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Maidstone Local Plan Review Examination: Stage 2 – comments on MIQs

Submitted on behalf of Teston Parish Council

Matter 12 Monitoring and Review

Issue 2: Other Issues

Question Submission

Q12.3 Are there any parts of the Plan that have not been

addressed by the questions set out above that are

unsound?

We believe the following require consideration and inclusion via Main Modifications.

Settlement Hierarchy

There need to be Modifications so that all policies are reviewed properly to recognise and include

Smaller Villages & Hamlets as a new hierarchy element. They would appear not to be Main

Modifications, so the requirement should be that MBC reviews and, as necessary, revises all

references to Countryside and Smaller Villages & Hamlets, including in detailed policies, to ensure

that the distinction is rigorously applied.

The new LPR hierarchy element, Smaller Villages & Hamlets, is, presumably, to distinguish them from

the Countryside element in that hierarchy.

That demands recognition of the different parts of a Parish – its Built-up Area and the countryside

remainder, with Policy LPRSP8 applying to the former and Policy LPRSP9 to the latter.

That distinction has not been rigorously defined and applied throughout Reg19. There is considerable

use of the general expression “settlement”, use of “envelope” and occasional omission of Smaller

Villages & Hamlets when separating the other elements of hierarchy from the Countryside. Examples

are, although this list may not be exhaustive:

1. Paragraph 5.34 includes: “It is important that the quality and character of the countryside outside

of settlements .....”;

2. Paragraph 6.123 includes: “Development on remote sites, or sites which do not appropriately

reflect the existing envelope of smaller villages, is unlikely to be acceptable due to impact on the

setting of the settlement within its countryside setting”;

3. Paragraph 6.126 includes: “The countryside is defined as all those parts of the plan area outside

the settlement boundaries of the Maidstone urban area, garden community developments, rural

service centres and larger villages with defined settlement boundaries”;

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4. Paragraph 6.129 includes: “The attractiveness of the countryside is partly due to its scattered

settlement pattern and buildings. The overall settlement pattern across the borough is

characterised by a large number of small villagesscattered across the countryside surrounding a

handful of larger, more substantial settlements”;

5. Policy LPRSP9 is entitled: “The countryside is defined as all those parts of the plan area outside

the settlement boundaries of the Maidstone urban area, rural service centres and larger villages

defined on the policies map”;

6. Policy LPRHou 1 Development on brownfield land opens with: “Proposals for development on

previously developed land (brownfield land) on land outside of smaller villages and the

countryside that make effective and efficient useof land and which meet the following criteria will

be permitted....” And then continues “In exceptional circumstances, the residential

redevelopment of previously developed land in the countryside and smaller villages ....”;

7. Policy LPRHou 2: Residential extensions, conversions, annexes, and redevelopment within the

built-up area opens with: “On land outside of the countryside and undefined settlements

proposals ....” and those words are used again within that policy definition;

8. Policy LPRHou 11: Rebuilding, extending and subdivision of dwellings in thecountryside opens

with: “Outside of the Maidstone urban area, larger villages and rural service centres as defined

onthe policies map, proposals for the replacement of a dwelling in the countryside ....”;

9. Policy LPREnv 3: Caravan storage in the countryside opens with: “Proposals for the open storage

of private caravans outside of the settlement boundaries asdefined on the policies map ....”;

10. Policy LPRQ&D 4: Design principles in the countryside opens with: “Outside of the settlement

boundaries as defined on the policies map, proposals which would create high quality design

....”;

Modifications. are therefore required to tighten Reg19 drafting, as indicated above:

Settlement Definition

The Settlement Hierarchy Review was completed by Figura Planning Ltd in July 2021 and provides

a basis for segmentation of settlements into the various levels of the Local Plan Review settlement

hierarchy.

The ONS Web Site shows Built-up Areas. These generally do not accord with Parish boundaries and,

in some cases, are considerably less than the Parish boundary.

Conservation Areas are shown in the “Policies Map Pre-Submission Plan (Regulation 19)”, but not all

Settlement Boundaries are shown. (We are aware that in at least one instance it appears that the

settlement boundaries shown in those maps stray across Parish boundaries, while the housing

allocation might be interpreted as relating to the Parish).

The new hierarchy element, Smaller Villages & Hamlets, is, presumably, to distinguish them from the

Countryside element in that hierarchy.

That demands recognition of the different parts of Parishes - Built-up Areas and the countryside

remainder, with Policy LPRSP8 applying to the former and Policy LPRSP9 to the latter.

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Modifications. are therefore required to establish that:

1. where the Policies Map Pre-Submission Plan (Regulation 19) does not depict a settlement

boundary for a Small Village or Hamlet, the Built-up Area boundary from the ONS Web Site (or

a declared and readily-available alternative) shall be used as the settlement boundary;

2. where the area within a settlement boundary spreads across more than one Parish, any

housing allocation related to that settlement boundary shall be apportioned between the

Parishes in proportion to the current houses within each segment of such settlement boundary

in the respective Parishes; and

3. the remainder of a Parish that is not within one or more so-defined settlement boundaries shall

be part of the Countryside element in the hierarchy.

Employment & Housing Locations & raffic Generation

Villages are adversely affected by developments and activities that generate addition traffic on

narrow roads, particularly HGV traffic.

Some activities are regulated by KCC, such as waste transfer, and the Traffic Commissioner has a

role in approving use of lorries. Neither appear to place weight on the impact on local road networks

and a new Policy in this LPR might assist the Council and Parishes successfully to object to such

proposals.

Modifications. are therefore proposed.

1. A new Policy shall be defined that, in the absence of an alternative definition from KCC,

declares that a “severe” traffic impact would occur when traffic modelling of the current

and already committed developments and activities, indicates that traffic flow rates and / or

junction waiting time would be worsened by more than 5% by the development proposal

and that full mitigation could not be achieved.

2. A new Policy shall be defined that any proposal that depends upon HGV access (after

construction) via a distance of more than 100 metres on other than A roads shall not be

permitted.

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