Gypsy, Traveller and Travelling Showpeople Development Plan Document

Disagree

I am writing to formally submit an objection to the inclusion of site C4S-008 in the Gypsy and Traveller Development Plan Document. I contend that the site is not deliverable, not sustainable, and legally unsound for the following reasons: 1. Irreconcilable Conflict with National Landscape Protection. The site lies entirely within the Kent Downs National Landscape (AONB). Pursuant to NPPF Paragraph 182, the Council is duty-bound to give "great weight" to the conservation of this landscape. • The introduction of an engineered caravan site, hardstanding, and associated domestic paraphernalia would constitute significant "urbanisation" of a highly sensitive, tranquil hillside. • Under PPTS (2023) Policy C (Para 14), the Government explicitly states that "When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such development does not dominate the nearest settled community." • The Footnote 7 constraint clearly tilts the balance such that the protection of the landscape overrides housing need. • The addition of development between the M20 Motorway and the existing railway between Maidstone East and Ashford International would be a blight on landscape for existing residents in the Barty Way development as well as the Mallings Lane development. • The designation of the Kent Downs National Landscape is such that conservation and enhancement of natural beauty is necessary. Alien features such as utility blocks, hard standing, caravans and fencing will not enhance beauty. • It is almost certain that additional and unacceptable light pollution would be created, contrary to the Kent Downs Management Plan which would require less unnatural light for habitat and species protection. • The site would also be highly visible in all surrounding areas including public rights of way. 2. Procedural Unsoundness: Unspecified Capacity. The submission of C4S-008 with an "unspecified capacity" renders the Council's Sustainability Appraisal (SA) impossible to conduct with any degree of accuracy. • Without a defined number of pitches, the Council cannot calculate the impact on the narrow Water Lane, the local water table, or the "Biodiversity Net Gain" requirements. • To allocate a site of unknown density is a failure of the Council’s duty to provide a "Justified" and "Effective" plan. • Water Lane continues to be an area with a high risk of flooding when heavy rain occurs, demonstrated most recently on the 8.01.20-25-09.01.2025. The Street was impassable on foot due to the torrent of water streaming down Water Lane. This produced a large area on The Street with upwards of 16cm of water across the whole road. Further destruction to the earth banks in Water Lane would result in further erosion and therefore a much bigger flooding problem. See attachment • The area between Mallings Drive and Roundwell is already designated as an Amber alert warning for flooding within the Maidstone Borough: https://www.getthedata.com/flood-map/maidstone • To proceed with a significant lack of detail is to propose a thoroughly improper site. This would also be contrary to the Environmental Assessment of Plans and Programmes Regulations 2004. 3. Severe Highway Safety Risks (NPPF Para 115). Water Lane is a narrow, rural "C" road characterized by steep gradients, blind bends, and significant width constraints. • The road is incapable of supporting the regular ingress and egress of large, towed caravans and commercial vehicles associated with Traveller sites without significant widening. This would represent a severe and unacceptable impact on highways contrary to NPPF Paragraph 115. • Any attempt to widen the road would result in the destruction of ancient hedgerows and protected banks, further violating AONB protections. • The road is also used frequently by pedestrians and equine riders, to access a Bridleway adjacent High Speed One. These pedestrians and equines would be on their way to Thurnham and the North Downs Way, so making their ability to safely walk or ride would be detrimental to local businesses such as the Black Horse Inn in Thurnham. • The road geometry of Water Lane makes turning circles for caravans and heavy goods vehicles impossible. • The lack of continuous lighting on Water Lane, as well as a lack of footways, forces vulnerable road users (e.g. pedestrians) into direct conflict with caravans or heavy goods vehicles. • Parked vehicles on The Street and Roundwell would likely render the delivery or movement of such towed or static caravans implausible. 4. Impact on Irreplaceable Habitats and Biodiversity The site contains several veteran Oak trees protected by Tree Preservation Orders (TPOs). • NPPF Paragraph 186 states that development resulting in the loss or deterioration of irreplaceable habitats (such as veteran trees) should be refused. • The intensification of use on this site poses a direct threat to the root protection zones of these ancient specimens. The compaction of soil in these zones by concrete hard standing, caravans and heavy goods vehicles would lead to further loss over time of these habitats. • You are reminded that there is a requirement for a 10% biodiversity net gain on developments. The adding of concrete hard standing, on a site that is mostly ‘green’, cannot possibly be a biodiversity net gain. 5. Unsustainable location. The National Policy (PPTS) is very clear that sites should be located with proper and sustainable access to amenities such as schools, medical care and public transport without the need for private cars. • This site is physically separated from core services in Bearsted, meaning there will be an over-reliance on private cars or light goods vehicles. • The gradients and lack of lighting and safe pedestrian access on Water Lane would mean residents of the proposed site would be a barrier to use of walking, cycling or other non-vehicular transport, particularly children and the elderly. 6. Feedback from Gypsy and Traveller Residents. I am interested in your consultations with the Gypsy and Traveller population that you are intending to create sites for. As part of this consultation process, documents show that when planning a site, it is pertinent to have older residents plots located furthest away from any childrens areas to maintain a more peaceful location for the older residents. Putting this site right next to a railway line would not seem to support this vision. The availability of local services also is an issue in Thurnham/Bearsted. Local bus services are minimal as are children’s play areas. One such area highlighted in your consultation document, is actually on a private housing development and as such would not be available to the children on the site, leaving them to have to walk down an unpaved road (Water Lane), to access the only nearest small play area on the Green in Bearsted. Conclusion Site C4S-008 fails the Council’s own "Sieve Test" for site selection. It is a speculative submission by a landowner that ignores the "highest status of protection" afforded to the North Downs. I request that this site be removed immediately from the candidate list and not be carried forward to Regulation 19. Continued inclusion undermines the credibility of the council’s process and we are in no doubt that there are many other far more suitable potential sites to consider. Water Lane is simply not capable of taking a higher volume of traffic, it is often a conduit for significant running water making it even more dangerous for vehicular and non-vehicular traffic alike. I further note that the site, being submitted by the landowner, is not one that is being undertaken for the pure purpose of delivering proper and necessary sites for gypsies and travellers / travelling showpeople – it is instead designed to maximise value for that landowner concerned.