Gypsy, Traveller and Travelling Showpeople Development Plan Document

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Form ID: 1487
Respondent: Alana Diamond

Disagree

Form ID: 1488
Respondent: Alana Diamond

Strongly disagree

Question 1 - Disagree. I strongly object to the intensification, expansion, and reorganisation of existing sites. It is highly inappropriate to further expand large sites, most of which are over-crowded, with poor layouts, with no proper regard for ecology. Many of these sites large sites are associated with crime and disorder and expanding them will only increase their domination of the immediate settled community (not the nearest village or town but the nearest house or houses). Sites that that are located in a LLV, must not be permitted to grown in size or to subdivide pitches. Enforcement must be a key part of these policies. Without enforcement, any policy will not be effective. To date, enforcement has been non-existent or too little, too late with MBC eventually allowing pitches and sites which has resulted in large, sprawling, unregulated, dominating sites and this must end. It has sent a message to some G&T that they can do what they want, where they want. This is unacceptable and must stop. Our open countryside, LLV and ecology – our legacy for everyone – it must be protected. New sites or the expansion of existing sites must not be allowed when proposed in our decreasing LLVs and sensitive ecological landscapes. To encourage G&Ts to educationally achieve, gain and sustain employment and increase their socio-economic statuses and social mobility, sites and pitches need to be allocated within walking distance (sustainability) to amenities and ideally be interspersed within settled communities. This approach would encourage meaningful interactions and socialisation between the G&T and settled community and in the longer-term reduce tensions. Sites and pitches need to be considered within or on the edge of towns to facilitate this approach and not in the open countryside, and especially not in an LLV. Question 2 - Strongly disagree. It is disappointing to read that MBC has chosen to ignore KALC and Headcorn and Ulcombe Parish Council’s, and several other responses, to the Regulation G&T 18b Consultation around G&T accommodation need figures and calculations. The figures in this 18c Consultation are the same as those set out in 18b – why is this? Why have you not taken into consideration the comments of those who responded to Consultation 18b? These figures and calculations are inaccurate, and over-estimate G&T accommodation need. Therefore, MBC are starting from a flawed position. The G&T populations in Headcorn and Ulcombe are already substantial – indeed they represent some of the largest in the UK. This begs the question, why? The answer is a mix of inaccurate figures, flawed calculations, and a lack of enforcement, which has damaged our precious open countryside, LLVs, ecology and sadly has created tension between G&Ts and the settled communities. Many G&Ts see MBC as an authority that does not enforce or when it does it, it never follows through. This is why we have such an elevated and increasing level of demand. Indeed, for example, in Ulcombe the G&T population (about 222) represents around 25% of the population (2021 Census)! This level is disproportionate to the settled community and not in line with national guidelines. There is tension between the settled and G&T communities and accommodating any more in this locality will not help to reduce tensions, indeed it will do the opposite. G&T communities, according to Government figures, have (on average) reported lower levels of social mobility, and higher levels of being represented in the criminal justice system and being sentenced to prison than the settled community. If MBC are serious about addressing inequalities, then the proposed policy would be to accommodate G&T where there is ready access (on foot) to services, health care, employment, and education. Accommodating G&T in rural area, especially in the open countryside, is highly inappropriate and means that G&Ts must rely on private transport to access health, social care, education, and employment. This is against national G&T policy, which raises the question - why are MBC proposing this policy? G&T sites should be established in towns (or on the edge) where there is ready access to facilities and resources. MBC needs to adopt a policy where new housing developments over a certain volume not only need to provide a quota of affordable housing but also in areas where there is G&T need, they also need to provide G&T pitch provision. This would help to meet G&T accommodation needs and importantly to ensure G&T and the settled community are integrated and this would bring about greater longer term social mobility opportunities and benefits to those G&T communities, which sadly have lower socio-economic status and social mobility statuses. Accommodating G&Ts on huge sites, does not help to encourage G&T to move from being an inward-facing, closed culture that is cut-off from wider society. Huge, intensified sites also increase tensions between the G&T and the local settled community. Cultural differences are made more stark and vast numbers encourages validation of these differences instead of establishing small sites, inter-mixed within existing settled communities, which encourages understanding, socialisation, and acceptance. These large sites are often associated with (and many would say encourage) crime and disorder, which again increases tensions between communities. They are also often over-crowed, with few amenities and are unregulated. G&T policy is supposed to reduce tensions between the G&T and settled communities, yet encouraging and establishing huge sites does the opposite. There are already several established sites that are large, growing, and unregulated and they have grown based on lack of enforcement by MBC, retrospective applications, and an ongoing disregard for national and local planning policy. For example, along the Lenham Road, Headcorn, TN27, where in a short space of time MBC has allowed existing sites e.g. The Meadows, Martins Gardens to grow exponentially all via retrospective planning applications with no or extremely limited enforcement. Indeed, when the Planning Inspector disallowed sites in March 2023 unallowed sites on the Rear of the Meadows, MBC enforcement officials went out to the site and encouraged those on disallowed pitches to apply for planning as they disagreed with the Planning Inspector’s considered view. This makes enforcement a tiger with no teeth and sends a strong message to some G&T that they can do what they like, where they like – and indeed this is what has and still is happening! A substantial number of newer sites have sprung up along Lenham Road and G&T massively outnumber the handful of houses (settled community) that are along the Lenham Road. Sadly, this has only served to increase tension between the two communities – this is not right, fair and is against national policy. MBC has allowed greenfield sites in open countryside in a LLV to be systematically destroyed along the Lenham Road and in other areas of Headcorn and Ulcombe. The settled community would not be allowed to build houses, let alone huge housing estates in open countryside in a LLV – yet G&T are allowed to establish sites, many of which are sprawling, have not regard for ecology, do not meet Kent Design Standards, and do not meet foul water disposal regulations. How does this policy sit with the Landscape Character Assessment 2025/26 consultation – where the LLV Headcorn Pasturelands have been recommended as being in the ‘conserve’ category? How does this sit with MBC commitments to ecology? Taking The Meadows as an example of one of the substantial number of sites along the Lenham Road – this started off as a one or two caravans on a green field site in open countryside in an LLV. It is now a huge, sprawling, over-crowded site, with illegal foul wastewater disposal, with caravans extending deep into the open countryside to form the Rear of the Meadows. There is ongoing crime, disorder associated with this and many of the other G&T sites along Lenham Road. See the March 2023 Rear of the Meadows Planning Inquiry report for evidence of trespass, using neighbouring private land as a human toilet, sheep worrying, invasion of land and erecting caravans on private land, outputting foul waste water onto neighbours land, light pollution, which can be seen for miles, noise from dogs barking for hours, noise from motorbikes being driven around the site, shouting, abuse, threats and intimidation by some of the G&T on this side to the local settled community. Locals find the Meadows site overwhelming, dominating and intimidating. Yet MBC want to add an additional 20 pitches to the Rear of the Meadows – how can this be a good idea? It is also frustrating that a huge G&T unregulated ‘housing estate’ – the Meadows - has been allowed to be established when an application for a housing estate for the settled community, including affordable housing would not be allowed. This one rule for the G&T community and another for the settled community has created tensions and increasing the size of already huge sites is not appropriate and will only serve to increase tensions. This is surely against national policy.

Form ID: 1489
Respondent: Alana Diamond

Strongly disagree

Strongly disagree. For the reasons set out in KALCs, Headcorn and Ulcombe Parish Councils’ responses to Consultation 18b – the proposed G&T accommodation need figures are too high and the calculations are inaccurate. I, and most of the settled community, strongly oppose MBC’s proposed approach to the intensification, expansion, and reorganisation of existing G&T sites. Expanding existing huge sites is against national policy – it amounts to domination – and serves to increase tensions between the settled and G&T communities. It does not facilitate tensions between the G&T and settled communities to ease. Intensification does not allow G&T the opportunity to have the socio-economic opportunities to increase and improve their educational achievements, employment, and social mobility. Instead, MBC is creating huge G&T ghettos – condemning G&Ts to limited socio-economic and mobility. This is to the detriment of G&T in the long-term. The existing huge sites, like the Meadows on Lenham Road in Headcorn, is sprawling, over-crowded, not a pleasant place to live and one that we should not be encouraging in 2026. Having recently walked the full length and breadth of the site, the current accommodation arrangements do not comply with MBC site plans. It is a dense, over-crowded, noisy site without a blade of grass in sight – it is not a place for the young, old, sick, or vulnerable. It is not a site we should be seeking to expand in 2026 and beyond

Form ID: 1490
Respondent: Alana Diamond

Strongly disagree

Strongly disagree. The complete refusal to allow alternative use of sites with permission for G&T accommodation is inflexible. I strongly oppose Part 3 of Policy TR3, the intensification, expansion, and reorganisation of sites. Carte blanche approach to intensification is highly inappropriate. This will encourage yet more unauthorised development and result in even more overcrowded sites with poor facilities and amenities. Part 3 needs to be dropped.

Form ID: 1491
Respondent: Alana Diamond

Disagree

Disagree: The calculated need for G&T accommodation, as already stated, is overestimated and MBC need to review these figures. Each site needs to be reviewed on its merit, but we need to move to a position of not creating huge sites as this will be to be long-term detriment of G&T and the settled community. Instead, small G&T sites interspersed within settled community developments, including new developments is far more appropriate and will in the longer-term increase G&T social-economic status and mobility. Sites should be located within or on the edge of towns to facilitate on foot access to amenities and encourage advancement of much needed opportunities for G&T communities.

Form ID: 1492
Respondent: Alana Diamond

Strongly disagree

Strongly disagree. There is a proposal to allocate an additional 20 pitches to the Rear of the Meadows on Lenham Road in Headcorn – a site in open countryside in an LLV. This is highly inappropriate to allocate yet more pitches to the sprawling, over-crowded, unregulated site, where foul wastewater disposal does not meet legislation. This site is associated with significant ongoing crime, disorder and abuse as reported to the March 2023 Planning Inquiry and has created fear and resentment. More recently there have been reports of child abuse. This site is not a place for the children, the old, sick, or vulnerable. This is not the type of G&T site we should be encouraging, let alone extending in 2026 and beyond. I strongly disagree with the additional pitches for Acres Place, opposite The Meadows. The cumulative impact of G&T sites along the Lenham Road, in open countryside in a LLV needs to be considered. This site has been (like the Meadows) unlawfully established based on retrospective applications following enforcement. They have, without permission, narrowed the highway, increasing road traffic dangers and have shown disrespect to legislation and planning policy. This is not the sort of site we should be establishing or expanding in 2026 or beyond.

Form ID: 1493
Respondent: Alana Diamond

Agree

Agree. I support the establishment of appropriately located public sites as this may be a way of ensuring sites are run in an appropriate, law-abiding way and to reduce breaches of planning, foul wastewater disposal, ecological policy. It should also be a way to manage crime and disorder that is associated with many G&T sites, especially those that are substantial in size. These sites need to be established where there is easy on foot access to amenities and ideally where it allows socialisation with the settled communities with a view to easing tensions. There needs to be maximum number of pitches of no more than an absolute maximum of 20. These sites must be located along the main road and not deep into open countryside. They must not be located in LLVs, areas of national landscapes or where there are ecological sensitives. These are the landscapes that MBC need to protect and should be our legacy for the future of everyone. Site monitoring and enforcement is essential if these types of sites are to be established and these should be baked-into any proposals.

Form ID: 1494
Respondent: Alana Diamond

Disagree

Disagree. National and local policies in relation to landscape, LLVs, ecological designations need to be followed. New sites should not be situated in LLV – these need to be protected, they are our legacy for future generations and establishing new sites will destroy these precious landscapes. Existing sites in LLVs need to be restricted in size, not allowed to increase, and new application for additional pitches or subdivisions of pitches rejected. Enforcement needs to be applied at pace to protect sites on LLVs to ensure they do not increase in size and conditions to protect the landscape, ecology are applied and enforced.

Form ID: 1495
Respondent: Alana Diamond

Disagree

Slightly disagree. Strongly oppose the policy of encouraging and agreeing intensification, expansion and reorganisation of existing sites proposed in other parts of the DPD. This policy is highly inappropriate and needs to be dropped. Existing sites need to be removed from the supporting text (para 125). Many of the existing sites were established via retrospective planning permission (after enforcement) despite being unacceptable in planning terms purely because alternative accommodation was not available. Many of these sites are in open countryside, in LLVs and are highly unacceptable. Many of these sites have grown exponentially, are huge, sprawling, unregulated and associated with crime and disorder, they dominate the local settled community and increase tensions between G&T and the settled community. Cumulative size of sites needs to be taken into consideration – e.g. the vast number of sites along the Lenham Road in Headcorn, which is highly inappropriate. This sheer number and scale of these sites dominate the handful of properties along the Lenham Road – this is not right, balanced, or fair. Domination of the settled community (neighbouring houses) needs to be a key consideration. Domination of the settled community needs to be considered not to the nearest village or town but too the nearest house or handful of houses in the immediate locality of the G&T site. Implementing such a policy would demonstrate fairness and contribute to alleviating ongoing tensions between the G&T and settled communities. The situation on Lenham Road is out of control and cannot be seen as anything else but domination of the settled community, and systematic destruction of open countryside in an LLV.

Form ID: 1496
Respondent: Alana Diamond

Disagree

Disagree. The number of pitches needs to be set out and enforced. Subdivision of pitches must not be allowed, as overcrowding is common and is associated with crime and disorder. Major developments e.g. 10 or more G&T pitches, needs to be supported by appropriate amenity space. High, closed board fences must (not should) not be allowed. Native hedgerows need to be retained (they exceedingly rare are) and established. Ecological guidelines must (not should) be adhered to. Lighting must meet the same standards as set for the settled community in the open countryside, with external lights on sensors. Hard standing that is not permeable must (not should) not be allowed. The disposal of foul wastewater needs to be addressed. Many current sites violate the law in this respect. Those that have fitted sewage treatment plants are too close to buildings and are emptying into dry ditches – which is unlawful. The disposal of wastewater needs immediate and urgent attention and sites should not be agreed unless they can meet all the necessary conditions – which apply to the settled community. Most of the sites are too over-crowded, have not got the space to ensure compliance with wastewater legislation and this is not properly considered when considering site and pitch layouts.

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