Gypsy, Traveller and Travelling Showpeople Development Plan Document

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Thank you for consulting Kent County Council (hereafter referred to as the County Council) on the Maidstone Gypsy, Traveller and Showpeople Development Plan Document (DPD), in accordance with the requirements of the Localism Act 2011. The County Council has reviewed the DPD and for ease of reference, has provided comments structured under the chapters and sections used within the document. General Commentary: Minerals and Waste From this DPD, it is not evident that Maidstone Borough Council (MBC) has considered Minerals and Waste matters and therefore the County Council wishes to remind MBC that it considers it important that the document has regard for all the potential constraints that would need to be considered in the identification of suitable sites. This should include the presence of safeguarded land-won mineral deposits as shown on the Mineral Safeguarding Areas proposals map for the Maidstone Borough Council (MBC) area. The presence of economically important mineral deposits may be a significant constraint in site identification as the presumption is to conserve their potential importance. Policy CSM 5: Land-won Mineral Safeguarding of the adopted Kent Minerals and Waste Local Plan (KMWLP) sets out the presumption to safeguard. Any potential sites identified in the Gypsy, Traveller and Showpeople DPD would have to be assessed against that presumption to justify an exemption from safeguarding. Policy DM 7: Safeguarding Mineral Resources of the adopted KMWLP 2024-39 sets out the potential exemption criteria that could be invoked. Moreover, potential sites either coincident or within 250m of safeguarded waste management, or mineral processing, or transportation facility would also have to be considered against the safeguarding presumption (as set out by Policy CSW 16: Safeguarding of Existing Waste Management Facilities). The presumption is that such safeguarded sites would not have their continued lawful operation compromised by incompatible development situated close to them, if not when coincident where other safeguarding tests would be relevant. Policy DM 8: Safeguarding Minerals Management, Transportation, Production & Waste Management Facilities of the adopted KMWLP 2024-39 sets out both the potential exemption criteria that could be invoked and the tests for acceptable impacts when within 250m of safeguarded facilities. Please see below for further specific comments on the sections within the Supplementary Planning Document Consultation: Policy TR1 - Spatial Strategy: Highways and Transportation The County Council is supportive of the proposed strategy, which focuses the provision of new plots and pitches on allocated sites, existing or planned built-up areas and existing authorised sites. This approach will help to ensure that the new accommodation is provided in locations where suitable access arrangements can be made available and there are opportunities for journeys to be undertaken by walking, cycling and public transport.

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Policy TR4 - Accommodation on Allocated Sites: Highways and Transportation It is noted that Policy TR4 identifies potential site allocations that will be the subject of further assessment and refinement prior to the Regulation 19 consultation. Pages 21/22 of the Strategic Land Availability Assessment (SLAA) confirm that this process will include site specific engagement with the County Council, as Local Highway Authority, on matters relating to site access, sustainability and cumulative impacts on the highway network. The County Council welcomes this future opportunity to provide input to inform the site allocations to be included in the Regulation 19 consultation.

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Policy TR7 - Accommodation on Non-Allocated Sites: Highways and Transportation The inclusion of criteria relating to site accessibility and the availability of sustainable transport links to local facilities is supported.

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Policy TR8 – General Site Design and Layout: Flood and Water Management The County Council notes that under the Natural and Built Environment Section, item m requires any sites which come forward to consider the use of SuDS where possible. This is welcomed and the County Council suggests that MBC should also reference the requirements in DEFRA’s SuDS technical standards which set out how SuDS should be designed Highways and Transportation The inclusion of criteria relating to achieving suitable access, supplementing those already captured in adopted Local Plan Policy LPRSP15, is supported.