Gypsy, Traveller and Travelling Showpeople Development Plan Document
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New searchDear Sir, Headcorn Parish Council Response to Maidstone Borough Gypsy, Traveller and Travelling Showpeople Plan: Preferred Policies and Potential Sites Regulation 18C Consultation (November 2025) Headcorn Parish Council is the elected body that represents the residents in Headcorn Parish within Maidstone Borough, Kent. Headcorn Parish is a designated Neighbourhood Plan Area and the views expressed in this response have been informed by Headcorn Parish Council's Neighbourhood Plan work (https://headcornpc.org/headcorn- neighbourhood-plan/). Headcorn's Neighbourhood Plan 2022-2038 recently passed both its examination and its referendum and was formally adopted (made) by Maidstone Borough Council on 13th October 2025 (see: https://localplan.maidstone.gov.uk/home/neighbourhood-planning/headcorn) Headcorn Parish Council welcomes the opportunity to respond to this consultation on the Regulation 18C draft Gypsy, Traveller and Travelling Showpeople Plan ("the dDPD"). It considers that a robust gypsy, traveller and travelling showpeople plan is an important component in planning policy and is needed to ensure that development is successful. Unfortunately, Headcorn Parish Council currently has significant concerns about soundness of the proposed policy approach. It therefore considers that more work is needed to ensure that the policies will be judged sound and deliver an effective policy framework. As set out in paragraph 36 of the National Planning Policy Framework ("NPPF"), December 2024 (as amended), to be judged as sound and pass examination, a Local Plan needs to demonstrate that it: has been positively prepared; is justified; will be effective; and is consistent with national policy and, in particular, will enable the delivery of sustainable development, where sustainable development is defined in relation to economic, social and environmental objectives (see the definition of sustainability in paragraph 8 of the NPPF). Headcorn Parish Council does not consider that the proposals, as set out, are consistent with national policy and will not enable sustainable development. In particular, it considers that the drafting of strategic policies supporting intensification, expansion and reorganisation of non-allocated existing gypsy and traveller sites (such as Policy TR1 Part 2.e; Policy TR2; and Policy TR3 Part 3) will result in overdevelopment and will create a range of social and environmental issues. Headcorn Parish Council notes that (unlike small sites) large gypsy and traveller sites within the Parish already create a separation between the settled and gypsy and traveller communities and are associated with a range of social problems, such as anti-social behaviour. The proposed policy approach of intensifying, reorganising and expanding existing sites (without identifying a priori which sites can support this), will exacerbate these issues. Such separation is contrary to the intension of the NPPF, as well as Objective 3 of this dDPD. In addition, the proposed approach will produce results that are directly contrary to the Vision and Objective 1 of this dDPD, in relation to reducing unauthorised development. It is the experience of Headcorn Parish Council that gypsy and traveller development rarely has planning permission prior to occupancy, and even where it does theoretically have permission, the development that takes place bears no resemblance to the one that was permitted (see, for example, the site layout approved as 24/501146/FULL, compared to the site layout in practice). Combined with extremely weak enforcement by Maidstone Borough Council, far from reducing unauthorised development, the proposed approach will create a carte blanche where any site (even sites with retrospective planning permission) can expand unchecked, resulting in large developments that would not otherwise be acceptable in planning terms. The approach will also result in an ever-increasing concentration of gypsy and travellers within a small number of Parishes, including Headcorn. Given the complex needs of many within the gypsy and traveller community, such high concentrations will place a significant strain on education, health, police and social services within the affected areas. Therefore, without an upfront commitment to supporting infrastructure delivery and to fund increased support services, the approach cannot be considered sustainable. Headcorn Parish Council notes, for example, that Headcorn Primary School is already at full capacity and is therefore not in a position to support the additional population increase. The failure to produce Plan policies that will deliver the Vision and Objectives of the dDPD means that, in addition to failing to support the delivery of sustainable development, the draft dDPD also fails the test of soundness on the grounds that it is not justified (in the sense set out in NPPF paragraph 36). Headcorn Parish Council's concerns about the strategy and policies within the Regulation 18C Gypsy, Traveller and Travelling Showpeople Plan, particularly in relation to their sustainability, means Headcorn Parish Council also has significant concerns about the accompanying Sustainability Appraisal. Given Headcorn Parish Council considers a change of policies are needed for the dDPD to be judged sound, it decided not to undertake a detailed response on the Sustainability Appraisal at this time. However, Headcorn Parish Council would be happy to talk through its concerns, if that would be helpful. Our responses to the questions posed in the consultation are included at Annex 1 below. Headcorn Parish Council considers that the issues raised in its response to Maidstone Borough Council's Gypsy, Traveller and Travelling Showpeople Regulation 18b Consultation are also relevant for this dDPD, particularly in relation to estimated need. For convenience, it therefore includes a summary of the issues raised in its Regulation 18b response, as well as the responses to individual questions in Annex 2. Question 1: To what extent do you agree with the proposed Vision and Objectives of the Gypsy, Traveller and Travelling Showpeople Development Plan Document? Partially disagree. Headcorn Parish Council considers that the Vision for the dDPD could do more to discourage unauthorised development. Indeed, far from discouraging it, as worded, the Vision implicitly condones unauthorised development as necessary. Headcorn Parish Council does not consider that the implicit condoning of unauthorised development is sound as it: is not compatible with the Plan being positively prepared; is not justified; and does not meet the definition of sustainable development. For example, unauthorised development can do considerable environmental damage, such as destroying hedgerows, contributing to pollution of local waterways and worsening surface water flooding through excessive use of hard standing. Headcorn Parish Council also notes that Maidstone Borough Council’s approach to deterring unauthorised development (including enforcement action), is much stricter in relation to the settled community than it is for the gypsy and traveller community. This creates tensions between the two communities, as it is perceived as unfair and undermines trust. Therefore, to meet the definition of soundness, as well as in the interests of fairness, Headcorn Parish Council considers that the second and fifth bullets of the Vision should be redrafted, to avoid implicitly condoning unauthorised development, so that they read: Sufficient suitable land/sites available to meet the identified need for accommodation including that of different tenures The same opportunities and responsibilities as the borough’s settled community, including a requirement not to undertake unauthorised development. Question 2: To what extent do you agree with the proposed spatial strategy policy? Please provide comments to support your answer. Strongly disagree/partially disagree. In relation to the drafting of Policy TR1: Spatial Strategy: For the reasons given in its response to the Regulation 18b consultation, Headcorn Parish Council considers that the target of 529 pitches for Gypsy and travellers set out in TR1 Part 1 is too high. In relation to TR1 Part 2 of the policy, Headcorn Parish Council: is pleased to see that Garden settlements have been included as an option within the spatial strategy, and considers that development of these settlements provides a unique opportunity to provide well integrated gypsy and traveller accommodation (TR1 Part 2.c) to meet the calculated need. considers that the policy for Rural Service Centres and Larger Villages needs to be clarified to make clear that it refers to development within the settlement boundary set out in the adopted Local Plan, not within the wider parish (TR1 2 Part 2.d). This would bring it in line with Maidstone’s adopted Local Plan (“MBC LP”). strongly opposes the proposed approach of giving a carte blanche for the intensification, reorganisation and expansion of existing gypsy and traveller sites within the countryside (TR1 Part 2.e.i). (See below for proposals on tightening the proposed rules.) Headcorn Parish Council considers that larger, privately-owned gypsy and traveller sites in the countryside are a major source of problems and should be avoided where possible. It therefore considers that, with the exception of Council owned/run sites, the development of greenfield sites within the countryside should be restricted to minor development only, including rules to avoid gaming the system by first subdividing a field and then applying for permission for each subdivision separately (TR1 Part 3). Headcorn Parish Council would like to see explicit mention of the fact that the Development Plan includes Neighbourhood Plans added to Policy TR1 Part 5, to ensure these are given appropriate visibility. Headcorn Parish Council considers that the proposed approach to intensification, expansion and reorganisation of existing gypsy and traveller sites in the countryside is neither justified nor consistent with sustainable development. In particular, it considers that: it is likely to encourage not deter unauthorised development, given the high likelihood it will be subsequently authorised (in line with current practice). Unauthorised development is often associated with significant detriment, but under the proposals once retrospective permission is given further expansion can take place, creating perverse incentives. it will result in overcrowded sites with poor amenities, eroding the living standards of residents and will lead to a range of social problems. This is particularly true as intensification is likely to take place without prior planning permission, and the proposed approach will make it harder to challenge. it will result in further concentration of the gypsy and traveller population within a few Parishes (including Headcorn), as the proposals would mean that development will mainly take place where there is existing development. This will exacerbate existing issues and can only be considered sustainable, if it is supported by significant infrastructure investment and an upfront commitment to fund the education, health, police and social services needed to support the gypsy and traveller communities, who often have a range of complex needs. This is lacking from the current Plan, which makes no reference to required enhancements to infrastructure and support services to support the proposals. it is likely to result in development that creates a range of landscaping and access issues and that will be contrary to the relevant policies for the area in question, but will be hard to challenge. For example, it is likely to result in a continuation of current development practices that result in developments where each individual unit has its own access onto the highway system (rather than a single access for the site as a whole), resulting in the suburbanisation/urbanisation of the countryside, as well as environmental harm. For example, the site layout approved under 24/501146/FULL, involved a single access point for the site as a whole, and a development that would be in keeping with existing development patterns in the countryside and would preserve trees and hedgerows to encourage wildlife. In practice when the site came to be developed, most of the hedgerow has been torn out and individual entrances to the site have been added to highway (Love Lane) without permission, with high fences and other impermeable barriers added that are more suitable for an urban setting. This type of change will be harder to prevent under the proposed policy, given the explicit permission of reorganisation. 3 It is contrary to one of the rationales for why gypsy and traveller development needs to be in the countryside set out in paragraph 65 of the dDPD, namely the keeping of horses, as site intensification and expansion will reduce land available for this use. Headcorn Parish Council recognises that for individual families, as their children grow, may need more accommodation to deal with this (in the same way the settled community may seek to add an extension). It considers that this could be dealt with by allowing for the addition of more touring caravans to accommodate children, rather than a blanket permission for site expansion and intensification. Headcorn Parish Council notes that larger sites in the countryside are in general the ones that create significant issues. It therefore considers that large sites should be avoided where possible and should ideally only be supported where they are Council owned and/or run to prevent problems. Reflecting the problems cause by larger sites, Headcorn Parish Council also considers that any major development in the countryside (defined in the NPPF as “development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more”), should only be allowed where it comes forward as an allocated site within the Local Plan (and that this should apply to both the settled and gypsy and traveller communities). This would ensure proper scrutiny of any proposals and a consideration of sustainability issues. Headcorn Parish Council notes that under the new rules for Local Plans, there will be regular opportunities for sites to come forward as allocated sites within the Local Plan and therefore does not consider that prohibiting large developments on unallocated sites is overly onerous, considering the planning benefits of doing so. Headcorn Parish Council therefore considers that much stricter rules should be applied to any permitted intensification, expansion or reorganisation, in order to limit potential detriment and reduce perverse incentives. To achieve this, it considers that Policy TR1 Part 2.e.i should include much stricter rules for intensification, reorganisation and expansion, namely that it can only take place where: it represents the addition of touring caravans to accommodate young adult children of the existing residents (in other words allowing the accommodation to expand to meet the needs of a nuclear family unit); or is limited to one or two units within existing site boundaries, that use the existing site access and where the broader site as a whole (ie. including all the units within the original field boundary, such as any previous subdivisions) would not be defined as a major development (ie the final development within a field will involve fewer than 10 homes and a site of less than 0.5 hectares or 1.235 acres).
Strongly disagree. For the reasons set out in its response to Maidstone’s Regulation 18b consultation, Headcorn Parish Council considers that the estimated need is too high. Headcorn Parish Council also strongly opposes Maidstone’s proposed approach to the intensification, expansion and reorganisation of gypsy and traveller sites. It considers that the proposed carte blanche approach to intensification, expansion and reorganisation of sites is neither justified nor consistent with sustainable development. In particular, Headcorn Parish Council considers that it is likely to encourage (not discourage) unauthorised development, with all the detriments that brings, and will result in overcrowded sites with poor amenities that erode the living standards of existing residents. It is also likely to undermine integration between the settled and gypsy and traveller communities, as large sites are typically more closed off. 4 Headcorn Parish Council notes that the proposed approach, far from identifying “broad locations” for development, would effectively permit development anywhere within the Borough. Furthermore, under the policy, any future unauthorised development that takes place and is given retrospective planning permission will then be allowed to expand, creating perverse incentives. In addition, to avoid creating both social and environmental harms, it is important to avoid overdevelopment. This is particularly true as many sites with existing permission were only given permission retrospectively, often not because they were acceptable in planning terms, but because no alternative sites to accommodate occupants were available. Expansion on these sites would exacerbate existing harms and would be contrary to the principles of sustainable development. Headcorn Parish Council notes that the proposed approach is also flawed, as the dDPD suggests only 45% of existing sites are likely to be suitable for intensification or expansion, but does not make clear that permission will only be given where the site is suitable. There is a strong presumption that any existing site can opt for expansion, given it is classified under this policy as a “broad location for growth”. This policy will also add to the concentration of gypsy and travellers in individual parishes with existing high concentrations. This will exacerbate tensions. In addition, given the complex needs of many in the gypsy and traveller communities, Headcorn Parish Council considers that the resulting development pattern would only be sustainable, if it were supported by significant investment in infrastructure and a commitment to increase funding upfront for education, health, police and social services. This commitment is lacking from this dDPD. Headcorn Parish Council considers that in order for the dDPD to be judged as positively prepared, justified and enabling sustainable development, the proposed approach should be changed so that MBC instead looks to allocate sufficient sites, while allowing small windfall developments that otherwise meet Development Plan policies (ie to meet the requirements of both the MBC LP and relevant Neighbourhood Plans). Such windfall developments could be on either existing or greenfield sites, but the key would be that they would otherwise meet the requirements of the Development Plan, in other words that they were acceptable in planning terms, not simply that they were on existing sites.
Headcorn Parish Council is broadly comfortable with Parts 1 and 2 of Policy TR3: Safeguarding permitted sites, although it is concerned that that a blanket refusal to allow the alternative use of sites with permission for gypsy and traveller accommodation is too inflexible. However, Headcorn Parish Council strongly opposes Part 3 of Policy TR3 covering the intensification, expansion and reorganisation of gypsy and traveller sites. It considers that the proposed carte blanche approach to intensification, expansion and reorganisation of sites is neither justified nor consistent with sustainable development. In particular, it considers that it is likely to encourage unauthorised development, with all the detriments that brings, and to result in overcrowded sites with poor amenities. Headcorn Parish Council further notes that intensification and reorganisation of sites is not required to achieve the purpose of Policy TR3, namely the Safeguarding of permitted sites, by preventing their conversion to alternative uses. Therefore, in order to ensure that Policy TR3 will meet the definition of sound, Headcorn Parish Council considers that Part 3 of the policy should be dropped.
Headcorn Parish Council will provide its assessment of the specific allocations set out in Policy TR4: Accommodation on allocated sites, in its response to question 6 below. In general terms, Headcorn Parish Council supports an approach that meets the identified need for gypsy and traveller accommodation through site allocations within the Local Plan. It considers that site allocations, rather than a reliance on other options such as the intensification and expansion of existing sites, should be the preferred route to meeting identified need. In particular, Headcorn Parish Council considers that any development that would meet the threshold of a major development set out in the NPPF (namely that it would involve a “development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more”) should only be permitted where it comes forward as an allocated site within the Local Plan. This would allow for proper scrutiny and an assessment of the relative sustainability of different options. In considering whether a site would constitute a major development, Headcorn Parish Council considers that existing development on the site as a whole should be included, to avoid creating major developments by stealth. Headcorn Parish Council notes that: the sites carried forward from the existing LPR would result in 22 new pitches; if accepted, the sites that have come forward through the call for sites with nominated site capacity would create an additional 175 pitches; and 5 additional sites have been proposed through the call for sites with unspecified capacity. For the reasons set out elsewhere, Headcorn Parish Council considers that the calculated need for pitches is likely to have been overstated. However, as set out in the Table following paragraph 50 of the dDPD, the short-term need for pitches amongst households meeting the PPTS definition of gypsy and traveller is for 251 pitches. Furthermore, the dDPD identifies that 75 new pitches have been granted permission since 2023, meaning only 176 additional pitches are now needed to meet demand from gypsies and travellers over the first 5 years of the plan period (2023-2027), with an additional 56 pitches needed for the next 5 years. Therefore, for the first 10 years of the Plan period, 232 additional pitches are needed. Even without any contribution from the five sites that did not quantify potential capacity, assuming the sites that have come forward are acceptable and are allocated as part of the final Plan, the identified capacity is for 197 pitches. This more than meets the identified demand for the first 5 years of the Plan. Combined with potential capacity on the five unspecified sites, as well as any further suitable sites that come forward through the call for sites, the identified sites are also likely to meet demand for the first 10 years of the plan period. As Local Plans will need to be reviewed every 5 years, Headcorn Parish Council considers that this eliminates the need for the proposed blanket approach supporting site expansion and intensification proposed elsewhere in the Plan. Putting stricter criteria on when site intensification, expansion and reorganisation would be allowed would still be compatible with meeting identified need. On a separate point, Headcorn Parish Council considers that it would be useful to list the site according to parish, rather than ward boundaries. This would make it easier to identify where sites are located and their likely proximity to local services and jobs markets.
Headcorn Parish Council will confine its response on potential sites, to sites within Headcorn Parish itself. There are two proposed sites in Headcorn Parish: C4S (004) Acres Place for 6 pitches, with access from Lenham Road; and C4S (002) Land adj. to Shenley Corner for an unspecified number of pitches. C4S (002) Land adj. to Shenley Corner: Headcorn Parish Council considers that of the two sites in the Parish, the site C4S (002) Land adj. to Shenley Corner is the most suitable to be allocated. The site is close to the main road (A274) and a bus stop, allowing for the use of public transport to access local facilities, and would be close to a cluster of other developments on that crossroad, meaning its impact on the countryside and local wildlife would be more limited than elsewhere in the countryside. Depending on the details of the final proposal, Headcorn Parish Council is therefore minded to support this proposed site, providing: it is served by a single point of access onto the site (rather than multiple entrances), for safety reasons ideally not onto the A274 itself; sufficient traffic calming measures can be added to the A274 to make entrance onto the site safe; the identified flood risk can be managed in an effective way. Environment Agency flood mapping suggests that while the risk of flooding associated with this site is currently low (0.1% to 1%), the risk associated with parts of the site will increase to medium (1% to 3.3%) for the period 2036-2069; the proposals for site design, access and landscaping will conform with the requirements of Headcorn’s Neighbourhood Plan, as well as the Development Plan more broadly; and particularly if the allocated site is for a major development (of 10 or more homes), the site should ideally be Council run (as there appear to be fewer problems associated with Council run sites). C4S (004) Acres Place: Headcorn Parish Council notes that it is unclear if the 6 pitches associated with the proposed allocation C4S (004) Acres Place are in addition to, or instead of, the 8 pitches proposed as part of planning application 25/501709/FULL. In general, given its location, Headcorn Parish Council does not consider that C4S (004) would be a suitable allocation, if it is in addition to the planning application (ie for 14 pitches in total). However, a smaller allocation might be suitable, although to avoid potential conflicts, particularly with other gypsy and travellers within the immediate vicinity of C4S (004), Headcorn Parish Council considers that development on that site is only likely to be successful, if it is Council run. In addition, to be made acceptable, Headcorn Parish Council considers that the policy supporting development of the proposed site should include a requirement that: it is served by a single point of access onto the site (rather than multiple entrances); sufficient traffic calming measures can be provided on the Lenham Road to make entrance onto the site safe; and the proposals for site design, access and landscaping will conform with the requirements of Headcorn’s Neighbourhood Plan.
Headcorn Parish Council supports the ambition to increase the supply of public sites within the Borough, as it considers that doing so would help ensure enforcement of planning policies could be effective. An increased supply of public sites would allow enforcement officers to point to the availability of affordable pitches to rent as an alternative location when seeking to eliminate unauthorised developments. Therefore, Headcorn Parish Council broadly supports Policy TR5: New public site provision, and considers that an expansion of the supply of public sites is needed for the dDPD to be judged as positively prepared. Headcorn Parish Council notes that the existing public sites within the Borough have low pitch turnover, waiting lists and relatively few problems compared to the larger privately run sites within Headcorn Parish. Headcorn Parish Council therefore has a strong preference that where sites of more than two pitches are allocated within the Parish, that these should be Council run. Headcorn Parish Council notes the discussion of a maximum site capacity of no more than 20 pitches set out in paragraph 120 of the dDPD. Headcorn Parish Council considers that this should be set as the maximum capacity for all development in the countryside (ie outside of existing settlement boundaries), not just for public site provision. This maximum should also limit any potential intensification or expansion of sites. In general, Headcorn Parish Council considers that, with the potential exception of sites that are located on (or abutting) a main road, major developments (of 10 or more homes) should be avoided in the countryside.
Headcorn Parish Council is broadly comfortable with the proposed monitoring and review indicators, but considers that additional indicators are needed. A. Headcorn Parish Council considers that indicator GT-6 needs to be supplemented with an additional indicator on the number of unauthorised developments. It is unauthorised developments, rather than encampments, that are of primary concern within Headcorn Parish. B. Headcorn Parish Council considers that until planning policy is backed by robust enforcement action, there will be no incentives for gypsy and travellers to abide by planning policy rules, leading to continued unauthorised development. Tracking enforcement is therefore needed in order to give visibility to this important tool of 11 planning policy and to deliver on the plans objectives. Therefore the monitoring and review indicators should be revised to include: i) the number of cases referred to enforcement; and ii) the number of successful enforcement actions. C. In addition, Headcorn Parish Council considers that, in order to assess need more effectively, Maidstone Borough Council should also collect information on: overcrowding versus concealed households; affordability; the geographic distribution of gypsy and traveller pitches in the Borough and indicators of where these are disproportionate compared to the settled community; time taken for applications to be processed; and windfall developments.
Parish Council broadly supports Policy TR6: Rural exception sites. However, it considers that some adjustments are necessary, in order to ensure the policy will be judged sound, as well as to otherwise strengthen the policy, namely: TR6 Part 2.a. To make clear the relevant connections to the local community and employment are of a strong and longstanding nature; TR6 Part 2.b. To clarify either in the policy itself, or the supporting text, that the definition of domination of the settled community is for houses in the immediate vicinity of the proposed development, not in the closest village (which will often be some distance away); TR6 Part 2.d. Headcorn Parish Council considers that a single access point to the whole site is needed to ensure that development is sustainable. The destruction of hedgerows associated with multiple access points is both bad for the environment and leads to development that is more in keeping with an urban or suburban area than the local countryside; and TR6 Part 2.e. It is not just national policy that should be followed in relation to national landscape, ecological and heritage designations. Relevant policies within Maidstone’s Development Plan, including any relevant Neighbourhood Plan policies, should also be followed.
Headcorn Parish Council is broadly supportive of Policy TR7: Accommodation on nonallocated sites. However, Headcorn Parish Council strongly opposes the proposed approach of encouraging the intensification, expansion and reorganisation of existing sites proposed elsewhere within the dDPD and does not consider that the proposed approach is sound. It would therefore like to see the explicit reference to existing sites removed from the supporting text (paragraph 125). Proposed changes to existing sites could still come forward under Policy TR7, but they would be judged in the same way as other sites, without a presumption in favour. This is particularly important as many sites obtained retrospective planning permission despite being otherwise unacceptable in planning terms, purely because alternative accommodation was not available. Judging all sites in the same way would therefore help prevent otherwise unacceptable sites expanding further. Headcorn Parish Council supports ensuring development will not dominate the local settled community and is particularly pleased to see reference to the cumulative size of development on multiple sites within the setting in Policy TR7 Part 1.i. However, where development is taking place in the countryside, Headcorn Parish Council considers that dominance should be judged relative to the settled community in the immediate vicinity of development proposals, not the community in the nearest village. The approach to site size set out in Policy TR7 Part 1.i, is ambiguous as to what is meant here, as it refers to “the nearest settled community”, which could refer to a village. Headcorn Parish Council would like to see the clarification either within the supporting text, or within the policy itself, that the nearest settled community refers to housing in the immediate vicinity of the development (not the local village). It considers that without this clarification the proposals on site size are meaningless, as it is highly unlikely that gypsy and traveller development will ever be larger than a village, and as such without clarification this part of the policy would not be justified. More broadly, Headcorn Parish Council would like the policy on site size for unallocated sites to be strengthened further to ensure that major developments of 10 or more pitches in the countryside (to be counted including any existing pitches on site) would not typically be permitted. Headcorn Parish Council, notes that the NPPF seeks to avoid development in the countryside, except in a relatively few circumstances, and considers that permission for major development would run counter to this. Headcorn Parish Council considers that major development should only be permitted on sites that have been allocated through the Local Plan process, rather than unallocated sites, to allow for proper scrutiny and an assessment of the relative sustainability of different alternatives. The supporting text at paragraph 127 refers to the need comply with Policy LPRSP9 within the MBC LP. However, the MBC LP is not the only relevant policy within the Development Plan for Maidstone, particularly where there is a Neighbourhood Plan in place, as is the case for Headcorn. Headcorn Parish Council would therefore like to see the final sentence of paragraph 127 expanded to refer to “and any other relevant Development Plan policies”. Finally, while broadly supportive, Headcorn Parish Council considers that the parts of TR7 dealing with “Living environment” (Part 1.e) and “Landscape character” (Part 1.f) would be better located in Policy TR8, as the considerations are relevant to both allocated and unallocated sites.
In relation to Policy TR8: General site design and layout, Headcorn Parish Council notes that the MBC LP is not the only source of relevant policies within the Development Plan on issues such as design, landscaping, etc. For example, in Headcorn, Neighbourhood Plan policies should also apply. The NPPF makes clear that Neighbourhood Plans are designed to allow local communities to have a say on what and where development takes place. Therefore, to avoid undermining the role of Neighbourhood Plans within the Borough and to ensure the dDPD is justified, Headcorn Parish Council considers that in the parts of policy TR8 that explicitly refer to MBC LP policies (eg LPRSP15) should be amended with a reference to: “and other relevant Development Plan policies”. Headcorn Parish Council considers that any major development (of 10 or more pitches) should be supported by appropriate amenity space, which depending on a site’s intended occupants could be for adults, not just children. It notes that the current policy wording on site layout (TR8 Part 1.b) would make it easy for developers to avoid the provision of amenity space and considers that the drafting should be strengthened to: “Larger sites of 10 or more pitches should include appropriate amenity space, such as children’s play space.” Headcorn Parish Council would prefer to see Policy TR8 Part 1.g strengthened to explicitly include the avoidance of high fences and other boundary treatments that would restrict views across the countryside. Headcorn Parish Council considers that it is important that any plan to deal with wastewater infrastructure and surface water flooding should be acceptable, not just provided, and considers Policy TR8 Part 1.m should be strengthened to reflect this. Headcorn Parish Council considers that vehicle access arrangement to sites should be from a single access point, to avoid the suburbanisation/urbanisation of the countryside and other environmental and landscape harms and therefore would like to see Policy TR8 Part 1.o and the supporting text (paragraph 142) strengthened to reflect this. The supporting text for Policy TR8 mentions national policy and policies in the MBC LP and in other Boroughs (such as Leeds), but does not mention Neighbourhood Plan policies. Without the need to list all the relevant policies, Headcorn Parish Council considers that the supporting text should make clear that any relevant Neighbourhood Plan policies should also be followed. For the reasons set out in its response to Question 11 below, Headcorn Parish Council does not support the use of semi-detached dayrooms of the type envisaged. It therefore does not support the proposed site layout shown in the third example associated with paragraph 138. Headcorn Parish Council notes that the subdivision of sites into ever smaller pitch sizes is directly correlated with the likelihood of problems on the site. It would therefore like to see a policy requirement that sets out minimum acceptable pitch sizes. Headcorn Parish Council would like to see paragraph 152 on hardstanding strengthened to make explicit mention of the need to avoid creating or exacerbating flooding, including surface water flooding.
