Gypsy, Traveller and Travelling Showpeople Development Plan Document

Strongly disagree

Strategic Policy TR1 – Spatial Strategy Submitted to: Maidstone Borough Council 1. Unsound Spatial Strategy – Driven by Land Availability, Not Proper Planning I strongly object to Policy TR1 because it explicitly acknowledges that the spatial strategy is not being guided by sustainability, settlement hierarchy, or balanced growth, but instead by: • The historic location of existing sites • The limited availability of land put forward by site promoters Paragraphs 66–67 confirm that the Council accepts a reactive and land-led approach, rather than a plan-led strategy. This directly conflicts with the fundamental purpose of plan-making under the National Planning Policy Framework (NPPF), which requires plans to be: • Positively prepared • Justified • Effective • Consistent with national policy A strategy that is “dictated” by where land happens to be available is neither justified nor sound. 2. Disproportionate and Inequitable Burden on Rural Communities The Plan places a clearly disproportionate share of development in the countryside, while: • Making virtually no provision in the Maidstone Urban Area • Acknowledging that no urban sites were submitted, yet making no meaningful attempt to identify or enable them This results in: • Rural villages and hamlets absorbing the majority of impacts • Urban areas being effectively shielded from responsibility • An inequitable distribution of development contrary to the stated settlement hierarchy Rural communities should not be expected to accommodate borough-wide needs simply because they are perceived as easier locations to deliver development. 3. Conflict with Countryside Protection Policies The Plan repeatedly recognises that Maidstone borough is predominantly rural and environmentally sensitive, yet simultaneously proposes that: • Most new Gypsy and Traveller accommodation will continue to be delivered in the countryside • Including beyond settlement boundaries and outside the 400m buffer This is fundamentally inconsistent with: • The intrinsic character and beauty of the countryside • The protection of agricultural land • The safeguarding of landscape, heritage, and ecological assets The policy sets up a structural conflict where countryside protection is acknowledged in principle but overridden in practice. 4. Failure to Properly Apply the Settlement Hierarchy Although the Plan states that provision should align with the settlement hierarchy, it then: • Concedes that this is largely unachievable • Accepts continued deviation as the norm rather than the exception This undermines the credibility of the hierarchy entirely. A hierarchy that is routinely overridden is not functioning as a genuine spatial planning tool. 5. Greenfield Development by Default, Not Exception Despite strong policy wording, the Plan creates conditions under which: • Greenfield countryside sites will continue to come forward • “Very special circumstances” risk becoming routine rather than exceptional • Cumulative harm is not properly addressed The requirement for applicants to demonstrate unmet need elsewhere places the burden on local communities to absorb impacts arising from systemic failures in land identification and delivery. 6. Inadequate Consideration of Cumulative Impacts The Plan assesses sites and locations largely in isolation, without sufficient consideration of: • Cumulative visual harm • Incremental erosion of rural character • Infrastructure strain on small settlements • Long-term social and environmental consequences This is particularly concerning where expansion of existing sites is actively encouraged, potentially leading to significant intensification over time. 7. Over-Reliance on Future Supplementary Planning Documents Key elements of delivery—particularly within Garden Settlements—are deferred to future SPDs that: • Do not yet exist • Contain no guaranteed outcomes • Push meaningful solutions beyond year 6 of the Plan This leaves rural communities exposed in the short to medium term while urban and strategic locations remain theoretical. 8. Lack of Genuine Alternatives or Balanced Options The Plan fails to demonstrate that: • All reasonable alternatives have been robustly explored • Urban, brownfield, or regeneration opportunities have been actively enabled • Strategic-scale solutions have been prioritised over piecemeal rural delivery As such, the Plan cannot be considered “justified” as required by soundness tests.