Gypsy, Traveller and Travelling Showpeople Development Plan Document

Disagree

We write to formally object to the inclusion of Site C4S (008), accessed via Water Lane, Bearsted, within the Council’s Call for Sites consultation for Gypsy, Traveller and Travelling Showpeople accommodation. Our objection is based on material planning considerations, with explicit reference to the National Planning Policy Framework (NPPF), and reflects long-standing and well-documented issues affecting this location. ⸻ 1. Severe and Well-Documented Flood Risk (NPPF paragraphs 159–165) Water Lane, Bearsted has a long-standing and well-documented history of surface water flooding, particularly during periods of heavy or intense rainfall. The lane lies at a topographical low point, where surface water naturally runs down from surrounding higher ground, overwhelming the existing drainage network and forming extensive ponding. Paragraph 159 of the NPPF requires development to be directed away from areas at highest risk of flooding through application of the Sequential Test. Given the established flood history of Water Lane, Site C4S (008) is clearly unsuitable for allocation. ⸻ 2. Flood Interaction with the Lilk Stream and Surrounding Area (NPPF paragraphs 159, 161, 167) Floodwater regularly accumulates at the lower end of Water Lane and has been observed to flow across The Street and into the nearby Lilk Stream, increasing flood risk both locally and downstream. The area locally known as “The Bogs” has long been recognised as flood-prone. Paragraph 161 requires that all sources of flooding, including surface water and interactions with watercourses, are fully assessed. The consultation fails to demonstrate that this has been adequately addressed. ⸻ 3. Inadequate Drainage and Sewer Infrastructure (NPPF paragraphs 167 and 174) The local drainage and sewerage network, including infrastructure operated by Southern Water, is already under strain during heavy rainfall events. Past flooding has resulted in drainage exceedance, sewer surcharge and blockages, demonstrating that the existing system lacks capacity to support additional development. Paragraph 167 states that development should not increase flood risk elsewhere, a requirement that cannot be met at this location. ⸻ 4. Recorded Flood Events and Climate Change Risk (NPPF paragraphs 152, 153, 159) Significant flooding incidents occurred in 2019, with further extreme rainfall events across Kent in 2021 highlighting the vulnerability of local infrastructure. In line with paragraphs 152 and 153 of the NPPF, planning decisions must mitigate and adapt to climate change. Allocating Site C4S (008) would be contrary to this requirement. ⸻ 5. Unsuitable Highway Access and Road Safety (NPPF paragraphs 110–113) Access to Site C4S (008) is via Water Lane, a narrow rural road with steep banks, no pavements, limited visibility, poor lighting and no safe passing places. Flooding frequently renders the lane partially or completely impassable. Paragraph 110 requires developments to provide safe and suitable access for all users. Increased traffic, including larger vehicles, would create unacceptable risks to pedestrians, cyclists, residents and emergency services. ⸻ 6. Impact on Local Infrastructure and Services (NPPF paragraphs 8 and 92) Local infrastructure, including roads, drainage systems, schools and healthcare services, is already under pressure. The proposal provides no evidence that additional demand arising from Site C4S (008) could be accommodated without harming existing residents. This conflicts with the social sustainability objectives of paragraph 8 of the NPPF. ⸻ 7. Harm to Rural Character and Landscape (NPPF paragraphs 174 and 180) The site is located within a sensitive rural setting, and development would be out of keeping with the established character and appearance of the countryside. The proposal would harm the openness and rural character of the area, contrary to national policy. ⸻ 8. Environmental and Ecological Concerns (NPPF paragraphs 174 and 180) There is potential for harm to wildlife, mature trees and established habitats, including possible impacts on protected trees. These environmental effects have not been properly assessed, and no evidence of biodiversity net gain has been provided. ⸻ 9. Scale of Development and Lack of Detail (NPPF paragraph 35) The consultation does not specify the number of pitches, layout, access arrangements, hardstanding or mitigation measures proposed. Paragraph 35 requires plans to be clearly justified and effective; this lack of detail prevents meaningful assessment by residents and decision-makers. ⸻ 10. Cumulative Impact (NPPF paragraphs 8 and 159) Maidstone Borough already accommodates a high number of Gypsy and Traveller sites. The cumulative impact of further allocations, particularly in flood-sensitive and infrastructure-constrained locations such as Water Lane, has not been adequately assessed. ⸻ Conclusion For the reasons set out above, Site C4S (008) – Water Lane, Bearsted is fundamentally unsuitable for allocation within the Gypsy, Traveller and Travelling Showpeople Development Plan. The proposal conflicts with multiple provisions of the National Planning Policy Framework, particularly in relation to flood risk, highway safety, infrastructure capacity, environmental protection and climate resilience. We respectfully request that the Council removes Site C4S (008) from further consideration.