Gypsy, Traveller and Travelling Showpeople Development Plan Document

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I would like to make the following comments on both the MBC Gypsy, Traveller and Travelling Showpeople Plan dated November 2025 and the supporting Appendix C of Volume 2 of the sustainability appraisal of the Plan. The plan details the overall vision and key objectives to deliver sustainable accommodation for Gypsy and Travellers which is also the guiding principals embedded in all the MBC housing developments Plans to ensure any development is sustainable and meets MBC sustainability criteria for everyone in the Borough irrespective of their ethnicity. These criteria are quite rightly rigorously applied and enforced on all Developer or individual Settled community planning applications however Appendix C states that the majority of the existing sites and those identified to be expanded are unsustainable and do not meet the MBC planning sustainability criteria. Global warming effects us all irrelevant of ethnicity and it is totally unacceptable for one ethic group to be seen as not being subject to this key planning principal as it will create tensions with the settled community contrary to the Plan objectives and could be seen as ethically prejudice whilst placing an increased burden on the Gypsy and Traveller site residents of car transportation. As stated in Appendix C many of the current sites in the RSC’s mean the Gypsy and Traveller’s have to travel several miles along unlit roads with no public transport, no footpaths to access fundamental services of shops, Healthcare facilities, schools, railway stations etc… I regularly see Mothers with babies in arms and in push chairs as well as children walking along these roads to access the RSC’s facilities. This is as a direct result of planning permission being granted by MBC disregarding the planning policy of sustainability and I fear this will eventually lead to serious injury or even death as these sites are expanded. There is a real and present danger this will further deter any integration with the Settled Community, as a larger Gypsy and Traveller site is ethnic homogeneity, enhances spatial confinement, is mutually distance and retreats into the private sphere of the patriarchy family is not facilitating integration but re enforcing separation which is contrary to the vision and objectives outline in the plan. This isolation of larger sites also sharpens the boundary between the Gypsy and Traveller Community and the Settled Population driving them to the margins, reinforcing disidentification and prejudice. Again, all of which is contrary to the vision and objectives of the plan. The Plan document acknowledges that at a Parish level there are substantially higher populations of Gypsy and Traveller communities and maybe even higher as there is often a reluctance to disclose their ethnicity. The Plan should also acknowledge in the background that these disproportionate higher levels of Gypsy and Traveller populations are as a direct result of the previous MBC planning decisions. In particular their decision to ignore MBC’s own sustainability criteria and the NPPF guideline which insists that the scale of such sites does not dominate the nearest settled Community and the decision to ignore the cumulative effect on the Parish’s population and the local landscape. The Parish level statistics clearly demonstrate that these Parishes are currently have a disproportionate number of Gypsy and Traveller pitches and any further increase would further breach the NPPF guidelines regarding dominating the nearest Settled Communities. A personal concern has been realised in that the output of these cumulative decisions has been be used as the basis of this development plan with existing unsustainable sites being enlarged to meet the identified need. It seems the Plan has been retro fitted to the “ easy “ option for MBC ignoring the key objectives including sustainability by expanding existing sites or relying on the Gypsy and Traveller community to source and purchase the land, apply for planning permission or retrospective permission, all leading to larger, Irregular and unmanaged Gypsy and Traveller sites which could be seen as creating sort of “ghettos” rather driving integration and delivering on the improvements health, safety, education and employment outlined as key important objectives in the Plan. Point 65 states that rural locations are generally more suited to the keeping of horses and whilst this is true it should not be used as a reason to sites to be located the rural areas. Horse ownership is not an accommodation need and not an essential part of keeping to a nomadic lifestyle. Today the majority of Gypsy and Travellers use motor vehicles and touring caravans to maintain a nomadic lifestyle which do not need to be located in rural locations. To include a comment regarding horse ownership is stereotyping and could be seen as ethnic discrimination. Likewise caravans are regularly seen parked in urban areas and it should not be suggested that rural locations offer better manoeuvring ability especially when the rural roads are often very narrow with occasional passing bays. In the spatial strategy point 68 of the Plan states that Maidstone Town Centre and the Urban areas are most sustainable locations for development and in the forward it states that 20,000 new homes will be built by 2038 but no sites for Gypsy and Traveller pitches has been or will be allocated in Urban areas. The larger residential building developments are generally closer to shops, transport links and health care facilities as a pre requisite of obtaining planning permission. Therefore a requirement to include Gypsy and Traveller accommodation should be mandatory on any new development along either an element of Social housing and this should not be waived by paying a large community infrastructure level as seems to be happening on other developments to reduce Social Housing quotas. Point 68 also states that the closest urban site at Coldharbour Lane is owned by Tonbridge and West Malling Council to meet their Council needs. The Plan does not state whether MBC have looked at this approach with a view to buying land outside the Borough to build a managed site or sites to meet their accommodation needs and meet their sustainability and design criteria’s. The Council should actively pursue this approach which is also used by London Borough’s to meet their social housing needs. Point 72 regarding Invicta Barracks. The document does not give clear reasons why this site is not suitable as an urban location. Development of such brownfield sites has been undertaken before and heritage and environmental constraints have also been accommodated. The site is an ideal site for development of a managed site. It is located near all the amenities, transport links, road networks, healthcare facilities, schools and its location facilitates integration with the local settled community making it an ideal site for a managed site by either MBC, a registered landlord, housing association etc… If after another detailed review, the Invicta Park Barracks is deemed not suitable for a Gypsy and Traveller site then it should not be suitable for any residential settled housing as this would be both incongruous and discriminatory. Safeguarding The safeguarding of permitted sites should include a mechanism to ensure that the sites are solely used by Gypsy and Travellers. There are many mobile homes on current permitted sites that are rented out on a weekly rental basis to non Gypsy and Travellers. Enforcing this requirement will create additional accommodation. Safeguarding should also include a programme to ensure the current permitted sites have met the original planning conditions and they meet the design and health and safety guidelines to ensure the well being of all the residents. Site Design I welcome the design policy on design and layout of new sites which should be enforced however the provision of paddocks, field shelters and other equine facilities should not take preference over providing residential accommodation as horse ownership is not an essential need and can be satisfied by using local livery services both self serviced and managed. Health and Safety: The policy should cover sanitation detailing how dirty water, rain water and sewage are managed on the pitch from both the amenity block or day room to ensure the health and safety of all the residents and to negate any environmental impact. When designing the layout of a site, careful consideration must be given to the health and safety of residents, and in particular children, given the likelihood of a high density of children on the site, vehicles and caravans. It is important to ensure that appropriate traffic calming measures are considered for all sites ensuring that appropriate drainage is accommodated within the scheme to allow for the effective passage of surplus water. Clear and effective signage should be introduced including clear directions should be in place to indicate the location of hydrants and other access points for the fire service etc when attending an emergency on site. The need for separate vehicular/pedestrian access should also be considered. Access for emergency vehicles: Consultation with the local fire and rescue service officer at the designing of a site to gain advice as to a minimum turning and reversing requirements of emergency vehicles in confined spaces for example, which may impact the design. To increase potential access points for emergency vehicles, more than one access route into the site is recommended. Where possible, site roads should be designed to allow two vehicles to pass each other. Specific guidance should be sought from the local fire authority for each site. Although roads on sites do not require adoption, it is recommended that all roads are constructed to adoptable standards of MBC to avoid future maintenance costs, and in anticipation of increased wear and tear due to frequent movement of heavy vehicles. Security The Site layout can play an important role in avoiding a sense of enclosure and isolation amongst Gypsies and Travellers. The aim should be to ‘design out’ crime and social exclusion and ‘design in’ community safety and social inclusion through openness of design, allowing ease in passing through, whether walking or driving. Care also needs to be taken to ensure that proper concern is shown for the safety of residents and children. Site layout should maximise natural surveillance enabling residents to easily oversee all areas of the site. Scheme specific advice on security provision for the site should be obtained from the Police Community Liaison Officer. I have a real concern that many of the current larger Gypsy and Traveller sites do not meet both the Health and Safety requirements and the access to emergency services. Additionally comments on Appendix C The detailed Map showing the location of all the existing sites is hard to read but I have a real concern on the numbers used to calculate the reasonable alternative site assessments. So I looked at the data for the Petsfield site really well and it is incorrect. The site was granted 2 pitches over 15 years ago and then had an additional 3 pitches approved and sited in October 2020 under planning application 20/502748. Therefore from late 2020, the existing is 5 and not the 2 stated in the appendix C. C.1.1.5 states the assessments were based on the baseline information given by the Council. This raises serious questions about the validity of all the numbers provided on both documents. How many of the other site numbers are wrong ? Was pre 2020 data used and why ? Is the overall base case being used flawed not only on these assessments but in the wider existing site calculations..?