Comment ID

Question 1 - Please state which proposed Main Modification you are making a representation on (e.g. MM1)

Question 2 - Do you consider the Local Plan Review Main Modifications to be legally compliant?

Question 3 - Do you consider the Local Plan Review Main Modifications to be sound?

Question 4 - If you answered ‘NO’ to sound (question 3) please tick below why you consider that the Local Plan Review Main Modifications are not sound?

Question 5 - If you have answered No in Questions 2 - 3 please set out your reason and what precise change to the proposed Main Modification will make it sound / legally complaint.

Question 6 - Do you wish to be kept informed about the Inspector's Report and/or Adoption of the Local Plan Review?

MM30 - Henhurst Farm MM30 reads as if the development of Henhurst Farm is now restricted to 60 units. This would read as an error in the way that the track changes have been approached with "approximately" having been deleted in the preceeding text. For soundness "approximately" should be added back in. With the emphasis in the NPPF to significantly boosting the supply of housing, it is important that the site allocations process does not prejudice the more detailed work that can be undertaken at the development management process which could justify proportionate increases above a Local Plan allocation.

Noted. The reinsertion of the word 'approximately' is a minor editorial change which we suggest should be dealt with under MI1 and MI2 of the Schedule of Proposed Minor Changes, as follows: In addition to minor development and redevelopment of appropriate sites in accordance with policy LPRSP 5 6 , approximately 710 new dwellings will be delivered on the remainder of allocated sites H1(48) and H1(49), plus to   approximately 60 on H1(50), and 127 on LPRSA066 and LPRSA114.

A consistent theme that binds all of our comments on the MMs process is one of contingency and the need to ensure a positively prepared approach to the supply of housing rather than one that just seeks to meet the minimum level of need (as being inconsistent with the expectation in the NPPF to significant boots the supply of homes). Having been involved in the Maidstone EiP (and as born out in the suggested MMs) three principal matters were confirmed by the EiP: 2. The infrastructure delivery challenges associated with the 3 strategic sites was well documented causing their proposed trajectories to be set back and significant additional text around phasing/the pre-requisites for development (see MM15, MM16, MM22).

MM39 - Maintaining Delivery Whilst we acknowledge that there is a role for Policy SP10 (see below), in the preparation of a positively prepared plan and one that is plan led the Local Plan should consider the allocation of additional sites that have been assessed through the SHLAA as Green but left unallocated (i.e. Henhurst Farm, Staplehurst). Such a situation is considered as being particularly applicable in the case of Maidstone given the contingency issues that have been raised above. The updated Housing Trajectory shows that for the 17 years of the Local Plan period for 9 of the years there is assumed to be an annualised deficit and for another 3 years the annual surplus is fewer that 60 units. This highlights the vulnerability in the proposed Housing Trajectory which is operating with limited tolerance. Overall the Housing Trajectory is showing a deficit of 279 units (this is in the absence of the application of any non-implementation rates). The windfall total at 2,711 annualises at 160 p/a and becomes a key part of the Housing Trajectory rather than a residual source. It is important to reflect that in the context of the NPPF the housing target is a minimum and not a glass ceiling. At present the Housing Trajectory is unable to demonstrate delivery at the minimum level of need, let alone seek a more positively prepared approach. Such concerns in the housing trajectory are validated by recent appeal decision in Maidstone which have confirmed the absence of a 5YHLS2• In the first instance we suggest that a positively prepared approach would be for the Council to positively identify additional sites to ensure robustness is built into the Local Plan. The need for this is particularly acute around 2028 - 2031 where there is an existing identified deficit and the strategic sites are expected to start delivering units. From the work that the Council has undertaken in the Sustainability Appraisal we know that such sites exist and have already been assessed such that the allocation of some of these sites should not be seen to represent significant additional delay for the Local Plan adoption process. Notwithstanding the above, there is still a role for Policy SP10 however it requires further modification.   As drafted, SP10 is reactionary in its approach rather than positively prepared. The basis of SP10 is that a shortfall needs to arise before the policy is engaged. Given that we know that the Housing Trajectory does not deliver a sufficient number of homes for the Plan Period additional sites will be needed (beyond that expected from windfall) regardless. As mentioned above, the housing target is a minimum and thus a policy for maintaining delivery should be more positively framed. A positive approach would be for the policy to state that "in order to maintain a supply of deliverable housing sites proposals will be supported that..."   The above position is further heightened by suggested future changes to the NPPF that the 5YHLS "test" could be disengaged in circumstances where the Local Plan was up-to-date. The redrafting of a more positively prepared policy would negate this potential issue. Similarly, the annual monitoring may show a lack of a 5YHLS still even if the policy consequences in terms of the tilted balance are switched off for up to date Plans. Why shouldn't the permissive wording at SP10 para 5(d) be triggered by annual monitoring showing a lack of 5YHLS as opposed to the tilted balance being engaged?   The suggested wording in SP10 leaves the Council to determine whether or not a 5YHLS exists. In reality, it may be that an applicant through the submission of relevant  evidence demonstrates the absence of a 5YHLS. The language in SP10 should be more objective in this regard and simply refer to the absence of a 5YHLS.

A consistent theme that binds all of our comments on the MMs process is one of contingency and the need to ensure a positively prepared approach to the supply of housing rather than one that just seeks to meet the minimum level of need (as being inconsistent with the expectation in the NPPF to significant boots the supply of homes). Having been involved in the Maidstone EiP (and as born out in the suggested MMs) three principal matters were confirmed by the EiP: 2. The infrastructure delivery challenges associated with the 3 strategic sites was well documented causing their proposed trajectories to be set back and significant additional text around phasing/the pre-requisites for development (see MM15, MM16, MM22).

A consistent theme that binds all of our comments on the MMs process is one of contingency and the need to ensure a positively prepared approach to the supply of housing rather than one that just seeks to meet the minimum level of need (as being inconsistent with the expectation in the NPPF to significant boots the supply of homes). Having been involved in the Maidstone EiP (and as born out in the suggested MMs) three principal matters were confirmed by the EiP: 3. Approximately 509 units were taken out of the potential allocations from the Town Centre (MM10).

MM15 - Heathlands One of the principal changes to MM15 has been the requirement for a new railway station at Heathlands to be a pre­ requisite of the development. The suggested phasing states that the new station would need to be delivered within Phase 1 of the development. MM15 comes following the confirmation from the Inspector at Paragraph 5.11 of ED70 that the modification is necessary for soundness to ensue that the policy fully aligns with the Sustainability Appraisal assessment which is the justification for the policy. We note various documents submitted to the EiP looking at a "no station" development scenario. However, there is no suggestion in MM15 (either policy or the supporting text) that Heathlands can be acceptable without a new rail station. The most recent version of the signed Statement of Common Ground (SoCG) with Highways England (ED106) states that "the signatories recognise that this commitment [referring to the train station] has yet to be fully worked through." As such, there remains a high level of uncertainty that a railway station would be forthcoming. There are a numerous examples of where Local Plan policies across England has indicated the potential for a railway station to be accommodated but then not been able to deliver this (see North Horsham). We disagree that the evidential threshold has been as suggested in the Stage I Interim Report ED70. If Heathlands was significantly back ended in the Housing Trajectory, on balance we could see how the evidential threshold had been met. However, the reality is that Heathlands is assumed to be delivering units within the next 7 years and, consequently, the level of evidential scrutiny should be heightened. In respect to dealing with matters associated with the AONB, MM15 also seeks to add in a significant amount of additional text. The signed SoCG with Natural England states that:   "Natural England still has concerns as to whether the proposed development at Heathland Garden Community can be mitigated to avoid adverse impacts on the setting of the Kent Downs AONB. In order to deal with this the site promoters have commissioned further work  in conjunction with the AONB Unit to look at the nature and scale [our emphasis added] of the development possible, the layout of the allocations and the role of structural planting..." This was signed by the Council in April 2023 and, to the best of our knowledge, represents the most up to date position. The Examination Documents webpage includes no update to account for the work that is indicated as being necessary above. Why is this relevant? MM15 as proposed only seeks to grapple with the role that structural planting could play in mitigating the impacts of the development. Crucially, there appears to be no landscape capacity work undertaken to conclude (and justify in the tests of soundness) the extent to which the proposed allocation (5,000 units) could be accommodated within the landscape in order to avoid harm to the AONB. The NPPF is clear that "the scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas." MM15 as drafted only seeks to propose to mitigate (i.e. structural planting) rather than considering whether the harm can be avoided through more fundamental measures such as developing at a reduced quantum. Whilst the AONB consideration is unlikely to go to the heart of the soundness  of the Heathlands policy when read as a whole, it does propose important soundness questions as to the contribution (in respect of housing delivery) that might be assumed from Heathlands. MM5 as drafted is unsound as it is not consistent with the NPPF. As drafted the MM states "Great weight will be given to conserving the Kent Downs and High  Weald  Areas  of  Outstanding  Natural  Beauty and  their  settings. Development will conserve and enhance the landscape and scenic beauty of the Kent Downs and High Weald Areas of Outstanding Natural Beauty and their settings." Paragraph 176 of the NPPF confirms that great weight is reserved for conservation and enhancement in National Parks. The MM as drafted conflates the weight to be given to setting which has a different set of considerations in the NPPF. MM5 should be further revised to confirm that great weight relates to development in the AONB. The approach that is proposed in MM15 to respond to the highways concerns identified through the EiP is a "Vision and Validate" and "Mitigate and Manage" type approach. The consequence of this is that the plan is adopted with a lack of validated assumptions as to the broad extent of the highways works (and importantly costs) that would be associated with delivering the project. The updated Infrastructure Delivery Plan (ED126)  confirms  that, save for the rail station, all other transport related costs in the IDP are left as "TBC". The quality of the resolution on the Strategic Sites Viability Assessment (ED128) is not sufficiently clear to be able to understand what level of contingency has  been assumed in respect of the transport costs associated with the strategic sites. This should be clarified. This point applies equally to the Lidsing Development.

A consistent theme that binds all of our comments on the MMs process is one of contingency and the need to ensure a positively prepared approach to the supply of housing rather than one that just seeks to meet the minimum level of need (as being inconsistent with the expectation in the NPPF to significant boots the supply of homes). Having been involved in the Maidstone EiP (and as born out in the suggested MMs) three principal matters were confirmed by the EiP: 1. The plan needed to be extended by a further two years creating a need for a further 1,923 units during the plan period (see MM7).

MM35 – Policy LPRSA7(D) We support the proposed modifications to Policy LPRSP7(D) which clarify, consistent with Policy LPRSA248 as modified, that Land at Kenward Road, Yalding will accommodate approximately 100 homes, with the new homes themselves to be located on the land north of Kenward Road (Parcel A as shown on the ‘Yalding Larger Village’ map on page 95 of the Plan), and the land south of Kenward Road (Parcel B) used to accommodate supporting infrastructure such as open space and sustainable urban drainage. These modifications reflect what was discussed and agreed at the relevant Local Plan examination hearing session in May 2023, where all parties agreed that whilst the land south of Kenward Road would principally be used for the provision of open space, an element of that land was required for the provision of infrastructure (pedestrian routes, sustainable urban drainage etc…) to support the delivery of new homes north of Kenward Road.

MM89 – Policy LPRSA248 In general terms we support the proposed modifications to Policy LPRSA248, which are based upon the verbal conclusions of the Local Plan Inspector / the agreement reached between ourselves and Council Officers at the Local Plan examination hearing session in May 2023. Most notably, these modifications make it clear that: • Policy LPRSA248 allocates land both to the north and south of Kenward Road; • the new homes themselves are to be provided only on the land north of Kenward Road; and • the land to the south of Kenward Road should be used for the provision of open space and the supporting infrastructure associated with the provision of the new homes in an appropriate way. However, we object to some detailed elements of the policy as modified / left unchanged which go to its soundness and, specifically, run contrary to the Council’s objective to make the policy effective and aid policy implementation. Policy LPRSA248 is a lengthy policy and as such, for ease of reference, our objections are made with reference to the relevant policy sub-heading and the relevant bullet point therein. Design and Layout - Bullet Point One We accept the clarity now provided by the policy in terms of the location of new dwellings within this allocation i.e. they are only to be located on the land north of Kenward Road. However, the policy text, as modified, refers to the development of these new homes taking place “at” an average density of 30 dwellings per hectare. This is overly (and we think unwittingly) prescriptive as it would limit the ability of development to respond to locational specifics / context i.e. requiring development at a very specific density. Furthermore, this approach: • conflicts with the opening paragraph of Policy LPRSA248 as modified which, rightly, refers to development taking place at a density of “approximately” 30 dwellings per hectare; and • conflicts with the provisions of Policy LPRHou 5 (Density of Residential Development), noting that whilst criterion 5 of that policy (which relates to residential developments within or adjacent to rural service centres and larger / smaller villages) requires a net density of 30 dwellings per hectare, the last sentence of the policy text that precedes the identified criteria i.e. text that applies to all of the policy criteria, is clear that the densities referenced are “minimum densities”. Against this background, bullet one should be amended to refer to development taking place at a density of “approximately” 30 dwellings per hectare. Flood Risk / Drainage The Council’s Main Modifications does not propose to make any changes to the policy text under this heading. However, as set out in our previous representations it clearly should do, noting specifically that: Bullet one makes reference to not worsening local flood risks on Mote Road. However, there is no Mote Road close to this site or in Yalding generally. Furthermore, there are no specific ‘local flood risks’ relating to Kenward Road in Yalding. It is, therefore, evident that this bullet point is a drafting error carried over from another policy / site and included in error; and • Bullet 2 refers to vehicular access to the site being through Flood Zone 3 and, as a consequence, the need to agree acceptable flood safety measures with the Environment Agency. However, access to Land at Kenward Road is in Flood Zone 1 i.e. land at lowest risk of flooding. It is again evident that this bullet point is included in error and relates to another site / policy. We assume that the retention of these bullet points in the Main Modifications document is an oversight by the Council as it is clear that they should have been deleted. We assume that as factual text changes / deletions, that the deletion of these bullet points could if necessary be advanced as Additional Modifications i.e. changes that can be made by the Council. Open Space – Bullet 4 We generally welcome the modifications proposed to this element of the policy which, whilst clarifying that the land south of Kenward Road should be used generally for open space provision, make the policy less prescriptive in terms of exactly how this open space should be configured. That approach is wholly appropriate. However, there are two practical soundness related issues raised by the policy as modified: • as worded, Bullet 4 makes no reference to the use of some of the land south of Kenward Road for the provision of infrastructure to support the new homes north of Kenward Road (sustainable urban drainage, pedestrian links etc….) This is exactly what the earlier part of this policy as modified, and Policy LPRSA7(D), seek specifically to allow. To ensure internal consistency within this policy, and wider consistency with the Plan as a whole, it is important that this text is amended; • the policy as modified proposes that the quantum / disposition of open space uses on the land south of Kenward Road is to be determined through the submission of an ‘Open Space Strategy’ in collaboration with the Council and the Parish Council. We take no issue, as a matter of principle, with this approach. However, the way that this requirement is expressed undermines its effectiveness for the following reasons: − as the Council is aware, the landowner (Hallam Land Management) intends to secure outline planning permission before selling the site to a developer / housebuilder to advance detailed proposals (to be approved via reserved matters) and then implement the approved scheme. The outline permission would of course establish the principle / overall quantum of residential development north of Kenward Road, and open space provision south of Kenward Road. However, the detailed decision as to the different open space typologies (and the relative quantum of each type of open space) on the land south of Kenward Road is best discussed and agreed at the reserved matters stage i.e. when matters of detail are considered. As such, it is important that the policy as modified, is clear that the ‘Open Space Strategy’ required by the Council is produced as part of any reserved matters / detailed planning applications and not as part of any outline application; and − − it is equally important to ensure that the policy is clear as to which body will ultimately approve any ‘Open Space Strategy’. That body is clearly the Council as local planning authority. The effectiveness of the policy as modified would be enhanced by providing clarity that the ‘Open Space Strategy’ is to be submitted by the applicant (having sought to collaborate with the Parish Council) and approved by the Council. Changes Sought Having regard to the above, we consider that the changes below are necessary to ensure that Policy LPRSA248 properly addresses the matters discussed / agreed at the Local Plan examination hearing session in May 2023, and that it achieves the Council’s objective of being effective and aiding policy implementation (the changes sought are shown in bold below for ease of reference): Design and Layout Bullet 1 should be amended, to ensure internal consistency within Policy LPRSA248 itself and wider consistency with the Plan as a whole (most notably Policy LPRHou 5), to state that: “The development shall provide approximately 100 dwellings, only to be provided on land north of Kenward Road, at an average density of approximately 30 dph” Flood Risk / Drainage These two bullet points should be deleted as they do not relate to the land allocated by Policy LPRSA248 or Yalding more generally. Open Space Bullet point 4 should be amended as follows: “The land south of Kenward Road shall provide, in addition to any supporting infrastructure associated with the delivery of the proposed homes north of Kenward Road, approximately 4.9 ha of public open space / habitat in the form of (to be determined by an Open Space Strategy produced with input from the Parish Council, submitted as part of any detailed planning application / reserved matters submission and approved by the Council): • Community allotments / growing areas • New Riverside landscape / habitat creation • Informal open space • Sustainable urban drainage • Ancillary parking to support the open space” MM89 – Policy LPRSA248 This representation supplements our previously submitted representations to this policy and should be read in conjunction with it. In general terms we support the proposed modifications to Policy LPRSA248, which are based upon the verbal conclusions of the Local Plan Inspector / the agreement reached between ourselves and Council Officers at the Local Plan examination hearing session in May 2023. However, as set out in our separately submitted representations, we object to some detailed elements of the policy as modified which go to its soundness and, specifically, run contrary to the Council’s objective to make the policy effective and aid policy implementation. This representation focusses on a specific change proposed by the Council (albeit not something required by the Inspector or discussed at the examination hearing session) under that part of Policy LPRSA248 that addresses ‘Open Space’. Open Space As referenced in our separate representations, we support the Council’s proposal to be less specific in terms of exactly how the open space to be provided on the land south of Kenward Road is constituted, with this matter of detail to be addressed at a later stage. However, the modification now includes reference to the land south of Kenward Road providing “approximately 4.9 ha” of public open space / habitat. As a matter of fact, the land south of Kenward Road (Parcel B as shown on the plan associated with Policy LPRSP7(D) (MM35), comprises only 4.3 hectares of land. The Council can verify this by measuring the land parcel and / or with reference to an earlier version of this policy of the Local Plan as drafted by the Council (extract included below for ease of reference): As can be seen from this extract, the total level of open space on the land south of Kenward Road adds up to 4.3 hectares. The reference to 4.9 hectares in MM89 is, therefore, an error and should be corrected for factual accuracy and to avoid unnecessary confusion at the development management stage. Changes Sought Having regard to the above, and in addition to the comments we have made separately, to ensure that this element of Policy LPRSA248 as modified is effective, it should be amended to refer to 4.3 hectares.

Noted. There are minor editorial changes which we suggest should be dealt with under MI1 and MI2 of the Schedule of Proposed Minor Changes, as follows: Design and layout: The development shall provide approximately 100 dwellings, only to be provided on land north of Kenward Road, at an average density of approximately 30dph. Flood risk/drainage: Delete bullet points 1 and 2 Open Space:  The land south of Kenward Road shall provide , in addition to any supporting infrastructure associated with the delivery of the proposed homes north of Kenward Road , approximately 4.9 ha of public open space /habitat, in the form of approximately ( which is to be determined through the submission to the LPA of an Open Space Strategy that has been prepared in collaboration with both the Council and the Parish Council): o 0.4ha of community allotments/growing areas o ha of new Riverside landscape/habitat creation o ha of informal open space o 0.5ha of recreational open space o Sustainable Urban Drainage o Ancillary parking to support the open space

We object to the overall Main Modifications due to the repeated reliance on a ‘Monitor & Manage Strategy’, on the basis that this is not a sound management plan. ‘Monitor & Manage’ is a reactive strategy and has no element of forward planning, or control – this is a fire-fighting policy. In addition, there is no baseline measurement for any sections that reference ‘Monitor & Manage’. As a result every activity is out of control, and cannot be managed.without further intervention or plan. Furthermore, no critieria have been set that would trigger the ‘Manage’ element of this so-called strategy. With specific reference to MM16 LPRSP4(B): Lidsing Garden Community, Traffic : As resdients of XX, we witness rat-running through this medieval village on a daily basis. The road through Boxley is neither an A or B road and is unclassified. At its narrowest it is less than 4m wide which is significantly less than the national standard for two-way traffic. Pedestrian safety: due to the narrowness of the road, motorists use the footpath as additional road width thereby endangering pedstrian safety – again, this is a daily feature of traffic passing through the village. The suggestion that cycle lanes/pedestrian footpaths be added indicates that the authors of the main modifications have never made a site-visit. There simply isn’t enough space for these additions and how does this mitigate increased traffic flow and resolve the existing rat-running? Traffic calming measures already exist through Boxley: it’s a 20mph zone with speed bumps which clearly do not work on this daily rat-run. As evidenced by the May 2023 survey conducted by Kent Highways: 57,000 vehicles were recorded in a week (2,970,812 a year); 61% were in excess of the sign-posted speed limit. In conclusion, we object to the overall Main Modifications due to the reliance on an unsound ‘Monitor & Manage Strategy’. In addition, we object specifically to MM16 LPRSP4(B): Lidsing Garden Community as it will further exacerbate the rat-running which occurs through Boxley on a daily basis.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

I am objecting to MM16 LPRSP4(B): Lidsing Garden Community for the following reasons: 1 - No infrastructure or road improvements WHATSOEVER are planned until 5 years (and 590 houses) after the building works start. Even then will his even happen? The infrastructure needs put in place first and that includes upgrading hospitals, doctors and schools never mind the water and waste.  Southern Water & SE Water  have trouble as it is keeping up with the current demand. 2 - 'Traffic calming' is proposed to discourage the increased level of traffic caused by 2000+ new houses travelling through Bredhurst and Boxley.  Both villages already have extensive traffic calming measures so it's hard to see how any further traffic calming could be implemented. 3 - 'Cycling and pedestrian facilities' are also supposed to be provided to 'encourage sustainable modes of transport via Boxley and Bredhurst'. It is pretty inconceivable how cycle lanes or pavements could be provided to link the two villages however the existing roads aren't wide enough for pavements or cycle lanes to be added. There is no note of widening of local roads specified. 4 - Traffic is at a standstill most of the week at peak times and Pear Tree Lane,  Ash Tree Lane and surrounding area cannot cope with the existing traffic . To make the plan sound the Lidsing Garden Village should be removed from the plan. Concerned

The plan states: "With the exception of a possible site access road and associated infrastructure, there shall be no built development on that part of the site that comprises the Walnut Tree Meadows Nature Reserve." This still allows for a road to be built across the Nature Reserve, where good planning would require the access road to be through the - as yet unbuilt - adjacent development site. The plan states: "Vehicular access shall be direct from Dean Street and/or via adjacent residential development sites onto Dean Street. The precise route and construction method of the access route will minimise land-take within the Nature Reserve. Any route must avoid harmful division of the reserve that would undermine its function/coherence." The route that minimises land-take within the nature reserve is a route via the adjacent housing development. The modification should be clear there is to be no road across the nature reserve. The plan states: "A community woodland of no less than (5) ha shall be provided." What is the purpose of having the figure five in brackets? Does that suggest it doesn't have to be five hectares? This is confusing. Also the site of the woodland should be specified so that local people know what to expect.

Whilst we note this comment, we do not consider that any revisions to the Main Modification are necessary to make the plan sound and/or legally compliant.  Comment regarding the use of the brackets around '5' is noted. This is a minor editorial change which we suggest should be dealt with under MI1 and MI2 of the Schedule of Proposed Minor Changes.

The ICB welcomes the modifications to policy LPRSP4(A) making specific reference to delivery of a new medical facility. We request the policy clarifies this should be provided as a fully fitted medical facility and transferred to the NHS at nil cost. We understand a supplementary planning document will be produced to masterplan and facilitate the site’s delivery and will engage with the council as part of this process to discuss the detail associated with the medical centre.

NHS Kent and Medway Integrated Care Board (“the ICB”) previously confirmed it would need to strategically assess requirements for the wider area to determine the appropriate response and requirements for this development. The IDP recognises “At the time of writing an Interim Kent and Medway Integrated Care System Estates and Infrastructure Strategy is in development and this will be further informed by place based clinical and estates strategies that will start to be developed by Health and Care Partnerships (HCPs) during 2023. These strategies will inform estates plans and further inform the IDP regarding future healthcare infrastructure plans and requirements.” The ICB welcomes the modifications to policy LPRSP4(B) making specific reference to provision of a medical facility on site although request it is recognised this will be subject to the need in this location being established through the HCP strategy. For that reason we request the policy provides flexibility for a fully fitted medical centre to be provided and transferred to the NHS at nil cost or equivalent funding provided to mitigate the need for this development at an alternative site following strategic assessment as part of the HCP strategy. We understand a supplementary planning document will be produced to masterplan and facilitate the site’s delivery and will engage with the council as part of this process to discuss the detail associated with the medical centre.

I am objecting to MM16  LPRSP4( B):  Lidsing  Garden Community for the following reasons :-       Traffic Calming   I object to MM16  LPRSP4( B):  Lidsing  Garden Community because the proposed mitigations for traffic calming  to discourage access / egress via  Boxley  and  Bredhurst  are unsound  as they  are not justified or  effective. There  are  already substantial traffic calming measures such as  20mph speed limits, chevrons, restricted rights of way,  speed bumps,   etc  through both villages.  There is no evidence that any further measures could be implemented  to discourage traffic taking the quickest  available travel  route s through either village. To make the plan sound, the  Lidsing  Garden Village needs to be removed  in its entirety.   Cycle & Pedestrian Facilities   I object to MM16  LPRSP4( B):  Lidsing  Garden Community because the proposed mitigations for the provision of cycle & pedestrian  facilities  to  en courage sustainable  modes of transport via  Boxley  and  Bredhurst are unsound as they are not justified or effective.  The roads which connect  Lidsing ,  Bredhurst  and  Boxley   are narrow rural roads  without pavements or street lighting .  To encourage cycl ist and  pedestrian use of these roads  in their current condition  would be reckless and  endanger life . If these roads are proposed to be widened to  accommodate cycle lanes, pavements and street lighting,  this would involve  multiple  substantial compulsory purchase  orders , destruction of  hedgerows (which are vital wildlife habitats),  removal of ancient woodland and also  residents’ front gardens or even properties.  There is no evidence to support that  this is feasible or the financial implications of this.  To make the plan sound, the  Lidsing Garden Village needs to be removed in its entirety.   S econdary Education Provision   I object to MM16  LPRSP4( B):  Lidsing  Garden Community because  the  secondary  education provision is unsound as it is  not  justified  or effective.  The Main Modifications state that  there will be a  “ contribution towards  the creation of a new secondary  school capacity in the Capstone Valley Area”.  The   Capstone Valley is under Medway  Council who have not agreed or planned for a new secondary school  in the area. Indeed, there isn’t even a signed Statement of Common Ground between the two councils.  Therefore, to make the Local Plan s ound, the   Lidsing  Garden Village should be removed in its entirety.   Removal of 31  Hectares of Open Space   I object to MM16 LPRSP4(B):  Lidsing  Garden Community because the  Main Modifications state that ’31  Ha of natural / semi natural open space’  planned for the  Lidsing  Garden Village has been removed.  Not only is this contrary to Garden Village Principles , it isn’t stated what will be included on the site instead . Surely this also completely negates the claim that  the development of 2000+ houses  and employment will result in a 20 % biodiversity net gain.  Therefore this plan is unsound as it is not justified or effective  and the  Lidsing  Garden Village should be removed accordingly.   Phasing and Delivery   I object to MM16  LPRSP4( B):  Lidsing  Garden Community because the  delivery  of the East – West  link road  from the development to  the North Dane Way  is unsound as it is not justified or effective.  There is no agreement with Medway Council ,  who own the so -called ‘Ransom Strip’ ,   to   complete  the link . Medway Council  have  objected to the Garden Village and there is no signed Statement of Common Ground between MBC and Medway.  Therefore, to make the plan sound, the  Lidsing Garden Village needs to be removed .

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

The following are my objections to the proposed main modifications Traffic Calming I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for traffic calming to discourage access / egress via Boxley and Bredhurstare unsound as they are not justified or effective. There are already substantial traffic calming measures such as 20mph speed limits, chevrons, restricted rights of way,speed bumps, etc through both villages. There is no evidence that any further measures could be implemented to discourage traffic taking the quickest available travel routes through either village. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety. Cycle & Pedestrian Facilities I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for the provision of cycle & pedestrian facilities to encourage sustainable modes of transport via Boxley and Bredhurst are unsound as they are not justified or effective. The roads which connect Lidsing, Bredhurst and Boxley are narrow rural roads without pavements or street lighting. To encourage cyclist and pedestrian use of these roads in their current condition would be reckless and endanger life. If these roads are proposed to be widened to accommodate cycle lanes, pavements and street lighting, this would involve multiple substantial compulsory purchase orders, destruction of hedgerows (which are vital wildlife habitats), removal of ancient woodland and also residents’ front gardens or even properties. There is no evidence to support that this is feasible or the financial implications of this. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety. Secondary Education Provision I object to MM16 LPRSP4(B): Lidsing Garden Community because the secondary education provision is unsound as it is not justified or effective. The Main Modifications state that there will be a “contribution towards the creation of a new secondary school capacity in the Capstone Valley Area”. The Capstone Valley is under Medway Council who have not agreed or planned for a new secondary school in the area. Indeed, there isn’t even a signed Statement of Common Ground between the two councils. Therefore, to make the Local Plan sound, the Lidsing Garden Village should be removed in its entirety. Removal of 31 Hectares of Open Space I object to MM16 LPRSP4(B): Lidsing Garden Community because the Main Modifications state that ’31 Ha of natural / semi natural open space’ planned for the Lidsing Garden Village has been removed. Not only is this contrary to Garden Village Principles, it isn’t stated what will be included on the site instead. Surely this also completely negates the claim that the development of 2000+ houses and employment will result in a 20% biodiversity net gain. Therefore this plan is unsound as it is not justified or effective and the Lidsing Garden Village should be removed accordingly. Phasing and Delivery I object to MM16 LPRSP4(B): Lidsing Garden Community because the delivery of the East – West link road from the development to the North Dane Way is unsound as it is not justified or effective. There is no agreement with Medway Council, who own the so-called ‘Ransom Strip’, to complete the link. Medway Council have objected to the Garden Village and there is no signed Statement of Common Ground between MBC and Medway. Therefore, to make the plan sound, the Lidsing Garden Village needs to be removed

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

I am objecting to MM16 LPRSP4(B): Lidsing Garden Community - main modifications. I am a very concerned local resident and I am objecting to these proposed main modifications as follows ; - Traffic Calming The proposed mitigations for traffic calming to discourage access / egress via Boxley and Bredhurst are unsound as they are not justified or effective. There are already substantial traffic calming measures such as 20mph speed limits, chevrons, restricted rights of way, speed bumps, etc through both villages. I cannot see what further measures could be put in place. The present measures have not discouraged the use of this route, and bigger vehicles just straddle the speed humps as if they don't exist. There is no evidence that any further measures could be implemented to discourage traffic taking the quickest available travel routes through either village. Cycle & Pedestrian Facilities The proposed mitigations for the provision of cycle & pedestrian facilities to encourage sustainable modes of transport via Boxley and Bredhurst are unsound as they are not justified or effective. The roads which connect Lidsing, Bredhurst and Boxley are narrow rural roads without pavements or street lighting. To encourage cyclist and pedestrian use of these roads in their current condition would be reckless and endanger life. If these roads are proposed to be widened to accommodate cycle lanes, pavements and street lighting, this would involve multiple substantial compulsory purchase orders, destruction of hedgerows (which are vital wildlife habitats), removal of ancient woodland and also residents’ front gardens or even properties. There is no evidence to support that this is feasible or the financial implications of this. The hill from Boxley to Bredhurst is very steep and only very fit cyclist take this route. There have been serious accidents involving cyclists heading up the hill and impatient motorists over taking when it was not safe. This area also consists of many livery yards, with horse riders enjoying the lanes as they are. There is absolutely no consideration for these significant road users, who will be put at significant risk of harm due to increased traffic and in patient drivers. The Main Modifications state that ’31 Ha of natural / semi natural open space’ planned for the Lidsing Garden Village has been removed. Not only is this contrary to Garden Village Principles, it dose not state what will be included on the site instead. Surely this also completely negates the claim that the development of 2000+ houses and employment will result in a 20% biodiversity net gain. For these reasons, this plan is unsound, as it is not justified or effective and the Lidsing Garden Village should be removed in its entirety in order to make the plan sound.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

I am objecting to the MBC's Consultation on the Main Modifications to the Draft Local Plan. I object to the Ransom Strip being sold so the transport links up to North Dane Way. This should not happen. There is no new school planned and it will be needed obviously. Many hectares have been removed from the plan. This is not right and our green spaces should remain. There will not be a 20% biodiversity gain if 31 Hectares are removed. The whole plan is unsound, not justified or effective. Lidsing Garden should be removed. I strongly object to the modifications.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

I am objecting to MM16LPRSP4(B) because this is unsound, not justified or effective. 1    It appears that Medway Council objects to the development and presumably not sell the land necessary to allow the site to connect to North Dane Way. The contribution towards a new secondary school is of no value if Medway Council has no intention of building a new secondary school in the area. If 31 hectares of open space has been removed from the development, how can the developers claim a 20% net biodiversity gain for the project.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Natural England supports this addition (after paragraph 7.149). 7(A) Natural England supports this amendment. 9. Natural England supports this amendment. 10. Natural England supports this amendment.

3) Natural England supports the plan under 3)a) and b) to avoid or minimise adverse impacts on the AONB and views in and out of the AONB. 3d) Natural England support the amendment. 3g) More strength needs to be brought to the policy wording for the protection of the setting of the AONB. For example: “ensuring the development respects the sites visual and physical relationship with the Kent Downs AONB".

Natural England supports the requirement for traffic modelling of the proposed development and a mitigation strategy with a project-level HRA if nitrogen deposition is too high. Natural England would expect the project-level HRA to consider potential impacts arising from displacement of traffic as part of the modelling. 3)m) The developments for Heathlands and Lidsing should follow the Kent practice guidance, including the AONB Guidance on the selection and use of colour in development, within the Kent Downs AONB guidance documents. n) Natural England welcome the commitment to controlling building heights in the sensitive AONB area.

Natural England has no comments to make in relation to whether the increase in new dwellings is justified or where the housing development and supporting infrastructure should be located. Natural England supports this addition (point 4).

objecting to MM16 LPRSP4(B): Lidsing Garden Community   Traffic Calming I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for traffic calming to discourage access / egress via Boxley and Bredhurst are unsound as they are not justified or effective. There are already substantial traffic calming measures such as 20mph speed limits, chevrons, restricted rights of way, speed bumps, etc through both villages. There is no evidence that any further measures could be implemented to discourage traffic taking the quickest available travel routes through either village. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety. Cycle & Pedestrian Facilities I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for the provision of cycle & pedestrian facilities to encouragesustainable modes of transport via Boxley and Bredhurstare unsound as they are not justified or effective. The roads which connect Lidsing, Bredhurst and Boxley are narrow rural roads without pavements or street lighting. To encourage cyclist and pedestrian use of these roads in their current condition would be reckless and endanger life. If these roads are proposed to be widened to accommodate cycle lanes, pavements and street lighting, this would involve multiple substantial compulsory purchase orders, destruction of hedgerows (which are vital wildlife habitats), removal of ancient woodland and also residents’ front gardens or even properties. There is no evidence to support that this is feasible or the financial implications of this. To make the plan sound, the LidsingGarden Village needs to be removed in its entirety. Secondary Education Provision I object to MM16 LPRSP4(B): Lidsing Garden Community because the secondary education provision is unsound as it is not justified or effective. The Main Modifications state that there will be a “contribution towards the creation of a new secondary school capacity in the Capstone Valley Area”. The Capstone Valley is under Medway Council who have not agreed or planned for a new secondary school in the area. Indeed, there isn’t even a signed Statement of Common Ground between the two councils. Therefore, to make the Local Plan sound, the Lidsing Garden Village should be removed in its entirety. Removal of 31 Hectares of Open Space I object to MM16 LPRSP4(B): Lidsing Garden Community because the Main Modifications state that ’31 Ha of natural / semi natural open space’ planned for the Lidsing Garden Village has been removed. Not only is this contrary to Garden Village Principles, it isn’t stated what will be included on the site instead. Surely this also completely negates the claim that the development of 2000+ houses and employment will result in a 20% biodiversity net gain. Therefore this planis unsound as it is not justified or effective and the Lidsing Garden Village should be removed accordingly. Phasing and Delivery I object to MM16 LPRSP4(B): Lidsing Garden Community because the delivery of the East – West link road from the development to the North Dane Way is unsound as it is not justified or effective. There is no agreement with Medway Council, who own the so-called ‘Ransom Strip’, to complete the link. Medway Council have objected to the Garden Village and there is no signed Statement of Common Ground between MBC and Medway. Therefore, to make the plan sound, the LidsingGarden Village needs to be removed.     I am concerned about the knock on effect to local hospitals and health services   The amount of increased traffic in the local area.. we are often in gridlock and this certainly won’t improve this situation   The will effect Medway council provision locally   Please please reconsider… I don’t want to live in an urban jungle..

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Dear Sir/Madam, Ashford Borough Council Representation on the Local Plan Review Main Modifications Consultation Thank you for consulting Ashford Borough Council (ABC) on your Local Plan Review Main Modifications. ABC has no comments on the proposed modifications. We would like to highlight that ABC agreed a Statement of Common Ground with Maidstone Borough Council (MBC) in October 2021 and expects that this will continue to form the basis for future engagement between the two authorities. As agreed within the Statement of Common Ground between ABC and MBC, ABC assumes and expects that it will be consulted on and engaged as necessary in these initiatives, to ensure that any potential impacts on Ashford Borough are addressed, particularly (but not exclusively) impacts on strategic and local road and rail infrastructure, on the strategic and local landscape, but also nutrient neutrality (Stodmarsh). As ABC begins work on our Local Plan Review, we look forward to continuing the positive and pragmatic discussions regarding the strategic cross boundary issues affecting the two authorities. If you need any clarification or wish to discuss matters further, please do not hesitate to contact via XXX, or e-mail XXX.

I am objecting to the Lidsing Garden Community because this is definitely unsound not justified or effective. Transport  . The transport network will rely on Medway Council and this can only come about if their Ransom strip is sold allowing the proposed site to connect onto the North Dane Way. Medway have never ever said that this would happen so how comes Maidstone Council think they will and just go ahead with plans to incorporate the said land into their plans . Water facilities are already becoming a problem in Kent so how do Maidstone Council think they will be able to facilitate all these houses and not have a problem in the coming future as other areas have. Our Senior Schools are already full so where are all the children from these houses going to go . Maidstone have stated a new secondary school in the Capstone Area but this area is under Medway Council who again have not agreed or planned for a new school and even if they had surely this would be for children in the Medway Area in their new housing plan. I feel that the planning and infer structure of this site by Maidstone Council thinks it can rely on Medway Council to provide the facilities ie schools doctors hospital and the use of the very congested roads in Hempstead Bredhurst Wigmore . Because of this The Lidsing Garden Village should be removed from the Plan.

The inspector found the Heathlands proposal unsound in his first letter of findings on the Local Plan. The main modifications do not change this position. Heathlands as a so-called Garden Development which has been proven to be undeliverable, unsustainable and unviable by a number respondents under consultation 18, 19, the inspection and Fish Legal's further letter to the inspector. The main modifications proposed by Maidstone Borough Council does not change this evidence that proves Maidstone Borough Councils Local Plan is politically motivated rather than meeting the NPPF guidelines. The proposed modifications do not change the fact that the allocation derives from a flawed spatial strategy. The Maidston Local Plan remains unsound which a number of respondents have proved. The Council and the inspector can not continue to ignore the evidence, Maidston Council should be sent back to the drawing board and be forced to evaluate the Leeds Langley bipass as they where requested to in 2017.

The inspector found the Heathlands proposal unsound in his first letter of findings on the Local Plan. The main modifications do not change this position. Heathlands as a so-called Garden Development which has been proven to be undeliverable, unsustainable and unviable by a number respondents under consultation 18, 19, the inspection and Fish Legal's further letter to the inspector. The main modifications proposed by Maidstone Borough Council does not change this evidence that proves Maidstone Borough Councils Local Plan is politically motivated rather than meeting the NPPF guidelines. The proposed modifications do not change the fact that the allocation derives from a flawed spatial strategy. The Maidston Local Plan remains unsound which a number of respondents have proved. The Council and the inspector can not continue to ignore the evidence, Maidston Council should be sent back to the drawing board and be forced to evaluate the Leeds Langley bipass as they where requested to in 2017.

The inspector found the Heathlands proposal unsound in his first letter of findings on the Local Plan. The main modifications do not change this position. Heathlands as a so-called Garden Development which has been proven to be undeliverable, unsustainable and unviable by a number respondents under consultation 18, 19, the inspection and Fish Legal's further letter to the inspector. The main modifications proposed by Maidstone Borough Council does not change this evidence that proves Maidstone Borough Councils Local Plan is politically motivated rather than meeting the NPPF guidelines. The proposed modifications do not change the fact that the allocation derives from a flawed spatial strategy. The Maidston Local Plan remains unsound which a number of respondents have proved. The Council and the inspector can not continue to ignore the evidence, Maidston Council should be sent back to the drawing board and be forced to evaluate the Leeds Langley bipass as they where requested to in 2017.

I refer to the consultation regarding the MBC Local Plan Modifications.   I should be grateful if you would confirm that the field to the east of Thorn Road and to the west of LPRSA295, will be removed from the Marden Settlement Area in the finalised MBC Local Plan.   This field is owned by myself and other local neighbours and is retained as agricultural countryside.   Your assistance is much appreciated.

Please find enclosed MBC Local Plan Review consultation feedback from South Ward Councillors Derek Mortimer, Paul Wilby and myself, Regards Brian Clark   Amendment to Policy LPRSA270   The "Main Modifications” to Maidstone’s Local Plan Update show a proposed increase from 196 units (a number which had been carefully considered leading up to the Regulation 18 and which remained throughout each stage of public consultation, including Regulation 18 and Regulation 19) to 300 units for this site, a 53% increase from the initial number, which we feel is unacceptable.   As local councillors, we have worked with the North Loose Residents Association and other local stakeholders throughout the local plan update process. The organisation has taken a considered approach, accepting that a level of housing would be allocated in the North Loose Area, and contributing thoughtfully to policy LPRSA270, the largest allocation in North Loose.   Instead of challenging the site allocation, the residents' association worked constructively with us and council officers, to develop, what we felt was the best outcome for our residents, even though the majority of the housing was to be developed in North Loose, while the open space was to be transferred to Boughton Monchelsea, a neighbouring parish.   Through each round of public consultation we have jointly continued to be constructive in our feedback, but each time we were responding to a site allocation of 196 units. Given our level of engagement, to find at this final stage of the process, that the number jump by over 50% to 300 is, in our opinion, unacceptable. We are therefore asking that this modification be reconsidered and the original 196 unit figure be reinstated.   Beyond this 300 unit figure, we also have a major concern that a change has been made to increase the maximum developable residential land from 11 hectares to “12-14” hectares. Firstly, from our perspective a “maximum” should not be range. In this case stating "12-14ha" would in reality equate to the maximum size being 14ha.   At 30 units per hectare, a maximum of 14 hectares would give the possibility of 420 units, a figure which has never been considered for this site throughout this update process. Earmarking "no less than 25ha of open space" will of course benefit the local area, but our concern is that that could put further pressure on the delivery of housing in a single field in North Loose at much higher unit levels than previously considered. We asked that at the very least this figure remain as 11 but would recommend a lower figure, more reflective of the delivery of 196 units (at 30 units per hectare).   Beyond the housing numbers, in Maidstone there has been a movement away from a focus on “country parks”, with a focus on visitor enjoyment (as these can come with an associated impact on local infrastructure and need the for visitor car parking), towards a "nature reserve" model, with an emphasis on maximising benefit to nature, especially biodiversity.   The council recently worked with local councillors to put forward a number of borough sites for national nature reserve status, successfully gaining local nature reserve status for several, with several more progressing.   As such we would ask that “local nature reserve” replace references to "country park” in the policy.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

Please find enclosed MBC Local Plan Review consultation feedback from South Ward Councillors Derek Mortimer, Paul Wilby and myself, Regards Brian Clark   Amendment to Policy LPRSA270   The "Main Modifications” to Maidstone’s Local Plan Update show a proposed increase from 196 units (a number which had been carefully considered leading up to the Regulation 18 and which remained throughout each stage of public consultation, including Regulation 18 and Regulation 19) to 300 units for this site, a 53% increase from the initial number, which we feel is unacceptable.   As local councillors, we have worked with the North Loose Residents Association and other local stakeholders throughout the local plan update process. The organisation has taken a considered approach, accepting that a level of housing would be allocated in the North Loose Area, and contributing thoughtfully to policy LPRSA270, the largest allocation in North Loose.   Instead of challenging the site allocation, the residents' association worked constructively with us and council officers, to develop, what we felt was the best outcome for our residents, even though the majority of the housing was to be developed in North Loose, while the open space was to be transferred to Boughton Monchelsea, a neighbouring parish.   Through each round of public consultation we have jointly continued to be constructive in our feedback, but each time we were responding to a site allocation of 196 units. Given our level of engagement, to find at this final stage of the process, that the number jump by over 50% to 300 is, in our opinion, unacceptable. We are therefore asking that this modification be reconsidered and the original 196 unit figure be reinstated.   Beyond this 300 unit figure, we also have a major concern that a change has been made to increase the maximum developable residential land from 11 hectares to “12-14” hectares. Firstly, from our perspective a “maximum” should not be range. In this case stating "12-14ha" would in reality equate to the maximum size being 14ha.   At 30 units per hectare, a maximum of 14 hectares would give the possibility of 420 units, a figure which has never been considered for this site throughout this update process. Earmarking "no less than 25ha of open space" will of course benefit the local area, but our concern is that that could put further pressure on the delivery of housing in a single field in North Loose at much higher unit levels than previously considered. We asked that at the very least this figure remain as 11 but would recommend a lower figure, more reflective of the delivery of 196 units (at 30 units per hectare).   Beyond the housing numbers, in Maidstone there has been a movement away from a focus on “country parks”, with a focus on visitor enjoyment (as these can come with an associated impact on local infrastructure and need the for visitor car parking), towards a "nature reserve" model, with an emphasis on maximising benefit to nature, especially biodiversity.   The council recently worked with local councillors to put forward a number of borough sites for national nature reserve status, successfully gaining local nature reserve status for several, with several more progressing.   As such we would ask that “local nature reserve” replace references to "country park” in the policy.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

Regional External Affairs Officer, South East Woodland Trust

MM16 it is disappointing given the extensive modifications to LPRSP4(B) that our requested modification to provide appropriate buffers for ancient woodland is not included The National Planning Policy Framework (NPPF) 2021 (paragraph 180c) states: “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”. We are concerned that this site contains areas of ancient semi-natural woodland (ASNW) at the following grid references; Roots Wood ASNW (Grid reference: TQ7810962471) Unnamed ASNW at TQ7841162079   In addition it is adjacent to the following areas of ancient woodland; Reed’s Croft Wood ASNW/PAWS (Grid reference: TQ7809662154) Unnamed ASNW at TQ7829861644 The draft policy fails to mention ancient woodland or the necessary protection for these areas. We recommend amending the policy to add new para 7h) 7h) A minimum 50 metre buffer should be maintained between areas of development and areas of ancient woodland.

Regional External Affairs Officer, South East Woodland Trust

Regional External Affairs Officer, South East Woodland Trust

MM24 Not sound as not in line with national policy on the protection of ancient woodland. It is disappointing given the other modifications to LPRSP5(C) that our requested modification to provide appropriate buffers for ancient woodland is not included. Lenham broad location for housing growth  The National Planning Policy Framework (NPPF) 2021 (paragraph 180c) states: “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”.  We note that this site contains the following areas of ancient woodland:  Wheatgratten Wood ASNW (grid   reference: TQ9115750805)  New Pond Shaw ASNW(grid reference: TQ9144950673)  East Lenham Roughett ASNW (grid   reference: TQ9090951184)  Round Wood ASNW (grid reference: TQ9018051273)  Alder Bed ASNW (grid reference: TQ9009149910)  In addition it is adjacent to   Wichling Wood ASNW (grid reference: TQ9259750641)  The draft policy para 8 says “Protect and,where possible, enhance any features of biodiversity value” but fails to make explicit mention of ancient woodland or its necessary protective measures. We recommend amending the policy to add new text to para 8… including adequate buffers for areas of ancient woodland and other proectected habitats.

Regional External Affairs Officer, South East Woodland Trust

MM15 - LPRSP4(A) (5)Infrastructure, part (d) Southern Water is the statutory wastewater undertaker for Lenham. Dependent on options taken forward, proposals for 5000 dwellings at this site will generate a need for the upgrade and possible expansion of Lenham Wastewater Treatment Works (WTW) in order to provide additional capacity to serve the development, as well as the wider Lenham settlement. As per our response to the Regulation 19 consultation, new development must be adequately separated from WTWs to safeguard the amenity of future occupants. This is in line with paragraph 174(e) of the National Planning Policy Framework (NPPF, 2021), which states that planning policies should prevent 'new [...] development from [...] being adversely affected by, unacceptable levels of soil, air, water or noise pollution', paragraph 185 which states 'Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on [...] living conditions', and paragraph 187 which states ‘Planning policies and decisions should ensure that new development can be integrated effectively with existing businesses and community facilities […] Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established’. Having regard to this, Southern Water sought the assurance of policy provision to ensure that the layout of any development scheme at Lenham Heathlands is informed by an odour assessment, to ensure adequate separation from the existing wastewater treatment works (WTW). Such an assessment also having regard to the potential future need of the WTW to expand its operations in order to accommodate forecast population growth in the area. We note the MM15 wording addition to the Infrastructure section (5) part (d) of LPRSP4(A) however this refers to 'sufficient distance between the new Wastewater Treatment Works' only, as below: "d) The delivery of an improved or new waste water treatment facility covering the Greater Lenham / Upper Stour catchment, including sufficient distance being provided between the new Wastewater Treatment Works and residential development, taking account of the potential need for future expansion, and allow for adequate odour dispersion, on the basis of an odour assessment to be conducted in consultation with Southern Water;" We therefore request that this wording be updated to ensure that it applies to existing wastewater treatment works - we suggest by removing the word 'new' to then read as follows: "d) The delivery of an improved or new wastewater treatment facility covering the Greater Lenham / Upper Stour catchment, including sufficient distance being provided between the wastewater treatment works and residential development, taking account of the potential need for future expansion, and allow for adequate odour dispersion, on the basis of an odour assessment to be conducted in consultation with Southern Water;"

Comment noted and suggested amendment to LPRSP4(A) section (5) part (d) agreed.  Revised text to read as follows: d) The delivery of an improved or new wastewater treatment facility covering the Greater Lenham / Upper Stour catchment, including sufficient distance being provided between the new  wastewater treatment works and residential development, taking account of the potential need for future expansion, and allow for adequate odour dispersion, on the basis of an odour assessment to be conducted in consultation with Southern Water;"

Dear Sir/Madam   Further to receiving emails and a letter regarding the above.   Our views remain the same regarding proposal LPRSA312 Land North of Heath Rd Coxheath. Copy of original letter attached. In fact it is even more relevant now as a consultation document has just been sent to us regarding a planning application that is to be submitted on Land South of the existing surgery on Heath Road, between Linton Crossroads and Coxheath.   Land Owners/Developers/Agent’s will not be content until every piece of green land has been developed upon, in order for them to move onto the next village.   Who is protecting the people that live in these villages ?   Regards Chris and Hazel Rose

I am writing this email to express my concerns regarding the proposed increase of the housing development on Pested Bars Road. I have lived in Loose for over 10 years and in this time I have witnessed a significant build up of traffic, pressure on schools, doctors and dentists as a result of continuous development of nearby fields and woodlands. I am concerned further development will exacerbate the existing problems and make life more miserable for those of us who are spending hours stuck in traffic, struggling to access medical appointments and local services. The infrastructure for this plan simply does not exist and continuing to over develop in this manner will be at the detriment to the residents. I ask you to consider the quality of life for the people of this local area and how further development will impact our daily lives.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. We do not consider that any revisions to the Main Modification are necessary to make the plan sound and/or legally compliant.

The latest traffic modelling was biased (by an optimistic prediction of EV uptake, by excluding 2m depth of road verges from the study and excluding the likely effects of the 660 houses to be added after 2038, even though their construction and future residents would still add to local environmental impact) to maximise chances of "scientific certainty" that this development would not adversely affect the integrity of the North Downs Woodland SAC. Despite this, it still found firstly that increased N deposition along Boxley Road was likely to have an adverse effect (so that a Mitigation Strategy would have to be agreed with Naural England before the Plan can be adopted) and secondly that air pollution in this area already exceeds site-relevant critical loads, so mitigations should be put in place even without further housing development at Lidsing and the Local Plan should not include any housing development that could increase traffic on Boxley Road.The mitigations suggested are neither plausible nor sufficient to prevent or offset damage to the connectivity of wildlife habitats in this area: Traffic calming is already in place in Boxley and Bredhurst, so can't be added as a mitigation, and Medway Council have not agreed to a link via North Dane Road, without which traffic into Medway will impact habitats alongside Ham Lane/Shawstead Road, Capstone Road and Hempstead Road (including Capstone Country Park, Darland Banks KWT Nature Reserve and South Wood Local Nature Reserve). Without new, heavily subsidised (electric) bus links into Maidstone and Medway Towns, no strategic road signage or configuration of estate roads will deter residents, their visitors and delivery drivers from acccessing/exiting via Boxley and Bredhurst and the provision of cycle and pedestrian facilities will encourage very few (very fit!) cyclists to undertake the 180m ascent/descent to Maidstone town centre on their daily commute. Green Travel Planning initiatives are supposed to include the provision of new primary and secondary schools within the Capstone Valley, but MBC has no "Statement of Common Ground" with Medway Council and it is unclear which schools and GP surgeries will serve new residents before 2033 (the earliest date given for provision of these services). Another suggested "mitigation", off-site planting will not reverse local damage to habitat connectivity and many of the possible locations for new native woodland planting are already earmarked to offset potential environmental damage due to increased traffic from the Lower Thames Crossing and widening of the A229 (Bluebell Hill). It is hard to see how this development, involving the loss of 13 hectares of green space (linking the Capstone Valley and Darland Banks Nature Reserve with Bredhurst Woods and the North Downs Woodland SAC) can be compatible with the national requirement (expressed in MBC's Biodiversity & Climate Change Action Plan and the Local Nature Recovery Strategy) to provide a 20% Net Gain in Biodiversity and specifically the landscape-scale reconnection of habitats. Paragraph 7 (Environmental) (i) of the Main Modifications to Local Plan Review document states that "Development proposals must demonstrate that the Lidsing garden community, either alone or in combination with other relevant plans and projects, will avoid adverse effects on the integrity of the North Downs Woodlands SAC, due to air quality, with reference to Policy LPRSP14(A). Mitigation measures will be required where necessary and appropriate." Medway Council's plans are very relevant in this context: Landscape-scale habitat connectivity is key to the integrity of the North Downs Woodlands SAC and will be severely damaged if the Lidsing Garden Community development isolates the Capstone Valley from Bredhurst Woods and the North Downs, removing environmental barriers to future development of the rest of the Capstone Valley. It is clear that the proposed mitigation measures will not be sufficient to offset this damage and the only way to ensure that Lidsing Garden Community will avoid adverse effects on the integrity of the North Down Woodlands SAC is not to build 2000 new homes here. A further comment on Paragraph 3 (Masterplanning and design parameters) (l) regarding the employment buildings flanking the M2: Rather than siting these "gable on" to the motorway to reduce the visual massing of the built form when viewed from the south, they should be oriented east-west so that all can have south-facing solar roof panels to support MBC's carbon neutrality objectives. This would also allow them to be staggered, diagonal to the motorway, reducing their visual impact.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Christopher Bernard Sheppard

Christopher Sheppard supporting Boxley Parish Council ‘s response to the Main Modifications MM16  relating to LPRSP4(b) pages 20-32 on document ED121 Schedule of Main Modifications to the Regulation 19 Maidstone Local Plan Review   I personally share all of the views of Boxley Parish Council (BPC) on the following Main Modifications as lacking sufficient detail for the following reasons:   LPRSP4 (B)   MBC’s proposed new paragraph to follow paragraph 6.77: Impact of new development on the integrity of the North Downs Woodlands SAC.   Comment on introductory paragraph:   It is not acceptable to wait until nitrogen deposition exceeds the criteria set out in the IAQM guidance.  For consistency it is essential that mitigation and an effective strategy are included in the Local Plan for developers to follow.   Comment on sub-paragraphs:         Not enough detail in the current proposal to enable proper answers. Will the school be built before first occupation and by who? Who will build the proposed medical facilities? Will anyone be in place to operate them before first occupation?  Will they be open at first occupation? Commercial facilities – who will build them? Will they be open at first occupation? ii        The very nature of the layout of Boxley village (and Bredhurst) precludes any possible meaningful mitigation further to that already in place.  iii        It is obvious that whoever drafted this modification has not actually tried to walk or cycle up or down Boxley Hill.  In the heart of the AONB this already busy road is very steep and narrow with steep banks either side. There is therefore no scope for improved facilities for pedestrians or cyclists.   Their absence would lead to almost total reliance on motor vehicles for anyone wishing to access Maidstone via this route. iv        Mere access to an EV charging point is not enough. Every house needs to have an EV charging point fitted as standard (and, ideally, solar panels). v        No comment. vi        No comment. vii       “Off-site planting” should be made “on-site planting”.  If planting is off-site with no restrictions as to on distance it would not mitigate air pollution within the development.  Mitigation measures as detailed in Air Quality Planning Guidance 2017 require using green infrastructure to absorb dust and other pollutants. This given the size of the proposed garden village would require all mitigation measures to be on site. viii      We cannot see how this is possible.  The new spur link to Junction 4 may not be completed until some 1,340 houses have been built. By then residents will have routes using the existing network embedded and any mitigation of this nature will be ineffective. ix        We fail to see how the proposed location for higher density apartment type accommodation will reduce vehicle ownership.  x        This is directly against current government strategy which is encouraging  people to return to offices and reduce home working. xi        This should be an MBC policy document and integral to the Local Plan.   The above issues need to be addressed for the plan to be considered sound.   Proposed amendments to Policy LPRSP4(B)   The Council (BPC) views the following criteria deficient for the following reasons:   Phasing and Delivery   Preliminary More detail is required for the plan to be sound.  The Transport Assessment needs to be completed before the development is added to the Local Plan.  The transport modelling has been proved incorrect by BPC when compared with the actual traffic surveys BPC have conducted and commissioned.   The criteria for the Monitor and Manage Strategy needs to be set out at the Local Plan stage.   It is not good enough to wait until monitoring shows a problem as it will then be too late to put in any mitigation.   Phase 1 For this to be sound the completion of the M2 J4 spur needs to be implemented at this stage to avoid overwhelming local roads.  If this spur is not completed until 2038 some 1,340 houses will be completed.   Phase 2 For the plan to be sound all mitigations should be addressed in phase 1, including off-site traffic mitigations in Boxley and Bredhurst which are difficult to envisage. It is too late to implement a Monitor and Manage strategy in phase 2. For the plan to be sound the primary school should be started in Phase 1. If not completed until 2038 the children from some 1,340 homes will already be enrolled in establishments off-site and unlikely to change. This will lead to ever‑increasing school run traffic on all roads around the development.  Similarly with medical facilities, there will be potentially have some 1,340 households using off-site facilities that cannot cope with even the existing population. There is provision for Section 106 contributions to construct the school but no such provision for the medical facilities, giving no guarantee that they will ever be constructed or operational.   The comments in Phase 1 and Phase 2 are supported by paragraph (c) which states that the environmental mitigations must be delivered in advance of construction and that requisite infrastructure is ready to operate “upon occupation” – although this paragraph needs to be amended to read “first occupation”.   Housing   b) The target of 40% affordable housing is acceptable but pricing should be at a rate that is affordable for residents on the average wage for Maidstone. Much ‘affordable’ housing is often outside the range of local residents and relies on government schemes such as ‘Help to Buy’ (currently only available in Wales).   3)        Master planning and Design Parameters   b) How can the Capstone Valley be enhanced when so much land will be taken away to be built on? Land that is already an inherent part of the landscape.   c) Boxley Parish Council cannot see how Capstone Valley’s utility will be significantly enhanced for recreation when three quarters of it is built on.   d) Boxley Parish Council do not see how a positive outfacing edge can be achieved from the AONB or Bredhurst.     4)       Employment/Commercial                     Boxley Parish Council has concerns about the Employment Site not being started until phase 2.  By the time it is completed some 1,340 houses will have  bee been constructed.  Without employment opportunities these residents will have to work off site with all the associated road journeys creating additional unsustainable pressure on local roads.            Boxley Parish Council wishes to see the employment site started at the same time as the housing otherwise residents will seek employment off-site and may be reluctant to change, This will lead to increased traffic when employers seek labour from elsewhere.   5)       Infrastructure   b) Boxley Parish Council would like this to remain unchanged and a new secondary school created in the Capstone area. No known plans exist for Maidstone Borough Council to build a secondary school in the north of the borough.  Currently most secondary school pupils use Medway schools which are already at capacity.  Increasing the capacity of existing schools, if feasible, is a short term solution when a long term one is required.   d) The loss of 31 ha of natural/semi-natural open space is unacceptable for no given reason or explanation. This development together with the two already approved will concrete over three quarters of Capstone Valley. These 31 hectares are vital for environmental sustainability and connectivity.             6)       Transport Connections   Direct access to the M2 must be created at latest before first occupation to avoid overwhelming local roads. It would also be the best, safest route for construction traffic.   f) This statement is very generalised and it is not possible to properly quantify a response when no detail is given. Boxley Parish Council already deals with current ‘rat running’ issues through Boxley Village on behalf of residents and having had extensive contact with Kent County Council Highways department fail to see what measures can be put in place that would have any effect on people’s habits. More detail is required on what measures are proposed.  Monitor and Measure is not acceptable as short-cutting through local roads will be well established and any measures put in place when a problem develops are unlikely to change established routes. How can telling a motorist to spend more in fuel and time on his journey to work by avoiding the shortest route through the villages be justified?  This is surely never going to work in practicable terms.   g) No comment possible without the Supplementary Planning Document.   Environmental   Looking at the new key diagram this is not achievable on site, especially with the loss of 31ha of open space.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Please record my objection to MM16LPRSP4 (B) : Lidsing Garden Community which I consider unsound and unjustified for the following reasons : I understand the proposed transport network relies on Medway Council selling their ‘Ransom Strip’ (land) and allowing the site to connect onto the North Dane Way. I further understand that Medway Council have objected to the development and there’s no agreement to sell the land so how can the transport element of the plan be sound ? I understand the Main Modifications state there will be a ‘contribution towards the creation of a new secondary school capacity in the Capstone Valley Area’. The Capstone Valley is under Medway Council who I believe have not agreed or planned for a new secondary school in the area and there isn’t even a signed Statement of Common Ground between the two councils. Again how can a plan that relies on this extra educational capacity be sound ? I gather that 31 hectares of natural or semi-natural open space has been REMOVED from the development, yet it is still claimed there will be a 20% net biodiversity GAIN. This claim appears to be wholly unjustified. With reference to the above factors, surely the Lidsing Garden Village should be removed from the plan to make it sound.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

The way this process is set out is to discourage public involvement. These questions are structured so as to remove the potential for opinion, especially of a negative sense.  For example, I read with dismay the plan to increase the number of new dwellings planned to be built within the area, further joining the villages of East Farleigh, Coxheath and Linton. This was previously an area of beautiful countryside which is now over-populated with traffic queuing along main roads while children try to get to school. Amendments to the road network does nothing to address the ridiculous amount of new houses which have destroyed the beauty and tranquility of such villages.This cannot be reversed. Not all new houses need to be built in the South East of England. I travel widely and can vouch that there are many other areas of this country that would benefit from development instead of Maidstone. While I would beseech you to cease and desist from further desecration of spaces the local public held dear, I suspect you aren't listening, everything will go ahead as planned and you will not note the desperate request just to stop. Please. It can't be undone and history will reflect badly the damage you do to the "Garden of England".

I note within MM6 that you base your entire document on the desire to be net-zero by 2030 because of what you describe as "the climate emergency". I fail to see that hoping to be net zero in 7 years time (half way through the delivery of this plan) is an appropriate timeframe to react to an "emergency"(in your words). I would be more impressed to see you LEAD as an authority and strive to be net zero NOW. I see many new dwellings being built in this area with a paltry 800w of solar on the roof. This is entirely missing the point of how renewables should be embedded in the culture of this authority. It is simply not good enough. Your aspirations are disappointing and inadequate and I urge you to set the bar HIGHER.

MM17 (LPRSP5) proposes a modification to part 1) a) of policy LPRSP5 to introduce “A target of 1,300 units at Invicta Park Barracks”. Response: The DIO is in agreement with the main modifications regarding Invicta Park Barracks in this section.

As a general comment, it is noted that the policy wording of the Local Plan refers to Invicta Barracks. For complete accuracy and correct representation, the DIO suggest that the full name of the site is used, i.e. Invicta Park Barracks in all policy references and supporting text.

MM21 (Para 6.94) proposes various modifications to the wording of this paragraph which are considered acceptable. Response: The DIO is in agreement with the main modifications regarding Invicta Park Barracks in this section but comment that the word “broad” should be deleted from the second sentence to allow continuity with MM7. Invicta Park Barracks is now a “Strategic Development Location” and not a “Broad Location for housing growth”.

Response: The DIO has some comments on the main modifications regarding Invicta Park Barracks in this section. Located in the table within MM22 in Phase 2 (from 2032) under the indicative complementary infrastructure the Main Modifications state: “• Subject to Transport Assessment and Monitor and Manage Strategy A229 junction and Sandling Lane improvements completed • Subject to Transport Assessment and Monitor & Manage Strategy, off-site highway mitigations completed” It is common ground that the DIO have been working with MBC and KCC to assess the likely highway and transportation impacts of the site allocation (see ED25 Statement of Common Ground between Maidstone Borough Council and the DIO). In addition, during the break between Stage 1 and Stage 2 of the Local Plan Examination Hearings, additional transport modelling technical assessments were undertaken. WSP, acting on behalf of the DIO, submitted The Invicta Park Barracks Traffic Modelling and Access Junction Review Update Technical Note, referenced as ED96. This Technical Note is cross-referenced in ED124 Maidstone Local Plan Review Sustainability Appraisal SA Report Addendum: Main Modifications in paragraphs 1.20 and 1.21 and also in ED127 Integrated Transport Strategy 2011-2031 - Addendum. DIO accept that a highway contribution will be required as part of the proposed bespoke infrastructure funding agreement or S.106 obligation. However, Invicta Park Barracks is not the catalyst for the improvement works required on the A229 Junction or for any suggested improvements to Sandling Lane other than improvements required to access the site, as identified in the modelling. Therefore, it is suggested by the DIO that Invicta Park Barracks should not be tied to highway works that are required now or prior to the development of Invicta Park Barracks coming forward. It is the view of DIO that Invicta Park Barrack’s contribution should be based on the collective impact from all schemes coming forward (and timings of that impact). For example, the works on the A229 roundabout should be completed when the need arises and not left until the Invicta Park Barracks scheme comes forward. The roundabout is in need of work now (i.e. in 2023) because of other mitigating factors impacting that are not caused by the proposed Invicta Park Barracks scheme. Therefore, this should be mitigated prior to the Invicta Park Barracks scheme coming forward (from 2029) and the Invicta Park Barracks scheme should not be wholly responsible for these improvements. As stated in ED25, The Statement of Common Ground between Maidstone Borough Council and the DIO and in ED96, the WSP Traffic Modelling and Access Junction Review Update: Technical Note (2023) together with evidence presented at the Examination set out the agreed position on highways contributions: “The parties agree that the Invicta [Park] Barracks site and its potential impacts on the road network has been assessed within the Jacobs transport and air quality modelling work. This modelling work is robust and demonstrates that suitable mitigations are achievable to enable the delivery of the development.” The DIO’s preferred wording for MM22 Phase 2 from 2032 would be the removal of the first bullet point but the DIO would find the additional wording below appropriate: • Subject to Transport Assessment and Monitor and Manage Strategy A229 junction and Sandling Lane improvements completed (to facilitate access arrangements). • Subject to Transport Assessment and Monitor & Manage Strategy, off-site highway mitigations in the vicinity of the site are completed. Phase 3 of the delivery and phasing table sets out the final phase to deliver homes by 2037. Under the development column the main modification proposes a: “• New through school” The need for and provision of a school is subject to continuing review by MBC and KCC and therefore the suggested phasing of the new through school is unacceptable to the DIO as a requirement within phase 3. Further, the suggested modification is contrary to the agreed position reached at the Stage 2 Hearings. Within ED25, the Statement of Common Ground between Maidstone Borough Council and the Defence Infrastructure Organisation in the agreed matters section, it explores the Education requirements stating: “Any education requirement and or contribution relevant to Invicta Park Barracks will be subject to ongoing discussions with the key stakeholders and if necessary, will be set out with appropriate wording within the SPD”. This is reaffirmed in paragraph 24 of ED117, the Inspector’s letter to the Council following the Stage 2 Hearing Sessions which states: “…the proposed approach and the indicated school location and cost…will be subject of proposed main modifications and I am not at this stage recommending any further changes to those previously considered at Stage 1.” Within phase 1 of main modification MM22, it proposes wording agreed in evidence presented by the DIO and as discussed and agreed at the Examination Hearing sessions on 24th November 2022 and on 17th May 2023, i.e. the “Identification of land for future educational needs and mechanisms for provision to KCC subject to need being established”. This would be more acceptable wording for the DIO regarding this modification. Therefore, DIO seeks the removal of the wording “New through school” as a requirement in Phase 3 and the insertion of: “Identification of land for future educational needs and mechanisms for provision by KCC, subject to future need being established”. MM22 (LPRSP5(B)), bullet point 7 modification regarding Biodiversity Net Gain states: “7. Preservation of features of ecological importance, including the retention and enhancement of wildlife corridors, and ensuring that connection with ecological features and corridors outside the site is maintained/enhanced, and securing biodiversity net gain, in accordance with Policy LPRSP14(A).” Response: Bullet point 7 has included new modifications within the section in blue above. This will require a 20% Biodiversity Net Gain for the Invicta Park Barracks site “…where appropriate”. The DIO are happy for the proposed blue text to be added to part 7 of the policy with “…where appropriate” inserted for reasons discussed during the examination process, greater flexibility is sought on the implementation of this policy in practice, particularly on the existing rich ecological environment found within parts of the Invicta Park Barracks site. Bullet Point 13 within MM22 is regarding the proposed all through school proposed at the Invicta Park Barracks Site: “13. Provision of an 8 FE all through school (2FE primary and 6FE secondary) on the wider Invicta Barracks site, subject to continuing review of future educational need in Maidstone Borough and an ongoing assessment of other sites in and around the town centre with the scope to accommodate some or all of the educational need.” Response: The DIO would like the modification to remove the reference to “the 8FE all through school (2FE primary and 6FE secondary)” as this is subject to continued review of educational need by KCC. The phrasing of “an Identification of land for future educational needs and mechanisms for provision to KCC subject to need being established”, in phase 1, is considered to be adequate description instead of the 8FE all through school which is overly prescriptive. As referenced above, the Planning Inspector’s Post Stage 2 Examination letter in ED117 required the Council to look at the identified cost and timing of the project when revisiting the Infrastructure Delivery Plan as part of the proposed main modifications and the Inspector recommended no further changes to the policy wording. He stated: “I am not at this stage recommending any further changes to those previously considered at Stage 1” The DIO suggest appropriate wording below, which entails the removal of the first part of the sentence. “13. Subject to continuing review of future educational need in Maidstone Borough and an ongoing assessment of other sites in and around the town centre with the scope to accommodate some or all of the educational need during the Plan period.”

We note these comments, and propose some amendments to the wording of MM22 as follows: (Phase 2) From 2032: Subject to Transport Assessment and Monitor and Manage Strategy A229 junction and Sandling Lane improvements completed (to facilitate access arrangements) . (Phase 3) By 2037: New through school subject to future need being established.

Good evening, I strongly object against the local plan’s proposed modifications for the Lidsing Garden development for the following reasons: Traffic Calming There is already major traffic calming measures in the Bredhurst and Boxley villages, but this doesn’t discourage use of this route between Medway and Maidstone. It has for many years been heavily used by significant numbers of vehicles and has substantial delays due to traffic, especially at peak hours in the morning and evening. Any further residential developments will severely breakdown movement and cause all the local areas to suffer with widespread gridlock on a regular basis, making the route impossible due to the proposed garden village. All the roads in the location would need to be significantly widened and improved to ensure that the area doesn’t turn into an accident black spot causing danger to life, frustrations and anger that the current road system would cause, that still wouldn’t cope with the volumes of vehicles the development would ultimately cause and also cause further loss of countryside. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety. Cycle & Pedestrian Facilities I have personally cycled along the roads from Bredhurst to Maidstone and with the latest requirements to allow a car width distance when overtaking a cyclist, this would be difficult and dangerous along these narrow lanes, especially in peak times. This is not a viable provision to encourage sustainable modes of transport via Boxley and Bredhurst, it is unsound as they are not justified or effective. The roads which connect Lidsing, Bredhurst and Boxley are narrow rural roads without pavements or street lighting. To encourage cyclist and pedestrian use of these roads in their current condition would be reckless and endanger life. If these roads are proposed to be widened to accommodate cycle lanes, pavements and street lighting, this would involve multiple substantial compulsory purchase orders, destruction of hedgerows (which are vital wildlife habitats), removal of ancient woodland and also residents’ front gardens or even properties. There is no evidence to support that this is feasible or the financial implications of this. To make the plan sound, the LidsingGarden Village needs to be removed in its entirety. Secondary Education Provision A secondary school provision is unsound as it is not justified or effective. be A contribution towards the creation of a new secondary school capacity in the Capstone Valley Area would need to be by Medway Council, who have not agreed or planned for a new secondary school in the area. Indeed, there isn’t even a signed Statement of Common Ground between the two councils. Therefore, to make the Local Plan sound, the Lidsing Garden Village should be removed in its entirety. Removal of 31 Hectares of Open Space By removing 31 Ha of natural / semi natural open space’ planned for the Lidsing Garden Village is another element of the showing the aim of profit over caring about the future of the area. Not only is this contrary to Garden Village Principles, it isn’t stated what will be included on the site instead. Surely this also completely negates the claim that the development of 2000+ houses and employment will result in a 20% biodiversity net gain. Therefore this plan is unsound as it is not justified or effective and the Lidsing Garden Village should be removed accordingly. Phasing and Delivery There is no agreement with Medway Council, who own the so-called ‘Ransom Strip’, to complete the link. Medway Council have objected to the Garden Village and there is no signed Statement of Common Ground between MBC and Medway. Therefore, to make the plan sound, the LidsingGarden Village needs to be removed.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

To whom it may concern,   I am putting my objection forward on the Lidsing Garden Proposed Development. My objection is on the main modification. This is unsound, not justified or effective due to poor transport connections. Lack of facilities such as schools, health care facilities. Also destroying our AONB whose distinctive character and beauty are precious enough to be safe guarded in the national interest.   The proposed transport network relies on Medway Council selling their 'Ransom Strip' and allowing the site to connect onto the North Dane Way. Medway Council have objected to the development and there's no agreement to sell the land.   The Main Modifications state that there will be a “contribution towards the creation of a new secondary school capacity in the Capstone Valley Area”. The Capstone Valley is under Medway Council who have not agreed or planned for a new secondary school in the area. There isn’t even a signed Statement of Common Ground between the two councils.   31 HECTARES of natural or semi-natural open space has been REMOVED from the development, yet they still claim there will be a 20% net biodiversity GAIN. This concludes my objection.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Dear Sirs   I may be wrong but I don't think the above deals with the sometimes negative effects of HMOs in established residential areas- can you advise?   Also it does occur to me the extent to which the Local Plan is able to provide a co-ordinating basis for development is prejudiced by its reliance for implementation on agencies such as at KCC Highways now lacking the resources to fund highway improvements, and utility companies found to be disinvesting in the provision of new/replacement water and sewage infrastructure   Moreover, I'm not sure whether the rapid shifts in central government policy undermine investment in the built and social environment which the Local Plan is attempting to achieve. One example would be house builders not being obliged to provide new builds which meet Green standards and the impact of DFLs on the supply of affordable rented and local owner- occupied housing........   Your guidance on the points raised above would be most welcome   Yours faithfully C. Blackwood xxx

Here is my objection to the proposed Lidsing development;   1) The Medway/Maidstone locale is already the most overpopulated conurbation outside of London, Hempstead in particular currently filled with residential housing to bursting point.   2) A town-sized development on the scale proposed will only attract more over-spill from London, never-ending out of control immigration, and property speculators. It will do nothing for Maidstone and Medway in general, and Hempstead in particular, apart from burden us with even more health, social and travel problems and result in severe loss of amenity. 3) The proposed development will create an overbearing additional locale at least the current size of Hempstead and Lordswood combined, vastly reducing the green space and countryside necessary to allow current Hempstead and other effected residents a space to go to from being packed into an already overpopulated area like sardines in a can. 4) Medway Council has been opposing a proposed 450 homes development at Gibraltar Farm, right adjacent to the proposed Lidsing Garden development for over 15 years. The two developments would effectively wipe out the green space between Hempstead and the outskirts of Maidstone causing even more health, social and travel problems and result in severe loss of amenity. It will turn this once beautiful landscape into a ghetto, ripe for social discontent and unrest, increased crime, and result in a vast reduction in the wellbeing and the quality of life for current residents. At least Medway Council supported by all the effected MPs and councillors, has the good sense to oppose the Gibraltar Farm development. It beggars belief that Maidstone Council should make such an irresponsible and clearly empire-building proposition. Which ever group is responsible should be hounded out of public service for life. Back down and stop Lidsing Garden Village or face years in courts with effected people, businesses and public officials legally opposing this disastrous scheme and in the process Maidstone Council wasting £millions of council tax payers money. 5) Maidstone and Medway including Hempstead in particular already has insufficient levels of NHS, council provided and other services to properly support the existing community. The prospect of something in the order of a further 3500 to 4000 extra people will completely swamp those services bringing the community to a state of bedlam. 6) Allowing this planning application to proceed will open the floodgates for other greedy developers and power-crazed councils to carpet the Maidstone-Medway locale green spaces entirely in bricks, concrete and tarmac. Human beings need green spaces and open areas for their well-being. Deny that, and there will be a vast increase in ill-health, both physical and mental.   Quite frankly, it beggars belief that MBC are even considering this odious development. Go tell Central Government to put their developments in Scotland. England is full, particularly the South-East, and has been for at least 30 years. And its getting fuller everyday with bogus immigrants allowed on shore by a weak, woke-driven government.   I have one question for you: what paricular socio-economic group is the development for? Explain who is going to buy these houses, and where they are living right now. This is question every effected resident in Hempstead, Lordswood, Lidsing and Bredhurst want an answer to, and you must surely know that answer. I look forward to your response. No response will be interpreted as our worst fears, and I take it you know what that is. If you don't, let me know, and I will spell it out for you.     Regarding gypsy camps   Please get the message regarding Lidsing - we don't want your proposed monster-sized housing estate for immigrants or a site for gypsies. Suggest you propose Ireland and Romania for gypsies.   There is a further overriding showstopper that I will submit - the south-east England chalklands water table and rivers will not support any more people residing in Kent, the other home counties and London.   Take a look at this video. The source is an independent assessor who identifies this little known in public circles fact, which nonetheless cannot be ignored and thrumps all other valid social and environmental considerations.   Feargal Sharkey: We’re destroying every river in the country  (https://www.youtube.com/watch?v=bfj3f45hXPo)

Please find enclosed MBC Local Plan Review consultation feedback from South Ward Councillors Derek Mortimer, Paul Wilby and myself, Regards Brian Clark   Amendment to Policy LPRSA270   The "Main Modifications” to Maidstone’s Local Plan Update show a proposed increase from 196 units (a number which had been carefully considered leading up to the Regulation 18 and which remained throughout each stage of public consultation, including Regulation 18 and Regulation 19) to 300 units for this site, a 53% increase from the initial number, which we feel is unacceptable.   As local councillors, we have worked with the North Loose Residents Association and other local stakeholders throughout the local plan update process. The organisation has taken a considered approach, accepting that a level of housing would be allocated in the North Loose Area, and contributing thoughtfully to policy LPRSA270, the largest allocation in North Loose.   Instead of challenging the site allocation, the residents' association worked constructively with us and council officers, to develop, what we felt was the best outcome for our residents, even though the majority of the housing was to be developed in North Loose, while the open space was to be transferred to Boughton Monchelsea, a neighbouring parish.   Through each round of public consultation we have jointly continued to be constructive in our feedback, but each time we were responding to a site allocation of 196 units. Given our level of engagement, to find at this final stage of the process, that the number jump by over 50% to 300 is, in our opinion, unacceptable. We are therefore asking that this modification be reconsidered and the original 196 unit figure be reinstated.   Beyond this 300 unit figure, we also have a major concern that a change has been made to increase the maximum developable residential land from 11 hectares to “12-14” hectares. Firstly, from our perspective a “maximum” should not be range. In this case stating "12-14ha" would in reality equate to the maximum size being 14ha.   At 30 units per hectare, a maximum of 14 hectares would give the possibility of 420 units, a figure which has never been considered for this site throughout this update process. Earmarking "no less than 25ha of open space" will of course benefit the local area, but our concern is that that could put further pressure on the delivery of housing in a single field in North Loose at much higher unit levels than previously considered. We asked that at the very least this figure remain as 11 but would recommend a lower figure, more reflective of the delivery of 196 units (at 30 units per hectare).   Beyond the housing numbers, in Maidstone there has been a movement away from a focus on “country parks”, with a focus on visitor enjoyment (as these can come with an associated impact on local infrastructure and need the for visitor car parking), towards a "nature reserve" model, with an emphasis on maximising benefit to nature, especially biodiversity.   The council recently worked with local councillors to put forward a number of borough sites for national nature reserve status, successfully gaining local nature reserve status for several, with several more progressing.   As such we would ask that “local nature reserve” replace references to "country park” in the policy.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

Please find enclosed MBC Local Plan Review consultation feedback from South Ward Councillors Derek Mortimer, Paul Wilby and myself, Regards Brian Clark   Amendment to Policy LPRSA270   The "Main Modifications” to Maidstone’s Local Plan Update show a proposed increase from 196 units (a number which had been carefully considered leading up to the Regulation 18 and which remained throughout each stage of public consultation, including Regulation 18 and Regulation 19) to 300 units for this site, a 53% increase from the initial number, which we feel is unacceptable.   As local councillors, we have worked with the North Loose Residents Association and other local stakeholders throughout the local plan update process. The organisation has taken a considered approach, accepting that a level of housing would be allocated in the North Loose Area, and contributing thoughtfully to policy LPRSA270, the largest allocation in North Loose.   Instead of challenging the site allocation, the residents' association worked constructively with us and council officers, to develop, what we felt was the best outcome for our residents, even though the majority of the housing was to be developed in North Loose, while the open space was to be transferred to Boughton Monchelsea, a neighbouring parish.   Through each round of public consultation we have jointly continued to be constructive in our feedback, but each time we were responding to a site allocation of 196 units. Given our level of engagement, to find at this final stage of the process, that the number jump by over 50% to 300 is, in our opinion, unacceptable. We are therefore asking that this modification be reconsidered and the original 196 unit figure be reinstated.   Beyond this 300 unit figure, we also have a major concern that a change has been made to increase the maximum developable residential land from 11 hectares to “12-14” hectares. Firstly, from our perspective a “maximum” should not be range. In this case stating "12-14ha" would in reality equate to the maximum size being 14ha.   At 30 units per hectare, a maximum of 14 hectares would give the possibility of 420 units, a figure which has never been considered for this site throughout this update process. Earmarking "no less than 25ha of open space" will of course benefit the local area, but our concern is that that could put further pressure on the delivery of housing in a single field in North Loose at much higher unit levels than previously considered. We asked that at the very least this figure remain as 11 but would recommend a lower figure, more reflective of the delivery of 196 units (at 30 units per hectare).   Beyond the housing numbers, in Maidstone there has been a movement away from a focus on “country parks”, with a focus on visitor enjoyment (as these can come with an associated impact on local infrastructure and need the for visitor car parking), towards a "nature reserve" model, with an emphasis on maximising benefit to nature, especially biodiversity.   The council recently worked with local councillors to put forward a number of borough sites for national nature reserve status, successfully gaining local nature reserve status for several, with several more progressing.   As such we would ask that “local nature reserve” replace references to "country park” in the policy.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

COMMENTS BY BOROUGH COUNCILLORS SPOONER AND SPRINGETT (BEARSTED WARD) We both wish to set out for the record, our severe disappointment that Housing Allocation Site LPRSA 266 – LAND AT WARE STREET, THURNHAM remains within the Local Plan Review. Together with former Borough Councillor Cuming we submitted sound planning objections to this allocation in our submission of 12 December 2021. We both re-iterated these objections in a further statement dated 15 May 2023 and Cllr Springett presented them to the LPR Hearing on  16 May 2023.  We remain strongly of the view that the inclusion of LPRSA 266 in the LPR makes a mockery of four recent Planning Appeal decisions rejecting speculative housing development on sites surrounding and within close proximity to allocation LPRSA 266. We anticipate that the development of LPRSA266 will severely compromise open land immediately to its west, north and east which will significantly encroach into open countryside, contrary Development Plan Countryside Protection Policies and substantially impact on the setting of the Kent Downs AONB contrary to the provisions of the National Planning Policy Framework.

Introduction The proposed modifications detailed at MM16 do not mitigate the extensive harm that would be caused to Bredhurst, Lidsing, Walderslade, Lordswood, Boxley and all neighbouring areas should the Lidsing Garden Village development proceed. The modifications detailed at MM16 do nothing to enhance LPRSP4(b) which remains unsustainable, undeliverable, unviable, and The Lidsing allocation must be removed from the Plan in its entirety. Garden Settlement & Strategic Development Locations LPRSSl, MM7 (6) states 'new, sustainable Garden Settlements are identified at Lenham Heath and Lidsing which will provide new homes, jobs and services, all delivered to garden community principles.' The Lidsing Garden Village proposal (LPRSP4(b)) does not adhere to 'Garden Community Principles' as set out in Government Policy. It would create a dormitory development which will not enhance the natural environment, will not provide integrated and accessible transport systems but instead will be heavily car dependant forcing vehicles onto unsuitable country lanes which are already used as 'rat runs' between Medway and Maidstone. North Downs Woodlands Special Area of Conservation (SAC) The impact of new development on the integrity of the North Downs Woodlands SAC must be afforded a much higher level of consideration. The wording inserted after para 6.77 is unhelpful and gives little assurance of the protection of this area. It is wholly inadequate to state 'if nitrogen deposition exceeds the screening criteria set out in IAQM guidance {1% of the SAC's critical load for nitrogen deposition), then mitigation will be required'. It is imperative that mitigation measures must be agreed at the onset before limits are exceeded. The wording continues 'applications must clearly demonstrate through project-level HRA that the Mitigation Strategy is appropriate, can be feasibly implemented and will be sufficient to fully mitigate any identified adverse effects on the SAC. This paragraph demonstrates that there is no mitigation in place at this stage and, therefore, the Lidsing allocation is not justified and is unsound.   Further MM Wording: 'Applicants should have regard to the following package of mitigation measures which may be deployed, either in isolation or in-combination, as and when necessary and appropriate for air quality. The mitigations, which are in no particular order and are not exclusive, are as follows: i.Green Travel Planning focussed on employment facilities, commercial facilities, schools, and the use of transport connections within and adjacent to the development. It is farcical to use the words 'green travel planning' in relation to Lidsing Garden Village. The proposed development is miles from the nearest train station and the roads south of the site towards Maidstone are unlit country lanes totally unsuitable for cyclists or pedestrians. If Lidsing Garden Village proceeds it will be almost totally car dependant. ii. Traffic calming to discourage access/egress via Boxley and Bredhurst There is already extensive traffic calming throughout Bredhurst and Boxley and there is no capacity to add to this. The examples given by the promoter at the Stage 2 Hearing all demonstrated traffic calming measures in urban not village settings and all required street lighting which neither village has nor wants. The proposals put forward at the Stage 2 Hearing would reduce the road width in Bredhurst which would not allow farm vehicles to access fields. In addition, Boxley Village has a number of listed properties so road widening in this location is not an option. iii. Provision of cycle and pedestrian facilities to encourage sustainable modes of transport via Boxley and Bredhurst. This is a absurd proposal as it would entail cyclists and pedestrians to use narrow, unlit country lanes, most of which the national speed limit of 60mph applies. Boxley Hill itself is 2.6km long with an average gradient of 5.9% and a maximum of 15.7% at its steepest part. The route is bordered by ancient woodland, arable fields and is in the AONB, therefore, widening or straightening of the road is not an option. iv. On-site measures to encourage/increase take up of low emission vehicles, such as EV charging points. It must be mandatory that EV charging points are installed for all new dwellings. v. HGV and other vehicle "site servicing" and "delivery route" management strategies It is difficult to envisage how HGVs and other vehicles will access the site or what 'management strategies' could entail as much seems dependant on the new west/east link road which requires Medway Council to sell land adjacent to North Dane Way. Medway Council remain adamant they will not sell this land and are totally opposed to the Lidsing development. Without the west/east link, HGVs will have to negotiate single track country lanes if exiting the M2 at junction 3 or through residential roads in Hempstead if exiting the M2 at junction 4. The alternative route from this junction would be through the unlit lanes of Bredhurst.   vi. Strategic road signage strategy The Local Plan cannot be found sound without this in place. vii. Off site planting at agreed locations and species. Details of locations and species  must be provided  at the Main Modification  stage.  It is not sufficient to provide this information at a later stage. Proposals must also give evidence as to the effectiveness  of  'off-site'  planting and how this will mitigate  poor air quality and pollutants which development at Lidsing will generate . viii. The design of residential layouts and configuration of estate roads in a manner which discourages access/egress via Boxley and Bredhurst. This is not physically possible unless all vehicles are to use equally unsuitable residential roads through Hempstead or unlit country lanes (Westfield Sole Road, Capstone Road or Ham Lane) . ix. Typologies of development located at the southern sector of the site which generate lower car ownership levels of trip rates, i.e. higher density apartment type accommodation, older persons accommodation. There is no evidence to support that higher density apartments or older persons accommodation will result in lower car ownership. x. Home and flexible working supported by broadband infrastructure to encourage and enable people to drive less.  Home and flexible working is only available to a limited number of roles so would probably not be applicable to the majority of residents. xi. Low emission strategy at south of site and through Boxley/Bredhurst. A low emission strategy should be applied to the whole of the site, not just to the south and through Boxley/Bredhurst. Residents in Lordswood, Walderslade and adjoining locations in Medway will be subject to increased and unacceptable emission.   Phasing and Delivery Preliminary The wording here is very weak with insufficient detail to comment. The major flaws in the deliverability of essential infrastructure needed to make Lidsing Garden Village 'sound' cannot and should not be addressed by an SPD. The monitor and manage strategy is not an acceptable approach. The NPPF states growth must be aligned with infrastructure, not that infrastructure will be considered as an afterthought. Phase 1 - (No later than 2028 to 2032 - circa 590 houses in the first five years) There is no methodology or evidence to support the delivery of the pt phase of 590 houses which appears to be totally reliant on the new east/west link road from North Dane Way to Maidstone Road. This was amended at the Stage 2 Hearing and is referred to as the 'interim scheme'. It was submitted without any viability evidence, detailed assessments, or Highway Authority approval. The 'interim scheme' is dependent on 3rd party land with no guarantee it will be available and no transport modelling has been presented. How can a statement be made that during this stage, the West- East link road will be completed and will facilitate the full orbital bus route? As has been repeatedly said, there is absolutely no assurance that the West-East road will ever be completed as Medway Council continue to state that the land needed for this, which is under their control, will not be sold. What does 'proportionate secondary school contributions received' mean? It appears that 590 houses will be built without any assurance of school places being available. Phase 2 - (2033 to 2038 - cumulative total of 1340 houses completed by 2038) The statement - 'completion' of the M2 J4 spur, with 'possible' interim utilisation of existing Maidstone Road bridge crossing to allow the employment development to commence early in this stage' is a grave There could be 1340 houses built plus employment development with no supporting road infrastructure. Consultation with local communities at this stage to discuss mitigation requirements is far too late in the process. By this time, local communities will have already suffered greatly and the occupants of 1340 houses will have formed established travel patterns. It is not acceptable to  state that towards the end of this stage  (2038)  as necessitated by demand, that the replacement  bridge  crossing could  be opened. From the very start of this process, residents were informed  that  a  replacement  bridge  crossing would be built but it seems, like many other issues, this has been watered down and it appears that there is no clear intention of constructing the originally proposed link to M2 junction 4. There is insufficient evidence to support the 'interim' arrangement of connecting to Maidstone Road and inadequate calculations of cost. The main modifications do not give confidence that the original M2 junction 4 scheme will ever be complet ed . This is a fundamental flaw and, therefore, the proposed development at Lidsing is unsound and undeliverable. There is no assurance of the transfer of land or costings for the 3FE primary school or health care centre which could result in new occupants without necessary local facilities. Phase 3 (By 2042 - cumulative total of 2000 houses) No details given as to how proportionate secondary school contributions will be received. Housing The 40% "target" for affordable housing provides no obligation to provide any particular figure. Evidence previously submitted has already questioned the viability of the development because of unknown land and infrastructure costs. There is a real danger that the scheme promoters will not be able to meet an appropriate level of affordable housing. Masterplanning and Design Paragraph e) relating to restriction of "floor plates" has been deleted. Will this reduce the protection for the AONB? There is no definition of what 'positive enhancements' can be made to the Capstone Valley and to the setting of the If Lidsing proceeds, along with other applications being fought by Medway Council from the same promoter, the entire Capstone Valley will be developed. The statement that the development will create 'a positive outfacing edge when viewed from the Medway urban' is totally disingenuous. Medway residents currently have far-reaching views over open farmland and they are furious this could be lost forever to a housing estate. At 3j - mention is made of a 'green bridge connection across the motorway'. There are no details as to how, where or when this would be delivered, neither have any viability or technical assessments been provided. It is a baseless statement without evidence to support its implementation. Employment/Commercial With the woefully lacking detail of infrastructure provided, it is difficult to understand how people will travel to the 2,000 new jobs nor is there evidence that the strategic road network has the capacity for new workers in addition to the occupants of the 2000 It is na'ive to believe that a high percentage of jobs will be taken by the new occupants. Realistically, new workers will come from far and wide which again will create huge traffic issues for the whole area. Infrastructure No strategy has been provided for additional Secondary School accommodation in the Capstone Valley. Undefined contributions will not ensure that additional capacity will be provided. Land for such facilities has not been identified and the cost of construction has not been assessed. Similarly, there is a chronic shortage of hospital capacity and health facilities in the Medway area and there is no assessment or strategy for addressing the situation with Medway Council or the Regional Health Authority. . The unexplained deletion of paragraph d (v) relating to the provision 31Ha of open space appears to be a major departure from the original Garden Village principles and is totally unacceptable. Transport Connections The first paragraph must refer to the need for consultations with Medway Council who will be the relevant Highway Authority for many of measures associated with site access arrangements and off-site transport/highway mitigations. Environmental There has been no assessment of the impact of the development on wildlife and biodiversity. It is essential that before any development takes place there is a fully detailed ecological and landscape study. The huge loss of open farmland will be detrimental to many species particularly ground nesting birds such as the "red listed" Skylark, birds of prey and many other species. The target for 20% biodiversity improvement is completely without any technical basis and is unachievable. This is particularly the case given the proposed deletion of the provision of 31 Ha of open space mentioned above (Infrastructure - paragraph 30). Conclusion The numerous reasons detailed above clearly demonstrate that the proposed development at Lidsing - Policy LPRSP4(B) is not justified, ineffective and unsound and must be deleted.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Main Comments concerning Heathlands Settlement Lenham Heath LPRSP4(A) We wish to support submissions by Lenham Parish Council. Our view is that this proposal is unsustainable, undeliverable, unviable, and therefore unsound. Nothing that has been brought forward within the main modifications changes our opinion, in fact the vagueness and lack of detail is overwhelming. Without wishing to repeat ourselves nor duplicate what others will say, we will focus on some of the key issues that we feel need emphasising. Throughout this long-truncated process, the Heathlands Garden Settlement evidence has been adjusted modified and cajoled for political purposes from the 2 main political parties on Maidstone Borough Council. The evidence to support has never, and continues to fail to appear, to be considered a sustainable proposal. The strategy of including an allocation of the garden settlement, Heathlands, which performed least well of all the potential locations which are more practical, viable and sustainable continues to render the allocation unviable and undeliverable as a garden settlement. We believe that Garden Settlement Locations identified at Lenham Heath and Lidsing proposed to provide new homes, jobs, and services, will not be delivered to garden community principles and the allocation selection was unjustified and remains unsound. Garden community principles are, “A wide range of local jobs in the Garden City within easy commuting distance of homes. Beautifully and imaginatively designed homes with gardens, combining the best of town and country to create healthy communities, and including opportunities to grow food.” Where is this in the report? “Development that enhances the natural environment, providing a comprehensive green infrastructure network and net biodiversity gains, and that uses zero-carbon and energy-positive technology to ensure climate resilience”. How can this be with a car dependent development? “Strong cultural, recreational and shopping facilities in walkable, vibrant, sociable neighbourhoods. Integrated and accessible transport systems, with walking, cycling and public transport designed to be the most attractive forms of local transport.” The plans show that infrastructure will not be place for those occupying homes in the first phase. Government policy states that Garden Settlement policy “this is not about creating dormitory towns, or places which just use ‘garden’ as a convenient label.” We feel this is exactly the Heathlands proposal. Those who can afford to live within Heathlands will need to commute to employment opportunities to justify their living costs. The policy goes on to say that. “We want to see vibrant, mixed-use, communities where people can live, work, and play for generations to come – communities which view themselves as the conservation areas of the future”. This does not describe this housing estate that will, if built, undoubtedly come forward without the necessary attributes for living, working, and playing. Government policy states “that each will be holistically planned, self-sustaining”. This would surely entail necessary infrastructure to be built alongside housing, this is not proposed for the Heathlands development. Land ownership The proposed development cannot be deliverable without the agreements for 100% of the land. Despite us and others asking for this clarification for over 3 years, it has not been confirmed that all relevant land is available. This is a fundamental omission. ED 128 States Heathlands is viable with a sufficient viability surplus of c. £18.5 million (£60,000 per acre / £148,000 per ha). Our sensitivity analysis shows that a 5% increase in build costs (or a 5% decrease in values) could render this scheme unviable. This seems such a small margin of error and we feel that MBC may be favouring its own scheme, which has been the position from the very beginning.   MM15 “g) having regard to the setting of the AONB” does not give this AONB setting enough significant weight to its importance and protection. Climate change The policy flies in the face of carbon neutral strategy. Nutrient neutrality There has been no mitigation given for the deterioration of the suggestion of a liner for the wetlands. This is a significant health risk. Traffic/Highways There is still a lack of evidence on highway improvements. Traffic modelling is incomplete, the rural roads to the south have not been investigated and are clearly incapable of taking the traffic that would be generated by a proposal such as Heathlands. There has been to date insufficient technical work carried out to demonstrate the impact on the A20 and surrounding roads. The effect on the road network has not been fully considered. Any further evidence and main modifications do not render the policy sound. This proposal could end as a housing estate of hundreds of houses with minimal infrastructure. With those occupying homes having to be totally car dependent for the majority of services. MM15 We note that in the indicative complementary infrastructure list Phase 1 2031-37 has a bus diversion, not a bus route. Not until Phase 3, 2048, 17 years after initial build, will there be a bus links to district centre and neighbouring villages. Movements to necessary services will be predominately by vehicle.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document.

Harrietsham as Rural Service Centre LPRSS1 We would like to give our support to the representation from Harrietsham Parish Council. Our comments are that Harrietshams’ lacking infrastructure continues to reinforce the fact that the village should not be developed further. It is unreasonable and unsound to suggest that Harrietsham with its sparse facilities and services can cope with more development LPRSP6(B). The modification within the review do not address the fact that Harrietsham cannot and should not be classed as a Rural Service Centre.

MM5 We are concerned that the words preserving and safeguarding have been removed in respect of the AONB and replaced with conserving and enhancing Kent Downs & High Weald Areas of AONB. The words conserve and enhance have already been included in the paragraph so have just been repeated. We believe “preserving and safeguarding” should have been retained, this would ensure the seriousness of protection of this asset. The report suggests that development will enhance other distinctive landscapes of local value and heritage designations…. However, there is still no mention of the Lenham Chalk Cross. 'The Cross' is a Grade II hill-figure war memorial at Lenham. This is a memorial which is protected and listed on the National Heritage List for England maintained by Historic England.

MM13 The report states “sensitive transition between the AONB and Heathlands, with a heathland landscape and strong planting in the northern parcels, and landscaped spaces for village greens, parks, commons and naturalistic green spaces throughout.” We feel the establishment and longevity of landscaping is not a given and shouldn’t be used to make an otherwise unacceptable development acceptable.

Network Rail support the inclusion of this wording to set out clearly the timescale for delivery of the Garden Settlement and recognition that additional work is to follow. Where possible, this work should focus on bringing infrastructure forward as early as possible in supporting the effectiveness of delivery of the settlement.

I am objecting to MM16 LPRSP4(B): Lidsing Garden Village because it is unsound for the following reasons: The proposed transport network relies on Medway Council selling their 'Ransom Strip' and allowing the site to connect onto the North Dane Way. Medway Council have objected to the development and there's no agreement to sell the land. The Main Modifications state that there will be a “contribution towards the creation of a new secondary school capacity in the Capstone Valley Area”. The Capstone Valley is under Medway Council who have not agreed or planned for a new secondary school in the area. There isn’t even a signed Statement of Common Ground between the two councils. 31 HECTARES of natural or semi-natural open space has been REMOVED from the development, yet they still claim there will be a 20% net biodiversity GAIN. To make the plan sound the Lidsing Garden Village should be removed from the plan.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Dear Sirs, I am strongly objecting to this proposed development ,as its unsound, not justified or effective. Medway Council clearly do not want or need or are willing to assist Maidstone Council build (in their back yard ) ,this ridiculous enormous scheme , which is wrong on many levels ,which have been highlighted previously . I understand that no agreement has been drawn up with Medway Council ,who are NOT willing to sell the strip of land to connect onto North Dane way now or in the future , thus making this scheme impossible from the outset. Furthermore , Medway Council have not agreed to or planned a new secondary school in the Capstone Valley area , which will not work with the proposal. There isn't even a signed statement of common ground between the two councils. I also see that 31 hectares of natural or semi natural open space has been removed from the proposed development, yet still claim there will be a 20 % net biodiversity gain. To make the plan sound the Lidsing Garden Village ( proposed development) should be removed from the plan.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

MM16 LPRSP4(B) Lidsing Garden Community Main Modifications  Good afternoon I have read the planning application including modifications and see clearly that there are deep flaws and sensible reasons for objection. Therefore I am objecting to MM16LPRSP4(B): Lidsing Garden community “There will be a contribution towards the creation of a new secondary school in the Capstone Valley area” my objection here is I live in the Capstone Valley area, which is part of Medway council and there have been no such agreements of plans for a new secondary school there. I do not believe there is any signed statement of common ground between Medway and Maidstone councils. There will be 31 Hectares of natural and semi-natural open space removed yet the claim is a 20% biodiversity gain. I would love to see some scientific, objective and non-biased, bought, lobbied or otherwise prejudiced evidence of this Medway council have made plain, multiple times they will not be willing to sell the strip of land to enable the site to be linked to North Dane Way, they have objected to this proposal in fact TO make the plan sound the Lidsing Garden Village should be removed from the plan Regards

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Myself and my partner object to the MM16 , on the grounds that it is ill thought out , the traffic issues caused by the build will be made thousand times worst , rush hour is complete stand still at present , more homes will make it worse , the plan was made out of greed and needs to be shelved for good, it will also create more strain on our over strained NHS with no after thought, along with schools and GPs there are also empty new build homes that remain empty. The natural impact on the area would be disaster to area and nature, with buzzards, and red kites in the area which are protected species. The area needs protecting and turned into a reserve for future generations, it is also a natural run off for rain water.

MM16 LPRSP4(B): Lidsing Garden Community - objection To whom it may concern. MM16 LPRSP4(B): Lidsing Garden Community - objection I don’t need to read the modifications to the Draft Local Plan. That’s simply because no end of modification is actually going to make the development a sound proposal. In terms of its pure geography, road networks are going to be choked, no matter how much you try to widen these arteries. Bredhurst and Boxley in particular don’t offer anything in the way of extra road space to transport thousands of extra people to-and-fro without major disruption. Only last week, the main thoroughfare through Bredhurst was closed off for a few days that caused chaos. Lidsing is NOWHERE NEAR to urban Maidstone and the other areas within the constituency that it can could “local” in terms of infrastructure availability. Schools, jobs, medical facilities, leisure, retail and roads; all of those immediately adjacent to Lidsing, based on the Medway side of the border upon which it sits, will become even more over-subscribed. Lidsing will NOT be self-contained. The new motorway access - it is not a new junction - located on the AONB will require traffic to run straight through the centre of Bredhurst, a village that has ONE main street, and upon which there also sits a school. It won’t be so much a rat run as a mouse trap, with over-congestion and increased pollution to overcome. The latter of which will be increased by a huge lack of green-field areas and trees that go towards soaking it up! 2,000+ houses will equate to 6,000 residents and 3,500 cars added to the count. Look at the density of the local population now and compare to the availability of services that are already struggling. Just because there is a lot of visible green land in the region, it doesn’t NECESSARILY mean that there is room for new residents to be sited, immediately able to integrate into society. Medway Maritime Hospital is on its knees right now. Maidstone Hospital in relation to Lidsing’s location is miles away, and not faring much better in its ability to cope. In terms of public transport, railway stations are CURRENTLY nearly three quarters of an hour away, before you factor in the extra bodies that will me making the journeys. At times when the M2 fails - and there are more than enough times for this to be considered - alternative routes simply clog up. And that includes Lidsing Road/Boxley Road route to the M20 that runs through the heart this new “poster project”. Maidstone uses, Medway loses. Lidsing is an ill-conceived money-grab. Nothing more. If this gets approved, it will be simply down to the fact that people were not allowed to have their say! Regards xxxxxxxxx.

I live at XXX and strongly appose the potential development of over 400 new houses. The roads in and around Loose and Maidstone simply couldn't take another 400+ vehicles on the road. Where are the extra school, Doctors and dentist places for this? Water supply around here is awful with pumping station always dropping so how could it cater for even more? I see this development as simply money making for someone with no thought for those living nearby. Please count my vote against this please.

I am objecting to the main modification concerning the contribution towards the creation of secondary school capacity in the Capstone Valley area -an area which is in Medway Council’s domain. This proposal is unsound and so ill thought-out that I am surprised that the suggestion has even been deemed worthy of consideration. To make the plan a little less unsound the Lidsing Garden Village should be dropped from the plan.

I write today to object to Objecting to MM16 LPRSP4(B): Lidsing Garden Community and the main modifications proposed. I am actually all for new housing. I understand the need and personally, if it enable for new facilities such as transport links, high speed broadband, employment into the area, then great. But it needs to be done in the right areas, with the right infrastructure. The area of Lidsing does not have this infrastructure and I eagerly awaited the main modification proposals to overcome this and sadly, they do not come even close to address the actual problems.   Having read the proposals, I can only assume they have been written by someone who has never been to the area. The first issue relates to the traffic calming issues in Bredhurst and Boxley. Anyone who has been to either village will know there is already substantial traffic calming in place including speed limits, speed bumps and restricted rights of way. The only possible measures left would be to make the villages residents only - anyone who has been to the area will know that is impossible. I personally live on Forge Lane and dread the thought of extra traffic calming down our single lane road never mind all of the vans/HGVs and trucks that will inevitably trash the road. I think it is damning in itself, that the modifications don't go into specifics as to what the traffic calming will be, as they know nothing more can be done and I assume they are playing on the ignorance of the planning inspector.   I understand that there will be 'contribution' towards the creation of a new secondary school in the area. Having seen Medway Councils provisional local plan. I do not see any 'plans' for a new secondary school in the area. In fact, I understand Medway Council are opposed to Lidsing Garden Community. I suspect, like the point above, it will never happen and they are just words on a piece of paper to make everyone believe they have been considered.   The last point, which in my opinion, truly highlights how unsound these modifications are, relate to the proposed cycle lane from Boxley to Lidsing. I stress again, these proposed modifications have been written by someone who has clearly never been to the area. As a keen road cyclist, I avoid Boxley hill at all costs. It is so steep that even most cycling enthusiasts would not be able to cycle up it. The proposal to build a cycle lane is ridiculous and a complete waste of money, as only the most fittest of athletes can actually cycle up it. No one is going to be able to commute using it. Average cyclists won't be able to use it. What is the point in it? The point is to give a tick to a box, to say they have considered the impact on the extra traffic caused by the Lidsing Garden Community. But all it highlights, is that they haven't truly considered it or they know there is no viable. I personally find it insulting that this is felt to be a viable 'proposal'.   These modifications do not address any of the issues and in my opinion, to make the plan sound, the Lidsing Garden Community needs to be removed from the local plan.

I wish to OBJECT to MM16 LPRSP4(B): Lidsing Garden Community because in my opinion this is not sound. Furthermore, it is my opinion that in order to make the Proposed Plan sound, the Lidsing Garden Village proposal should be removed. My reasons include the following: The existing highway and other infrastructure is completely inadequate for the current use/demand. Despite this, no infrastructure or road improvements are planned until 5 years (and 590 houses) after the building works start. This also takes no account of the impact of the construction traffic etc which will inevitably be associated with a development of this scale and nature. It is suggested that ‘cycling and pedestrian facilities’ are to be provided to ‘encourage sustainable modes of transport via Boxley and Bredhurst’. Given the topography and nature of this area, it is difficult to envisage how this could possibly be achieved without the construction of very substantial infrastructure with its resultant disruption, damage to the environment and enormous cost – in addition to that directly caused by the scheme itself. It is proposed that ‘traffic calming’ is provided to discourage the huge increase in traffic through Bredhurst and Boxley which will be generated by the proposed development. Both villages already incorporate significant traffic calming measures to try and mitigate the impact of current traffic on these single track rural roads. In these circumstances, it is very difficult to envisage what further calming could be undertaken on these modest rural roads. It would seem that some 31 hectares of natural or semi-natural open space has been removed from the proposed development, yet it is still claimed this will somehow create a 20% net biodiversity gain. This is surely illogical. To repeat, I wish to OBJECT to MM16 LPRSP4(B): Lidsing Garden Community because in my opinion this is not sound. Furthermore, it is my opinion that in order to make the Proposed Plan sound, the Lidsing Garden Village proposal should be removed.

I wish to object to the above plan.   I believe the plan to be flawed in as much that the proposed roads will be both dangerous (to ALL users) and will require more work than is currently identified. Road width is inadequate and to obtain optimum size there needs to be removal of some of the privately owned space along with the removal of hedge/greenery.   The movement of traffic will not work. Agreement with Medway council will be required to get safe and proper road network. The current costing will not be sufficient for this joint work. I also believe that Medway have also raised their concerns about this. Schools. There is no provision for extra education facilities. This will be a big problem with more pressure being placed on local schools and finding more teachers (who will also need to access the area). Health. An extra 2000+ homes will require more doctors. There is already extreme pressure on our surgeries so this would be the first requirement before any work was thought about. Also more pressure on our hospitals and the NHS.   In short it would create an imbalance to the facilities currently required and to the health and wellbeing of all surrounding residents.   For these reasons the plan should be removed.

I am objecting to MM16 LPRSP49(B) Lidsing Garden Community because this is unsound, not justified or effective or the following reasons. Medway Council have objected to the development and there is no agreement from Medway Council to sell their ransom strip allowing the site to connect to North Dane Way. The proposed transport network for this development relies on Medway Council selling their ransom strip. There is no such agreement. The associated new proposed roadworks will cause destruction to the surrounding rural environment, and the associated increase in traffic will create unwanted noise and unhealthy choking air pollution. The area is already heavily congested particularly at peak times with long traffic queues. Other recent new developments of houses in this area already causing a marked increase in traffic. The modifications state there will be a contribution towards the creation of a new secondary school in the Capstone Valley area. The Capstone Valley comes under Medway Council who have not agreed to or planned for a new secondary school in the area. There is no signed Statement of Common Ground between the two councils. As such the creation of a new secondary school in the area is unsound. 31 hectares of natural or semi-natural open space has been REMOVED from the development, yet they still claim there will be a 20% net biodiversity GAIN . This proposed development will drastically change the rural area causing significant environmental harm. It will rip the heart out of our precious countryside and lay waste to this irreplaceable green belt running through the heart of our community with a colossal loss of green spaces and countryside in an area of outstanding natural beauty, with the destruction of local flora and fauna, the loss of natural habit for native wildlife, and the loss of farmland to grow food. It will have a profound negative impact on traffic, noise and air pollution, the environment and local amenities. Schools are overscribed. The nearest local hospitals at Medway Maritime, Maidstone and Sittingbourne, are already struggling to cope with demand with corridor care because the wards are overflowing. All GPs and dentists in the area are oversubscribed with waiting lists. There is always a shortage of appointments to meet demand. This outline planning would drastically change the face of this rural area. The xxx family presenting this proposed planning with modifications have also submitted separate planning to Medway Council for multiple proposed housing developments in the nearby area. The proposed plan for MM16 LPRSP49(B) Lidsing Garden Community should not be considered in isolation, but alongside separate outline planning to Medway Council for multiple proposed housing developments in the nearby area with the construction of new dwellings with associated roadworks for estate roads, road links, new junctions and realignment of roads. All in all, a heck of a lot of natural rural and farmland decimated - concreted over never to be seen again. A report from CPRE, the countryside charity to protect rural England, states there is enough brownfield land for 1.3 million new homes and over half a million already have planning permission. These figures show there is already enough available and suitable land in the planning system to meet the Government's ambitions to build 300,000 homes per year during the 5-year term of office for this Government, calling into question the need to pass the proposed planning application MM16 LPRSP49(B) Lidsing Garden Community Maidstone has brownfield land, many sites that have previously been built on and now sit derelict or vacant. Land such as this provides a valuable resource in protection of the greenfield site for the proposed development planning application MM16 LPRSP49(B) Lidsing Garden Community which involves the destruction of woodland and rural areas which should, and must be protected and preserved for future generations. I (like countless many others) have enjoyed them as a child with my parents, later with my children, and I now share that pleasure with grandchildren. Capstone Valley has already lost a huge chunk of land to new houses in this area; we cannot afford to lose anymore. Maidstone must adopt a 'brownfield first' approach by targeting brownfield areas to breathe new life into sometimes long forgotten, and derelict areas in the towns and villages within its local authority. This approach will deliver huge benefits building the affordable homes in areas where communities are already established, with access to transport links and the amenities and services they need. I strongly urge MBC to reject the proposed development and modifications for MM16 LPRSP49(B) Lidsing Garden Community and to promote a 'brownfield first' policy and bring forward neglected and often overlooked brownfield sites for development and regeneration, ensuring suitable previously developed or under used land is always prioritised for redevelopment over the much-needed green spaces and ancient countryside we are fortunate and privileged to enjoy within our local community. We are the custodians of the countryside. We should cherish and preserve it. MM16 LPRSP49(B) Lidsing Garden Village should be removed from the plan in order to make the plan sound.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

I am writing to object to the planning submission MM16 LPRSP4(B): Lidsing Garden Community: Main Modifications as they are unsound, unjustified nor are they effective for the following reasons: The Main Modifications refer to a "contribution towards the creation of a new secondary school in the Capstone Valley Area". Medway Council under which Capstone Valley is governed has not agreed or planned for a new secondary school in this area. The claim in the Main Modifications that there will be a net biodiversity gain of 21% following the removal of 31 Hectares of natural and semi-natural open space from the development is clearly absurd. There will of course be a net loss of biodiversity. The proposed transport network is reliant upon the selling of land owned by Medway Council allowing the site to connect to North Dane Way. Medway Council have objected to the development and they have not agreed to sell this land. Lidsing Garden Development should be removed from the plan in order for it to be sound.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

We are writing to comment on the main modifications to the Maidstone Local Plan review with regard to this proposed site allocation. MM75     LPRSA265 Access, Highways and Transportation The policy proposes that: “ vehicular access to the site will be direct from Dean Street and/or via adjacent residential development sites onto Dean Street.  The precise route and construction method of the access route will minimise land-take within the Nature Reserve. Any route must avoid harmful division of the reserve that would undermine its function / coherence .” We are concerned that the wording here is ineffective in guarding against the possibility of a road being constructed through the Walnut Tree Nature Reserve. This is part of Hayle Park Nature Reserve and a significant asset to the landscape and ecology of the area. We would like to see the wording strengthened to ensure that the access road to service the proposed 250 homes at Abbeygate Farm off Straw Mill Hill does not run through the Walnut Tree Meadow Nature Reserve, but instead runs through the adjacent housing development on Burke's Site. Design and layout/Open Space – land to the East of Straw Mill Hill Whilst we welcome the statement that “ there will be no built development east of Straw Mill Hill or south of the public right of way ”, we are concerned about the safety of new residents crossing the already busy Straw Mill Hill in order to reach the space for nature conservation to the East (in green to the extreme right on Diagram LPRSA265). We ask that the Inspector considers including a comment on the necessity of ensuring the safety of pedestrians in this specific area (the junction of Bockingford Lane with Straw Mill Hill/Stockett Lane). We would be grateful if you would consider our comments in response to the main modifications (MM75: LPRSA265) to the Maidstone Local Plan Review.

Please see enclosed Main Modifications Consultation Response (Avison Young, dated November 2023) for full response. (issued via email on 13/11/2023) The submitted response outlines the following key points: - There is a critical need for high quality, large-scale, modern distribution units within the local market. - Based on econometric forecasting, there is a minimum requirement for 12ha of additional employment land in Maidstone and 79ha in the wider sub-region between 2022-2041. - None of the allocated sites put forward provide the full suite of location and building specification requirements to meet the considerable unmet need in Maidstone and across the M20 corridor. -The phasing of delivery envisaged across both of the Garden settlements, and the size limitations of the consented sites at Syngenta Works and Woodcut Farm) means there is no identified supply of land suitable for B8 activity and therefore the clear, immediate, need for such accommodation in the borough cannot be met. -The failure to deliver large scale stock along the M20 corridor is acting as a constraint for growth for Maidstone, and for the wider region. -The development of the Ashford Road site would therefore make a significant contribution to realising the borough’s Economic Development Strategy (EDS, 2023) aim to be the “Business Capital of Kent”. Providing the right facilities for B8 activity would not only support new jobs directly, but also deliver space for businesses that form a key part of wider supply chain and networks, enhancing the ‘ecosystem’ of the borough and supporting wider productivity gains. Ultimately, we consider that the plan is not sound in its current form as it fails to objectively meet the economic needs of the administrative area, as well as to effectively address the economic needs of the wider sub-region. In its present form it is unclear how the need for distribution floorspace has been dealt with through joint working with neighbouring authorities.

Please see enclosed Main Modifications Consultation Response (Avison Young, dated November 2023) for full response. The submitted response outlines the following key points: - There is a critical need for high quality, large-scale, modern distribution units within the local market. - Based on econometric forecasting, there is a minimum requirement for 12ha of additional employment land in Maidstone and 79ha in the wider sub-region between 2022-2041. - None of the allocated sites put forward provide the full suite of location and building specification requirements to meet the considerable unmet need in Maidstone and across the M20 corridor. -The phasing of delivery envisaged across both of the Garden settlements, and the size limitations of the consented sites at Syngenta Works and Woodcut Farm) means there is no identified supply of land suitable for B8 activity and therefore the clear, immediate, need for such accommodation in the borough cannot be met. -The failure to deliver large scale stock along the M20 corridor is acting as a constraint for growth for Maidstone, and for the wider region. -The development of the Ashford Road site would therefore make a significant contribution to realising the borough’s Economic Development Strategy (EDS, 2023) aim to be the “Business Capital of Kent”. Providing the right facilities for B8 activity would not only support new jobs directly, but also deliver space for businesses that form a key part of wider supply chain and networks, enhancing the ‘ecosystem’ of the borough and supporting wider productivity gains. Ultimately, we consider that the plan is not sound in its current form as it fails to objectively meet the economic needs of the administrative area, as well as to effectively address the economic needs of the wider sub-region. In its present form it is unclear how the need for distribution floorspace has been dealt with through joint working with neighbouring authorities.

Please see enclosed Main Modifications Consultation Response (Avison Young, dated November 2023) for full response. The submitted response outlines the following key points: - There is a critical need for high quality, large-scale, modern distribution units within the local market. - Based on econometric forecasting, there is a minimum requirement for 12ha of additional employment land in Maidstone and 79ha in the wider sub-region between 2022-2041. - None of the allocated sites put forward provide the full suite of location and building specification requirements to meet the considerable unmet need in Maidstone and across the M20 corridor. -The phasing of delivery envisaged across both of the Garden settlements, and the size limitations of the consented sites at Syngenta Works and Woodcut Farm) means there is no identified supply of land suitable for B8 activity and therefore the clear, immediate, need for such accommodation in the borough cannot be met. -The failure to deliver large scale stock along the M20 corridor is acting as a constraint for growth for Maidstone, and for the wider region. -The development of the Ashford Road site would therefore make a significant contribution to realising the borough’s Economic Development Strategy (EDS, 2023) aim to be the “Business Capital of Kent”. Providing the right facilities for B8 activity would not only support new jobs directly, but also deliver space for businesses that form a key part of wider supply chain and networks, enhancing the ‘ecosystem’ of the borough and supporting wider productivity gains. Ultimately, we consider that the plan is not sound in its current form as it fails to objectively meet the economic needs of the administrative area, as well as to effectively address the economic needs of the wider sub-region. In its present form it is unclear how the need for distribution floorspace has been dealt with through joint working with neighbouring authorities.

Please see enclosed Main Modifications Consultation Response (Avison Young, dated November 2023) for full response. The submitted response outlines the following key points: - There is a critical need for high quality, large-scale, modern distribution units within the local market. - Based on econometric forecasting, there is a minimum requirement for 12ha of additional employment land in Maidstone and 79ha in the wider sub-region between 2022-2041. - None of the allocated sites put forward provide the full suite of location and building specification requirements to meet the considerable unmet need in Maidstone and across the M20 corridor. -The phasing of delivery envisaged across both of the Garden settlements, and the size limitations of the consented sites at Syngenta Works and Woodcut Farm) means there is no identified supply of land suitable for B8 activity and therefore the clear, immediate, need for such accommodation in the borough cannot be met. -The failure to deliver large scale stock along the M20 corridor is acting as a constraint for growth for Maidstone, and for the wider region. -The development of the Ashford Road site would therefore make a significant contribution to realising the borough’s Economic Development Strategy (EDS, 2023) aim to be the “Business Capital of Kent”. Providing the right facilities for B8 activity would not only support new jobs directly, but also deliver space for businesses that form a key part of wider supply chain and networks, enhancing the ‘ecosystem’ of the borough and supporting wider productivity gains. Ultimately, we consider that the plan is not sound in its current form as it fails to objectively meet the economic needs of the administrative area, as well as to effectively address the economic needs of the wider sub-region. In its present form it is unclear how the need for distribution floorspace has been dealt with through joint working with neighbouring authorities.

I am objecting to MM16 LPRSP4(B): Lidsing Garden Community. My reasons for objection are outlined below.   Removal of 31 Hectares of Open Space I object to MM16 LPRSP4(B): Lidsing Garden Community as I am very concerned about the removal of 31 Hectares of natural / semi natural open space which were originally planned for in the Lidsing Garden Village development. The site is currently natural vegetation in an area of Outstanding Natural Beauty and as referred to in my previous objections contains a number of Red List Species of Conservation Concern. In my opinion it isn't possible to increase net biodiversity by 20% if 2000+ houses and employment facilities are built on the site, which is currently arable farmland with hedgerows and trees. The development plan does not provide any information on how they propose to increase biodiversity by 20%. I have studied Ecology and for the past ten years I have been recording the wildlife of the proposed development, as the site is adjacent to my Chapel Lane allotments which abut the site. I am very concerned about the effects this development will have on the Red List species and other wildlife. To make the Local Plan sound, the Lidsing Garden Village should be removed in its entirety.   Traffic Calming I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for traffic calming to discourage access via Boxley and Bredhurst are unsound and traffic will still take the quickest route available via these villages. There is already a 20 mph speed limit through the villages with speed bumps. In my experience the chevrons are ignored and traffic drives over them and competes for the narrow space with traffic coming over the speed bump in the opposite direction. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety.   Cycle and Pedestrian Facilities I object to MM16 LPRSP4(B): Lidsing Garden Community because the proposed mitigations for the provision of cycle and pedestrian facilities to encourage sustainable modes of transport via Boxley and Bredhurst are unsound and are not justified or effective. The country lanes which connect Lidsing, Bredhurst and Boxley are very narrow, without street lighting or pavements. To encourage pedestrians and cyclists to use these rural lanes would be reckless and dangerous to all users. If there are plans to construct cycle lanes and pavements, this would require compulsary purchase of gardens and farmland, plus the destruction of hedges and woodland, with a deleterious effect on wildlife habits, villagers and farmers. There is no evidence supporting that this is feasible or financially viable. To make the plan sound, the Lidsing Garden Village needs to be removed in its entirety.   Secondary Education Provision I object to MM16 LPRSP4(B): Lidsing Garden Community because the secondary education provision is unsound, as it is not justified or effective. The Main Modifications state that there will be a "contribution towards the creation of a new secondary school capacity in the Capstone Valley Area". Capstone Valley is under Medway's control and they have not agreed or planned for a new secondary school in this area, nor is there a signed Statement of Common Ground between Maidstone and Medway Councils. Therefore to make the Local Plan sound, the Lidsing Garden Village needs to be removed in its entirety.   Phasing and Delivery I object to MM16 LPRSP4(B): Lidsing Garden Community because the delivery of the East - West link road from the development to North Dane Way is unsound, as it is not justified or effective. Medway cancel owns the 'Ramson Strip' between the proposed Lidsing development and North Dane Way and there is no agreement to allow this area to be used for access to the proposed development. Medway Council have objected to the Lidsing Garden Village development and there is no signed Statement of Common Ground between Maidstone and Medway Councils. Therefore to make the Local Plan sound, the Lidsing Garden Village needs to be removed in its entirety.

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

Whoever decided to increase the number clearly doesn't live in this area! The amount of traffic around Maidstone/ loose/ Sutton road/ loose road is already horrendous on a daily basis. The amount of development in and around Maidstone is ridiculous, there is no infrastructure to support the amount of housing. Most of the villages surrounding Maidstone are small, with small country lanes. As soon as one of the main roads is closed which is a lot, the lanes are clogged and in moveable! Why anyone would think that road could support any new houses is beyond me. You won't be able to move in Maidstone soon! Far too many backhanders being given as nobody with half a brain cell would think more houses, cars, pollution would be a good idea for that road/ area. 

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. We do not consider that any revisions to the Main Modification are necessary to make the plan sound and/or legally compliant.

Dear Sirs   I write regarding the above development.   The proposed transport network relies on Medway Council selling their 'Ransom Strip' and allowing the site to connect onto the North Dane Way. Medway Council have objected to the development and there's no agreement to sell the land.   The Main Modifications state that there will be a “contribution towards the creation of a new secondary school capacity in the Capstone Valley Area”. The Capstone Valley is under Medway Council who have not agreed or planned for a new secondary school in the area. There isn’t even a signed Statement of Common Ground between the two councils.   31 HECTARES of natural or semi-natural open space has been REMOVED from the development, yet the current plan still claim there will be a 20% net biodiversity GAIN.   To make the plan sound the Lidsing Garden Village should be removed from the plan. I would ask that the council do everything in their power to stop the destruction of our open spaces.   Kind regards, Emma Davis (...)

We note these comments, however these issues were discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. The Council do acknowledge the lack of clarity with regards to the proposed removal of 31ha and would like to propose some amended wording to rectify this below: natural/semi natural open space will be delivered as per parts 1(a) phase 2, 3 (g) & (j) and in accordance with the framework diagram, with further detail supplied in the subsequent SPD. To clarify the above part 3 of the policy will also be amended to read: Development will be based on the Masterplan vision framework diagram plan . Plus, a caption will be added to the framework diagram stating what it is.

I am against this modification to the local plan. The traffic heading into town from anywhere south of Maidstone is horrendous. The extra traffic that will come from packing in even more houses into this greenfield site will be unacceptable without a large overhaul to Maidstone’s infrastructure.

We note this comment, however this was discussed in detail during the examination hearing sessions and the reasons for the modification are summarised in the Main Modifications consultation document. We do not consider that any revisions to the Main Modification are necessary to make the plan sound and/or legally compliant.

This Main Modification adds a further paragraph to provide clarification in relation to criterion 3 of Policy LPRSP11(A). The additional text states: “*For those EDAs listed under part 1 of Table 11.1, the term ‘business uses’ includes Use Classes E(g), B2 and B8. For those EDAs listed under part 2 of Table 11.1, the term ‘business uses’ includes Use Classes E(g). At Eclipse Park EDA only, this definition may also include other uses falling under E Use Class.” Eclipse Park is listed under part 2 of Table 11.1. As a result, the effect of the proposed Main Modification upon Eclipse Park is therefore to allow proposals for the redevelopment of premises and the infilling of vacant sites for business uses, which are defined as including Use Class E(g) and other uses falling under Use Class E. Gallagher Properties’ Response Gallagher Properties Ltd SUPPORTS the widening of the Use Classes specifically referenced as being appropriate at Eclipse Park as a result of MM44. Gallagher has argued throughout the Local Plan Review process that the previous definition was unnecessarily restrictive. In that context, we welcome the Council’s agreement that the uses should indeed be more flexible than just offices in this location. However, whilst that is the case, Gallagher continues to consider that the definition as amended should be widened further, as it has argued throughout. In that context, Gallagher OBJECTS to the Main Modification on the basis that the wording should be extended further to allow a wider range of uses. Without the additional wording, the policy is not as effective as it could be. Need for flexibility We have set out in our previous representations at the Regulation 18 and 19 stages, and in response to the Inspector’s MIQs in relation to Matters 2 and 5, that there is a need for flexibility to enable the last remaining development plot at Eclipse Park to be built out. We will not repeat those arguments in full, but we set out in detail the reasons why restricting uses to office uses only was unacceptable due to a total lack of market interest in office uses on the site in the last 15 years or so. We set out the case for why the policy should allow office uses, but to also be flexible enough to allow other employment-generating uses to come forward in the meantime. Other potential uses The proposed Main Modification would allow the last remaining development parcel at Eclipse Park to be brought forward for a range of other Class E uses, which we agree increases the flexibility. However, there are other employment uses which may also be acceptable. In particular we see no reason why small-scale B8 logistics and warehousing uses should be excluded from the list of acceptable uses in this location, especially in the context that the policy, as proposed to be modified, allows light industrial uses. Whilst we would accept that a large-scale warehouse may not be appropriate here, it should be noted that the only remaining plot is not big enough to accommodate a use of that nature. Furthermore, the site would be unlikely to attract such a use which would always be more appropriately accommodated on a site like Woodcut Farm, which is purpose-designed for that type of operation. Indeed, our clients have had discussions with such operators which support the view that they would not consider Eclipse Park suitable for large-scale B8. There is however market demand for smaller scale B8 uses, for example selfstorage units. Indeed, a planning application has been submitted on part of the Eclipse Park site for exactly such a use, as part of a wider masterplanned scheme including other uses falling within Use Class E. As set out in the supporting Planning Statement to that application, a small-scale B8 self-storage use would help to meet a local need for self-storage facilities and would create further jobs on the site. Self-storage uses are low-impact small-scale B8 uses which generate relatively little traffic and help to meet the needs of local people. Such uses are most appropriately located on industrial estates, due to the requirements of the buildings, and this is considered to be an acceptable location for such a use. Customers tend to fall mostly into one of two categories: (a) local residents looking to store items that are not required in the short term and for which they have insufficient storage space in their homes. It is appropriate that such a use is located close to housing estates to allow people to collect and drop off items without having to travel unnecessarily; and (b) local businesses requiring storage space which is easily accessible from their existing operations. The Eclipse Park site is close to M20 Junction 7 and so would further allow opportunities for trips to and from the storage facility to be made in conjunction with other trips whilst already on the road network. We have also received pre-application advice from Maidstone Borough Council which confirmed that a B8 self-storage use could be considered acceptable on the site as part of a wider mix. Summary In this context, it is clear that there is no good reason why the policy wording should not be extended to also allow small-scale B8 uses in addition to the wider range of uses falling within Use Class E. Proposed alternative wording for MM44 Taking the above into account, we would propose the following revised wording for MM44:  “*For those EDAs listed under part 1 of Table 11.1, the term ‘business uses’ includes Use Classes E(g), B2 and B8. For those EDAs listed under part 2 of Table 11.1, the term ‘business uses’ includes Use Classes E(g). At Eclipse Park EDA only, this definition may also include other uses falling under E Use Class as well as small-scale uses falling within Use Class B8.” If this additional wording was added, we would be in a position to withdraw our objection and fully support the proposed Main Modification.