.”
Movement and connectivity provision must also include equestrians

6.11.6 “Walking, Cycling and Wheeling
The Garden Settlement must be designed to create walkable neighbourhoods - places where a range of useful facilities are within a short walking distance of all homes.
A network of well-designed and direct pedestrian and cycle routes must be provided throughout the site, linking the rail station, district centre and local centres to the housing and employment areas, and beyond to the open countryside and to surrounding settlements.
Local Plan Policy LPRSP4(A) requires that the Heathlands Settlement provides cycling and footpath connections between Charing and Lenham along the A20 at the preliminary stage of development, establishing healthy and sustainable travel patterns from the outset.
A network of 'greenways' for pedestrians and cyclists will connect residential areas with the rail station, mobility
hubs, parks, local and district centres and employment areas. These routes will be separated from vehicular
routes, be lit and attractively planted to encourage the choice of walking, cycling and wheeling as preferred
modes of travel. Cycle parking will be provided at key locations.”
All the above must include equestrians
"There are a number of existing Public Rights of Ways (PRoW) throughout the area which facilitate key
connections between the existing residential areas and the countryside beyond. The network of green corridors
and existing PRoW will offer links to the surrounding countryside, nearby settlements including Lenham, and to
the National Cycle Route 17 to the north of the site."
This is to be commended provided that equestrians are included and that existing rural PROW are not adversely
impacted by inappropriate surfacing. Upgrading of footpaths to bridleways or even restricted byways makes
connectivity and permeability easier for all non motorised users including horse riders and (with restricted
byways) carriage drivers.

"Active Travel – Walking, Cycling, Wheeling" AND HORSE RIDING
"a. Active travel principles must be prioritised within the Garden Settlement, with those walking, wheeling
and cycling afforded the most direct route, with priority over and protection from motorised traffic
where possible […]." AND HORSE RIDING
"c. Unless it is justified and evidenced, all active travel routes will be LTN 1/20 compliant and be delivered in
accordance with the detail established in the accompanying allocation-wide design code."
LTN 1/20 is primarily aimed at urban areas which, presumably, planners would wish to avoid creating.
Consultation has taken place on a proposed amendment/adjustment for this policy within more rural areas
and we urge the developers to put this site at the forefront of the proposed changes. Please see the impact
of LTN 1/20 on horse riders and carriage drivers here.
"d. Existing Public Rights of Way (PRoW) in the Garden Settlement must be retained/diverted and
incorporated within any development proposals and s.106 contributions will be required to enhance the
PRoW network.
Enhancement must not be to the detriment of primary intended user. New paths and existing paths should
be created or upgraded to bridleways and/or restricted byways.
Streets & Highways Improvements
i. The main vehicular access points to the site must be provided from the A20."
AND to include safe provision for equestrians and other Non Motorised Users (NMUs)
"j. Suitable and robust measures must be included to minimise vehicular movement towards or along local
lanes that are assessed as having unacceptable levels of increased use."
We agree
"k. Impacts from the development on the local and strategic road networks must be fully assessed
throughout the planning process, mitigation measures identified and reviewed through an ongoing
process of monitoring as part of a 'Monitor & Manage' approach."
We agree
"l. All streets and parking areas should benefit from passive surveillance, landscaping, and appropriate
inclusive provision for pedestrians and cyclists."
AND horse riding

7.2 "Transport & Movement
Infrastructure Delivery"
Provision for NMUs including equestrians must be at an early stage and connectivity to the existing and forthcoming network needs to be carefully protected and enhanced wherever possible.
Connectivity along, and across, the A20 should include equestrians so path provision needs to ensure the safe passage of all NMUs.
At no time must existing PRoW be adversely affected by construction. Diversions should take place before building starts and be maintained and protected throughout.
We would like to see the provision of infrastructure for non motorised use required by the same stage of development as infrastructure

Attachments:


Our response:

Comment noted.
Figure 11: Access & Movement Framework sets out the key routes and connections for active travel.
Principles and guidelines relating to active travel are set out at Chapter 6.11 which requires a well connected network of pedestrian and cycle routes.
Officers agree that an additional principle should be added to refer to equestrian movement through the site.

Comment

Heathlands Garden Settlement SPD

Q34: Do you have any other comments on the Draft Supplementary Planning Document?

Representation ID: 383

Received: 10/12/2025

Respondent: British Horse Society North and West Kent

Representation Summary:

8 “Approach to Transport Assessment and Mitigation
Heathlands Garden Settlement is taking a vision led approach to transport planning– to maximise the use of sustainable modes of travel."
Horse riding and carriage driving ARE sustainable.
8.1.6 "The following set of transport related analysis and information will be required as part of preparing planning applications based on a 'vision & validate' approach, which will be reviewed as the Garden Settlement is built out utilising a Monitor & Manage Strategy:
a. Active travel strategy and site wide Travel Plan."
To include horse riders
"b. Public transport strategy.
c. Vehicle access strategy.
d. Highway Modelling Assumptions and results for reasonable scenarios as agreed with the Highways Authorities.
e. Road Safety appraisals as required by KCC Highways and National Highways, including development of approved Road Safety Audit briefs and assessments where required"
To include A20 road crossings for non motorised users
"f. Mitigation strategy including measures with preliminary designs and associated modelling."

9.2 "Developer Contributions and Funding"
Funds for improvements to existing PROW as well as the creation of new should be expected to provide the connectivity and enhancement of the network for all NMUs

9.3 "Pre-Application Working Pre-application engagement with the local community and relevant local stakeholders including the local communities must be undertaken, to ensure that proposals continue to evolve with local community engagement in accordance with National Planning Guidance.
Additionally, applicants must engage directly with any relevant statutory consultees, including Kent County Council, National Highways, the Environment Agency, Sport England and others as appropriate."
Pre-application engagement should also include, as a minimum, KCC Public Rights of Way, British Horse Society, Ramblers, etc. when it comes to PROW and other non motorised user routes.

"Appendices
In relation to 'Movement'
Design Codes must demonstrate how proposals have incorporated a well-designed movement network and suitable hierarchy of street types that:
• is safe and accessible for all;
• functions efficiently to get everyone around, takes account of the diverse needs of all its potential users and provides a genuine choice of sustainable transport modes;
• limits the impacts of car use by prioritising and encouraging walking, cycling and public transport, mitigating impacts and identifying opportunities to improve air quality;
• promotes activity and social interaction, contributing to health, well-being, accessibility and inclusion;
•"
All the above must include, and take into account, equestrians

"In relation to 'Public Space'
Design Codes must demonstrate how public spaces within the Garden Community will create a healthy and successful place, encourage social interaction, and integrate with movement corridors and a wide mix of uses. Proposals must:
• include well-located public spaces that support a wide variety of activities and encourage social interaction, to promote health, well-being, social and civic inclusion;
• […] have public spaces that feel safe, secure and attractive for all to use; and […]"
All the above must include, and taken into account, equestrians for the reasons outlined in Appendix 1

"Appendix B: Anticipated Developer Contributions to be secured by legal agreements
Public Transport and Active Travel
Off-site Highway Improvements
Green Space and Open Space"
All the above must include, and taken into account, equestrians for the reasons outlined in Appendix 1

As previously requested above, we urge the Council to read the information contained within Appendix 1 below which explains why the inclusion of equestrians is beneficial to everyone, including the tax payer. As always, we would welcome the opportunity to work with the Council and, indeed, future applicants to ensure the inclusion of equestrians in development plans.

Attachments:


Our response:

Comment noted.
Officers agree that the SPD should make additional references to the potential for equestrian and horse riders within the site and proposals.

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