Gypsy, Traveller and Travelling Showpeople Development Plan Document

Disagree

We write to formally object to the proposed allocation of Site C4S (008) – The Lodge, Water Lane, Thurnham – for Gypsy, Traveller and Travelling Showpeople accommodation. Our objection is based on material planning considerations and the site’s failure to meet key requirements set out in Maidstone’s Development Plan, including the Local Plan Review and the emerging Gypsy, Traveller and Travelling Showpeople Development Plan Document (DPD), as well as national planning policy. 1. Flood Risk and Drainage Constraints Water Lane is known locally to experience regular flooding, particularly at the junction with Roundwell. This raises serious concerns regarding the safety and reliability of access to and from the site for residents, visitors and emergency services. Development Plan policies and the emerging DPD require sites to be located in areas where flood risk can be avoided or satisfactorily mitigated, and where development will not increase flood risk elsewhere. The introduction of residential units, associated hardstanding, and additional foul and surface water drainage infrastructure would be likely to increase surface water runoff and place further pressure on existing drainage systems in an area already prone to flooding. In this context, the site fails to meet flood risk and drainage policy requirements. 2. Inadequate Highway Access and Road Safety Water Lane is a narrow rural road with limited passing opportunities, poor forward visibility and constrained geometry, particularly in the vicinity of the proposed site. These characteristics make it unsuitable to safely accommodate the level and type of traffic associated with residential use, including larger vehicles, service vehicles and emergency access. The Development Plan and emerging DPD require that sites can be safely accessed by all vehicles and do not result in unacceptable harm to highway safety. Given the physical constraints of Water Lane, this requirement cannot be met, and the allocation would therefore conflict with highway safety policy objectives. 3. Lack of Pedestrian Infrastructure and Sustainable Access There are no pavements or public footpaths along Water Lane, nor is there sufficient space within the highway corridor to provide them. Pedestrians would therefore be required to walk in the carriageway alongside vehicular traffic. Given the narrow road width, blind bends and vehicle speeds, this creates an unacceptable risk to pedestrian safety. Planning policy requires development to provide safe and suitable access for all users and to promote sustainable patterns of movement. The absence of any safe pedestrian infrastructure means the site fails to meet these requirements. 4. Absence of Street Lighting Water Lane has no street lighting. This further exacerbates the highway and pedestrian safety issues identified above, particularly during hours of darkness and periods of poor weather. The lack of lighting materially undermines the suitability of the site for residential occupation and conflicts with the policy objective of ensuring safe and inclusive access. 5. Impact on Protected Trees and Environmental Assets We understand that there are Tree Preservation Orders affecting at least three trees in close proximity to the site. Development would inevitably involve construction activity, access works and installation of services within or near root protection areas, placing these protected trees at risk. Development Plan policies require proposals to avoid unacceptable harm to protected environmental assets, including trees subject to TPOs. Given the constrained nature of the site, it is difficult to see how development could proceed without adverse impacts, rendering the site unsuitable in policy terms. 6. Impact on the North Downs Area of Outstanding Natural Beauty (AONB) The site lies in close proximity to the North Downs Area of Outstanding Natural Beauty. Residential development at this location would have an adverse impact on the character and setting of this nationally designated landscape, both visually and through increased activity and noise. National planning policy and Maidstone’s Development Plan afford the highest level of protection to AONBs, requiring that great weight is given to conserving and enhancing their landscape and scenic beauty. Development that harms the setting of an AONB should only be permitted in exceptional circumstances, which have not been demonstrated in this case. 7. Previous Planning History and Site Suitability We note that previous planning applications for domestic residential use at this site have been refused. If the site has previously been found unsuitable for conventional residential development on planning grounds, it raises serious concerns as to how it can now be considered appropriate for residential occupation under this allocation. This calls into question the consistency and soundness of the site selection process. Conclusion For the reasons set out above, Site C4S (008) fails to meet key Development Plan and emerging DPD criteria relating to flood risk, highway safety, pedestrian access, environmental protection, landscape impact and overall site suitability. The allocation is therefore unsound and inconsistent with both local and national planning policy. We respectfully request that Site C4S (008) – The Lodge, Water Lane, Thurnham – is removed from the Gypsy, Traveller and Travelling Showpeople Development Plan Document and not taken forward for allocation.