Heathlands Garden Settlement SPD

Comment

Representation ID: 820

Received: 16/12/2025

Respondent: Save Our Heathlands

Consultation response to Heathlands Garden Settlement Supplementary Planning Document (SPD) Save Our Heath Lands (SOHL) is a volunteer group formed in September 2019 in response to Maidstone Borough Council's (MBC) proposed Heathlands garden settlement in Lenham. We have strong local support, evident from high petition turnout, packed community meetings, and a large membership and social following. We are not anti-housing. We support sustainable, needs-led development and back Lenham's adopted Neighbourhood Plan, which allocates 1,000+ homes to 2031. Lenham has already accepted substantial growth, more than other Rural Service Centres and Larger Villages in the borough. Over the past six years we have engaged throughout the Local Plan Review: submitting formal responses at every stage, participating in the Inspector's Examination in Public, and responding to the Main Modifications consultation. Despite repeated requests, we were denied a seat on the Heathlands Stakeholder Steering Group established by the Local Planning Authority (LPA) in January 2025. As a major community stakeholder, we are concerned this exclusion may have been politically influenced by MBC leadership. Earlier involvement would have helped shape the SPD at formative stages. We remain committed to constructive engagement with MBC as plan making progresses. On 14 October 2025, SOHL presented a petition signed by 1,500+ residents asking MBC's Cabinet to pause the Heathlands SPD until: A full transport assessment is completed, including modelling with the Kent Integrated Transport Model. Government confirms support for a new railway station. A costed infrastructure delivery plan is published. Meaningful engagement occurs with Lenham Parish Council and SOHL.

The Cabinet neither acknowledged nor debated the petition before sending the SPD to consultation. These conditions are essential to improve the SPD; we set out in more detail below in response to the questions posed within the consultation.

1General Principles

SOHL supports, in principle, the introduction of additional planning guidance for Heathlands; however, the draft SPD is inadequate. In his final report, the Inspector set clear expectations for the SPD, including detailed transport modelling and assessment, clarity on the location of wetland provision, and further work on Landscape and Visual Impact Assessment. These requirements have not been met.

It is also disappointing that a more detailed masterplan was not produced alongside the draft SPD. Such a document would have clarified the scale and form of the development and shown how it would integrate with existing settlements and the wider community.

SOHL considers that the SPD has been rushed for reasons of political expediency. An alternative mechanism - an Area Action Plan (AAP) - would have been more appropriate. Because SPDs are not legally binding and carry less weight than Development Plan Documents (DPDs), an AAP would have provided greater rigour. Its statutory status and independent examination would have helped rebuild confidence and trust in a process that has been significantly eroded by the way MBC and Homes England have conducted their business in recent years.

We therefore reiterate the need for detailed transport modelling and comprehensive masterplanning to be undertaken as part of the SPD's preparation. Until this preparatory work is completed, we must register our strong objection to the adoption of any Heathlands SPD.

General Comments The document as presented in the online website format is not easy to read or understand. The figures and maps provided do not enlarge to a sufficient size to be legible. For those residents not versed in planning documents, it is difficult to consume. This was exacerbated by the seemingly lacking knowledge at the formal drop in events arranged with many of the representatives aware of much of the detail or background.

Specific comments/changes on paragraphs 3.1, 3.1.1 and 3.1.4 can be found in Appendix A.

Phasing and Delivery It is concerning that the consultation includes no questions on the section about phasing and delivery of Heathlands.

SOHL has maintained from the start that the phasing has been hopelessly optimistic for a flagship development purporting to be infrastructure-first. It is inconceivable that completions could begin from 2031 unless the approach being adopted is to start with an orphaned housing estate in the middle of the countryside.

SOHL believes that Phase 1 needs to be split into two subsets to ensure that sufficient infrastructure is delivered as new homes are completed. Bus diversions from the A20 need to be in place from the first occupation of the first unit to ingrain sustainable travel behaviours from the outset. Both accesses should be delivered from a very early part of phase 1 to allow good public

6transport, walking and cycling links through the proposed development. Nutrient neutrality and improvements to the waste water treatment works can not wait until 1.300 units or 2037 arrives. A more granular phasing plan is required to provide confidence in delivery and this should start by splitting phase 1.

Please see attached Appendix A - Comments and proposed amendments to SPD wording

Comment noted.
The SPD was 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 for the draft SPD, 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.
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.
Policy LPRSP4(A) of the Local Plan Review requires the preparation of the SPD together with a Landscape Strategy and Transport Assessment which have been produced.
The Framework Plans and other guidelines set out within 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.
The principles set out at Chapter 10.1 require a site wide Strategic Masterplan and a Strategic Design Code must be submitted as part of the future outline planning applications.
Chapter 9.3 of the SPD sets out guidance around pre-application working including the need to engage with the local community and relevant local stakeholders to inform the preparation of planning applications and all related supporting information including masterplans and design codes.
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.

Comment

Representation ID: 821

Received: 16/12/2025

Respondent: Save Our Heathlands

Vision & Objectives

The Vision and Objectives for the Heathlands garden settlement are commendable but, in our view, unachievable. The vision, objectives, and the wider SPD underplay the relationship with existing settlements and communities, presenting instead a utopian idyll in the middle of the Kent countryside.

Greater emphasis is needed to explain how Heathlands will integrate with and add value to the existing community.

The proposed "green integration" which claims to provide "a sensitive transition between the National Landscape and Heathlands, with strong planting in the northern parcels, and landscaped spaces for village greens, parks, commons and naturalistic green spaces throughout" is unconvincing. It is difficult to envisage a genuinely sensitive transition given the scale of change at the foot of the Kent Downs National Landscape (KDNL); no amount of planting or boundary protection would conceal the resulting impact on the existing countryside.

The objectives need to add more certainty to when and how they will be realised. A development of this magnitude can not wait 30 years until the development is fully realised (if indeed it ever will be) to deliver on these objectives.

Comment noted.
The Green and Blue Infrastructure Framework (Figure 10) and Placemaking Framework (Figure 14) show that there will be landscape buffers and structural planting along the boundary of the site to the north towards Kent Downs National Landscape and the northern most part of this area is protected from inappropriate built development, providing a 350m offset to the National Landscape.
Paragraph 7.1.1. of the SPD notes that given the scale of the development and likely rate of delivery, it is estimated that it will take approximately 20-25 years to build out the residential elements of the scheme.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope and phasing of infrastructure, and 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.

Comment

Representation ID: 822

Received: 16/12/2025

Respondent: Save Our Heathlands

Framework Plans

The framework plans in the SPD lack the supporting studies and assessments needed to make them meaningful and deliverable. In the absence of detailed masterplanning, the four key spatial frameworks read as tentative and unconvincing.

2Comments on each of the presented frameworks are as follows:

Green & Blue Infrastructure Framework

The claim in 5.2.3 that over 50% of the site will comprise green infrastructure is not credible without forcing severe over-densification elsewhere.

The indicative green spaces plan appears to ignore topography and existing land uses; for example, sports pitches are shown on elevated or otherwise unsuitable parcels.

Concentrating a significant share of housing in the northern part of the site conflicts with the aim of protecting views from the Kent Downs National Landscape (KDNL). A 350m offset will not adequately mitigate visual impact.

Given the rural context, every resident should be within 400 metres of nature and parkland.

While the framework promises a new "semi-natural" Country Park for local people and visitors, it does not consider trip generation or parking requirements for a destination of that scale.

Proposed changes: See Appendix A for amendments to paragraphs 5.2.7 and 5.2.11 addressing these deficiencies.

Access & Movement Framework

The document provides little detail on the dimensions and design of segregated, multi-use streets and paths.

Principal movement corridors are shown abutting heritage assets, and there is an over-reliance on secondary connections that fall outside the red line and are not suitable for high traffic volumes.

Bus service proposals are inadequate for a development of this scale. To make Heathlands genuinely sustainable, all residents should be within 400 metres of a bus stop. There is also insufficient detail on how the railway station will be served, including the need for high-frequency routes from the outset to embed sustainable travel habits.

Proposed changes: See Appendix A for amendments to paragraph 5.3.7.

Land Use Framework

Figure 12 is unclear and poorly labelled; it does not explain what each colour or block represents.

The proportionality in the block chart is incorrect: the 50% green block (presumably green infrastructure) is depicted smaller than the 35% orange block (presumably residential/mixed use).

We maintain that the stated land-use proportions are undeliverable without very high densities that are inconsistent with the setting and surrounding countryside.

Placemaking Framework

We fundamentally disagree with the statement in 5.5.1 that "the location for Heathlands has been selected to allow for generous landscape gaps... to avoid the physical

3coalescence of Lenham, Charing Heath and Charing.' The development boundary is less than 600 metres from Lenham's settlement boundary to the east and directly abuts Lenham Heath (and therefore Charing Heath) to the west. Coalescence will not be avoided.

Without a detailed masterplan, it is unclear how higher densities will be "greened" or visually screened from outside the site. We do not accept the claim that placemaking will be "sensitive to the surrounding countryside."

Composite Spatial Framework

The composite plan is extremely difficult to view in the format provided on the consultation website. At the current resolution it is neither legible nor capable of being interrogated.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review. This included the stated quantum of uses and aspects such as the 350m offset to the Kent Downs National Landscape.
The SPD captures 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. Aspects marked as 'indicative' also provides flexibility to allow for more detailed work to consider suitability and impacts.
Principles and guidelines relating to traffic are set out at Chapter 6.11 which requires detailed assessments of impacts on the local and strategic road network and direct reference to minimise impacts on local lanes.
Officers agree that the proportionality of the land use breakdown at Figure 12 has been incorrectly presented and will be corrected for a final version of the SPD.
The allocated land for the Garden Settlement is located beyond the settlement boundary of Lenham village and there are no other allocations in the Local Plan review that would create coalescence with the Garden Settlement.
The Green and Blue Infrastructure Framework (Figure 10) and Placemaking Framework (Figure 14) show that there will be landscape buffers and structural planting along the boundaries of the site with the north (towards Kent Downs National Landscape) and to the west (towards Lenham) to further protect against visual impacts and coalescence.
The Framework plans are not intended to set out detailed proposals as these will need to be evolved through planning applications and are considered appropriate for this consultation. A high resolution version of any final SPD will be available.

Comment

Representation ID: 823

Received: 16/12/2025

Respondent: Save Our Heathlands

Blue Infrastructure

SOHL has repeatedly raised concerns about the proposed wetlands within the Heathlands scheme, which now appear in the SPD under "Sustainable Urban Drainage techniques." The document is almost entirely silent on the requirements for these systems and how they will mitigate harmful impacts on local waterways, including rare chalk streams.

The Inspector's final report stated "the subsequent SPD and masterplanning processes will develop further the detail of how the Heathlands development could be delivered, including scale and location of wetlands and precise trigger points for WWTW infrastructure." This has not been carried out.

Specific concerns we have previously raised about wetlands: Unsuitable locations and technical risks: The indicative plans place wetlands in unacceptable locations and present a range of serious technical issues. Risk to principal aquifer: Several proposed wetlands overlie the Folkestone Formation, creating a clear pathway for contamination of underlying groundwater. The Environment Agency classifies this formation as a Principal Aquifer. Proximity to Source Protection Zones (SPZs): Wetland areas lie 30 m and 45 m from the SPZ boundary. Even if not directly above the SPZ, groundwater moves laterally, making this close enough for sewage held in wetlands to contaminate the SPZ. Floodplain siting: Some wetlands are located directly within the floodplain of a stream that crosses the SPZ. During flood events, contaminated runoff could enter the aquifer, the Great Stour, and ultimately the Stodmarsh SAC. Conflict with wastewater expansion land: Proposed wetlands look likely to encroach on land reserved by Southern Water for future expansion of the existing Wastewater Treatment Works (WWTW). Railway embankment stability: The proximity of wetlands to the railway embankment raises concerns about potential impacts on embankment stability.

4Geological and access constraints south of major corridors: Some wetlands face similar geological constraints and are located south of the motorway and high-speed rail line, creating significant technical challenges for access and delivery.

Ecological appraisal and protection SOHL has also flagged the insufficient appraisal of existing ecology within the Heathlands red line and the potential impacts if the development proceeds. We remain deeply concerned about the protection of aquatic life, including wild trout and the invertebrates they depend on. The banks of local waterways support diverse plant communities that feed a wide variety of insect species, some extremely rare, which must be safeguarded.

Comment noted.
The Plans capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
Officers agree that greater prominence should be given to require developers to consider good practice and guidance in the approach to wetlands and SUDs as produced by CIRIA (the Construction Industry Research and Information Association).

Comment

Representation ID: 824

Received: 16/12/2025

Respondent: Save Our Heathlands

Minerals SOHL and the local community believe that the assumptions for intended mineral extraction at Chapel Farm are overly optimistic and will lead to significant delays in the phased approach.

Furthermore, SOHL remain deeply concerned by the significant volume of HGV movements servicing the new Chapel Farm minerals site as well as construction traffic for the proposed Heathlands development. There remains a severe risk to public safety with this volume of movements for both uses and this needs to be factored into the logistics and servicing plans for both sites. Noise and dust are also key cumulative impacts of jointly working both mineral site and building Heathlands.

Comment noted.
The SPD is providing guidelines and principles, and further work will be required as part of the preparation and determination of planning applications to consider impacts and necessary mitigation.
Appropriate requirements and mitigation measures will be secured through the use of planning conditions and legal agreements.
Issues of impacts and appropriate mitigation related to the minerals operations themselves would be subject to separate consideration as part of the preparation. determination and implementation of applications for the minerals extraction, and be considered against wider policies of the Kent Minerals & Waste Local Plan which includes requirements to consider traffic impacts, pollution and the where necessary suitable mitigation.
Appendix C of the SPD sets out planning application requirements including the need for an Environmental Statement (which will need to consider cumulative impacts), a Construction Management and Construction Traffic Management Plan.

Comment

Representation ID: 825

Received: 16/12/2025

Respondent: Save Our Heathlands

Protecting Heritage and Archaeology To date, the development of Heathlands has given scant regard to existing heritage and archaeology. The indicative framework plans supplied in the draft SPD do not give sufficient consideration to heritage sites and their settings.

Comment noted.
The SPD sets out principles and guidelines relating to 'Protecting Heritage and Archaeology' (6.5) to guide the preparation and consideration of future planning applications for the site.
The Plans included in 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.

Comment

Representation ID: 826

Received: 16/12/2025

Respondent: Save Our Heathlands

Placemaking, Density and Character SOHL finds the proposed densities for the development wholly unacceptable for the setting. Further detailed masterplanning work should have accompanied this SPD in order to better inform residents of the visual intrusion the proposed high-density development will have on the existing landscape. It is unacceptable that this will be left to Outline Planning Application stages.

The highest density category at 50-75 dwellings per hectare is not in keeping for the Kent countryside.

No consideration has been given to existing local character of the area.

Comment noted.
The SPD takes forward policies of the Local Plan Review including requirement of Policy LPRHOU5 to optimise density and ensure the most effective use of land, taking into account the local character and context across the site and wider approach to masterplanning as a whole. The SPD sets out different density ranges for different parts of the site with the highest density only being appropriate in locations with the greatest accessibility to local services and transport, and lowest density in the most sensitive locations.
The Framework Plans capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site.
All future applications will be the subject of consultation and future decision making.

Comment

Representation ID: 827

Received: 16/12/2025

Respondent: Save Our Heathlands

Employment

The employment principles and guidance do not provide a credible plan to deliver 5,000 jobs on 14 hectares of employment land. They are also internally inconsistent: paragraph 6.10.4 questions the suitability of Heathlands for large-scale logistics or distribution, yet principle (e) proposes a mix of uses that includes B8 (storage and distribution).

5The document shows limited consideration of where employment sites should be located and what types they should accommodate, another symptom of the lack of comprehensive masterplanning to date.

Until the type, location, and scale of employment uses are defined with much greater clarity, it is impossible to assess the implications of delivering 5,000 jobs for access, movement, and wider infrastructure requirements.

SOHL maintains, as we did during LPR examination, that homeworking jobs should not contribute towards the 5,000 jobs total.

Objection noted.
The Framework Plans set out in the SPD at Chapter 5 capture the key structuring elements and principles, whilst also allowing for appropriate flexibility for further design work to consider matters in more detail and bring forward appropriate proposals.
Future planning applications will set out more details around the proposed layout of buildings, uses and infrastructure across the site. All future applications will be the subject of consultation and future decision making.
Section 6.10 sets out guidelines and principles for employment, and the types of new employment space to be provided.
Officers do not agree that the SPD is inconsistent in the potential for B8, as whilst the site is unlikely to be suitable for 'large scale' B8 warehouse type development, there could be potential for smaller scale and sensitively designed B8 uses in parts of the site.
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: 828

Received: 16/12/2025

Respondent: Save Our Heathlands

Movement and Connectivity SOHL maintains that the SPD has not been informed by sufficient transport modelling or assessment. As set out in our petition, the SPD should not be adopted until comprehensive modelling is completed using Kent County Council's Kent Integrated Transport Model (KITM), including full junction capacity analysis. Without this detailed work, it is impossible to assess impacts on the existing highway network or define adequate mitigation.

The Inspector's final report recommended "additional detailed content requiring further assessment, for both junctions 8 and 9, as part of any subsequent SPD process and detailed Transport Assessment and for National Highways and KCC to be co-operatively engaged in this work." This has not been carried out.

The Inspector also specified "that the SPD will include a detailed Transport Assessment, which amongst other things will look further at the impact on all surrounding road corridors having regard to a number of factors. As Policy LPRSP13 states, the site specific infrastructure in the site allocation policies are not exhaustive lists and further requirements, stemming from more detailed work, may be required." This, too, has not been done.

This serious omission calls into question the overall validity of the SPD. The Local Planning Authority must address it as a matter of urgency.

Comment noted.
The SPD takes forward the requirements of Policy LPRSP4(A) of the Local Plan Review which established the necessary scope of infrastructure.
The SPD is supported by a Transport Annex and Transport Assessment which have both been published alongside the SPD and set 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: 829

Received: 16/12/2025

Respondent: Save Our Heathlands

Design Codes It is disappointing that a Design Code has not been produced for the SPD and consulted on. It is not acceptable for this to come at Outline Planning Application stages. The design coding principles/guidance have given no acknowledgment or credence to the Lenham Neighbourhood Plan' design qualities and how any new development would be integrated into existing local character and setting.

Comment noted.
Chapter 9.3 of the SPD sets out guidance around pre-application working including the need to engage with the local community and relevant local stakeholders to inform the preparation of planning applications and all related supporting information including masterplans and design codes.