Gypsy, Traveller and Travelling Showpeople Development Plan Document

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Kent Wildlife Trust (KWT) welcomes the opportunity to comment on the Maidstone Gypsy, Traveller and Travelling Showpeople Development Plan Regulation 18c consultation (2026). We have reviewed the documents online and provided comments below. To allow us to submit a targeted response to your consultation, please accept our comments in letter format. Our key concerns at this stage centre on two of the proposed site allocations namely Policy LPR (256) – Stede Row Woodland, South of Pilgrims Way and Policy C4S (030) – Riverwood. Policy LPR (256) – Stede Row Woodland, South of Pilgrims Way With respect to the proposed site allocation at Stede Row Woodland, the site primarily consists of deciduous woodland, a Habitat of Principal Importance (HPI). HPIs for the conservation of biodiversity in England are listed under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006. The NERC Act, as amended by the Environment Act 2021, places a duty on public bodies to conserve and enhance biodiversity. Due regard to habitats contained within the Section 41 list is key in adhering to this ‘biodiversity duty’. The allocation of this site does not follow the mitigation hierarchy and does not give due consideration to the importance of existing onsite habitats. It is our view that the site is not considered a suitable candidate for allocation at this time and should not be included in future iterations of the development plan, particularly given the habitat known to be present and that surveys have not been undertaken to fully establish its importance for nature or whether any potential development can be suitably mitigated. Policy C4S (030) – Riverwood The proposed allocation at Riverwood sits adjacent to River Len Alder Carr to Fairbourne Mill Local Wildlife Site (LWS) and an area of deciduous woodland. The citation for the LWS states that it supports a complex of habitats including wet woodland and areas of both unimproved and semi-improved grassland which occur alongside the River Len. The LWS site provides refuge for a range of protected, priority and red listed species including kingfisher, turtle dove, reed bunting, and spotted flycatcher as well as water vole and adder. The River Len itself is narrow, shaded and shallow, and flows over base-rich alluvium providing a key habitat for an array of species. Aerial photos of the site indicate that it is already occupied but that the landscaping as required by the draft allocation policy has not been carried out. Notwithstanding this we wish to raise concerns about the proposed allocation and potential impacts of residential occupation on the adjoining LWS. As a minimum we would request that any site allocation policy for this location contains additional requirements to ensure appropriate mitigation measures are put in place to protect the adjoining LWS. These measures should include the provision of a suitably sized and appropriately vegetated buffer zone from the edge of the LWS alongside requirements for the submission and approval of details addressing light, noise and surface water pollution. We hope that the comments made within this letter prove useful in the formation of the Maidstone Gypsy, Traveller and Travelling Showpeople Development Plan. We would be more than happy to hold further discussion with you on any of these issues raised.