Gypsy, Traveller and Travelling Showpeople Development Plan Document

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Background & General Matters National Highways is the government owned company which operates, maintains and improves the Strategic Road Network (SRN) as the strategic highway company appointed under the provisions of the Infrastructure Act 2015 and in accordance with the Licence issued by the Secretary of State for Transport. National Highways is a statutory consultee to the planning process. It has a specific obligation to deliver economic growth through the provision of a safe and reliable SRN in line with the provisions set out in DfT Circular 01/2022: The strategic road network and the delivery of sustainable development. Circular 01/2022 is national policy that sits alongside MHCLG NPPF (2024) Further information about National Highways' role in the planning system and how we are aiming to be a proactive planning partner can be found at https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road-network-in-england/ . The Role of Local Plans/DPDs With Regards the Strategic Road Network Each Local Plan/DPD must identify and mitigate as appropriate, the impacts of the polices and development it contains on the SRN. Likewise, individual consented or proposed developments must also identify and mitigate as appropriate their impacts. In doing so, no assumptions can be made regarding the Government or National Highways bringing forward as yet uncommitted schemes that would also mitigate the Local Plan. However, National Highways will work with all parties to seek to identify where, alongside any bespoke mitigations, it may be possible and sensible to look to create cumulative impact schemes covering any combination of Local Plan/ development impacts. Likewise, National Highways will expect all parties to take a pragmatic approach when considering the impacts of emerging Local Plans and/or unconsented applications, using sensitivity testing and other tools. Vision & Validate, Monitor & Manage A key change in national transport and planning policy brought about via C1/22 and the NPPF (2024) are the shift from older style “predict and provide” (ie if demand for road space is forecast, then it is planned for) to “Vision & Validate” and “Monitor & Manage” (ie to look to manage the future through active, sustainable transport and other means, and then keep progress under active review). While the policy and practices continue to evolve, the following may assist: V&V and M&M are based on the achievement of sustainable development supported by active and sustainable travel. Active/sustainable travel includes walking/ wheeling/ cycling (occasionally equestrian) plus public transport plus to a degree EVs (but seeking to reduce reliance on car travel) Ø They should express the Vision (the what do you want to achieve and why, for the plan/ development). To be strategic and long term, the Vision will need to be fairly high level. Ø They should explain the Validate (the how are you going to achieve the Vision in practice – this can include mitigations/ programmes etc but often also the governance, funding, deliverability etc ie showing that there is reasonable certainty the “how” will work in practice). This should be sufficiently detailed to demonstrate it is deliverable/ funded etc but equally allow for evolution over time or new means to achieve the same Vision ends. Ø They should set out the M&M (the how will you know if you are achieving the vision and if you are not, what will you do about it) These need to be enshrined as a golden thread connecting Local Plan/DPD policy/ supporting evidence / the Infrastructure Delivery Plan. With regards this DPD we are content that all this can largely be achieved in conjunction with the adopted Local Plan. Duty To Co-operate We are content that from the National Highways/ Strategic Road Network perspective, the Council and their advisors have met their obligations set out in the Duty to Co-operate. In doing so, as per normal practice, while the SRN with the borough includes parts of the M2 and M20, the evidence base will, and potential impacts and mitigations may, cover a wider area, and may also need to cover non-SRN links. We are content the given the scale of the likely individual developments, their distribution and cumulative impact, that the existing adopted Maidstone Local Plan modelling is sufficient to support this DPD. The degree to which individual sites will need to be supported by their own Transport related evidence can be determined on a case-by-case basis at pre-application or application stage. Going forwards, while the Duty is to be ended in due course, the NPPF (2024) sets out requirements for Council’s to address as appropriate and relevant with other authorities and statutory consultees “strategic matters”. Transport and Movement are strategic matters. The net effect is that the Council will continue to need to work with us to progress the Local Plan/DPD and its evidence base. In due course, the normal practice would be for the Council to reflect the work done in a Statement of Common Ground” ahead of the submission of the Plan to the Planning Inspectorate, with any further updates as necessary before/ during the examination. We commit to using our best endeavours to continue to assist the Council in the production of their Local Plan/DPD and its supporting evidence base. Detailed comments on the R18c DPD We have no objections to the R18c plan per se. But have the following comments

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Policy/ Supporting Text TR7/ TR8 We suggest that text is included in the plan – perhaps within or supporting policies TR7/ TR8 – to cover the following: National Highways, acting as the statutory consultee on behalf of the Department for Transport Secretary of State, will be concerned with proposals that have the potential to impact on the safe, reliable and/or efficient operation of the SRN (the tests set out in DfT C1/22 and MHCLG NPPF2024), by virtue of a) The traffic attracted to, generated by or rerouted as a result of proposals and/or b) the construction, operation or maintenance of a site adjacent to or in close proximity to the SRN. While traffic generated by any GTTS sites is unlikely to be material, if an access is on/close to the SRN it may still be. And any sites located close to or on the SRN boundary will be material. For example, we would need to ensure: • changes of ground level or structures (eg bunds/ community buildings etc) don’t affect the geotechnical integrity of the SRN or create a risk of a structure collapsing into the SRN; • changes to or new drainage infrastructure doesn’t connect to SRN related highways drainage per se nor unacceptably affect SRN related riverine drainage/ nearby land via water flow or quality changes; • boundaries (fencing/vegetation etc) prevent people/ pets etc from straying onto the SRN; • any street or other lighting doesn’t produce glint/ glare/ dazzle / distraction for SRN users. • any development or the expectations of occupiers does not fetter the future ability of NH to operate, maintain and/or improve the existing SRN Thus, text ensuring that National Highways are consulted on any relevant applications should be included in the DPD.

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Policy/ Supporting Text TR7/ TR8 We suggest that text is included in the plan – perhaps within or supporting policies TR7/ TR8 – to cover the following: National Highways, acting as the statutory consultee on behalf of the Department for Transport Secretary of State, will be concerned with proposals that have the potential to impact on the safe, reliable and/or efficient operation of the SRN (the tests set out in DfT C1/22 and MHCLG NPPF2024), by virtue of a) The traffic attracted to, generated by or rerouted as a result of proposals and/or b) the construction, operation or maintenance of a site adjacent to or in close proximity to the SRN. While traffic generated by any GTTS sites is unlikely to be material, if an access is on/close to the SRN it may still be. And any sites located close to or on the SRN boundary will be material. For example, we would need to ensure: • changes of ground level or structures (eg bunds/ community buildings etc) don’t affect the geotechnical integrity of the SRN or create a risk of a structure collapsing into the SRN; • changes to or new drainage infrastructure doesn’t connect to SRN related highways drainage per se nor unacceptably affect SRN related riverine drainage/ nearby land via water flow or quality changes; • boundaries (fencing/vegetation etc) prevent people/ pets etc from straying onto the SRN; • any street or other lighting doesn’t produce glint/ glare/ dazzle / distraction for SRN users. • any development or the expectations of occupiers does not fetter the future ability of NH to operate, maintain and/or improve the existing SRN Thus, text ensuring that National Highways are consulted on any relevant applications should be included in the DPD.

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Appendix A etc Reference should be made in the Glossary and elsewhere, as appropriate, to DfT Circular 01/22 as it comprises national policy for the SRN that sits alongside and carries the same weight as the NPPF. Gypsy and Traveller Call for Sites We have no comments on the exercise and have no suggestions regarding sites. However, we would welcome a conversation with you once the exercise is completed to discuss any sites that if allocated may have implications for the SRN for reasons the same/ similar to those described above regarding traffic and/or boundary matters. Next Steps National Highways is committed to working closely with all parties to facilitate this DPD commensurate with our obligations with regards the safety, reliability and operational efficiency of the SRN. We will work with the Council and its advisors seeking to address any outstanding or newly arising matters ahead of the DPDs submission, examination and adoption.