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LPC Reg 19 response

Maidstone Borough Council - local plan review

The formal consultation for Maidstone Borough Council’s review of the Local Plan closed on 12 December 2021 and MBC is now "reviewing" the responses. We will post a notice here when these are published                                        

The response from SOHL can be seen at: 

The response from CPRE Kent can be seen at:

As of October the cost of the Heathlands proposal, that has been publicly declared, is £631,496.00 up from a disclosed figure in July of this year which was £564,000 - this is public money, our council tax which is being speculated. 

In spite of the Local Plan Review process, the Lenham Neighbourhood Plan remains in force and contains a policy which defends against development in the open countryside outside of the agreed "development envelope" set out within the Neighbourhood Plan, this remains in force until 2031. MBC planners have already used this policy to reject some planning applications.

If Maidstone decides to put forward the version of the Local Development Plan for inspection in the form set out in this consultation we expect this to be considered by an Independent Examiner around the end of 2022 – beginning of 2023.

Until then the parish council will continue to gather relevant information and opinions from specialist advisers in readiness for the public examination. More about that nearer the time.

You can view the refreshed "Heathlands masterplan" for the development proposal at Lenham Heath here

We continue to wonder what promises are being made to the principle landowners and how Maidstone envisages these can be kept, given the lengthy timescales involved, for without the land being available the scheme would not be viable at all.

Lenham Parish Council is making public the responses it has submitted to Maidstone Borough Council’s public consultation on the Regulation 19 Local Plan Review 2022 - 2037. Lenham Parish Council would like to thank everyone involved in the effort to derail the Heathlands proposal, this includes our planning consultant who did the bulk of the work for which we are very grateful, Paul McCreery, the Barrister working on our behalf at Knight's Solicitors, Simon Bell and the Queens Counsel from Landmark Chambers, John Litton QC as well as James Neill from Landmark Chambers all of whom managed to deliver a significant amount of detailed work in what was a very short time-frame. We have also had significant support from our County and Borough Councillors, Shellina Prendergast at KCC and Tom and Janetta Sams at MBC, we have all worked tirelessly together to highlight the flaws in the plan to include the "Heathlands" proposal and will continue to collaborate.

All the responses were sent by both email and hand-delivered hard copy to Maidstone Borough Council on Friday 10 December, ahead of the 12 December deadline.

If you wish to see the response to the earlier Regulation 18b consultation (December 2020) that can be seen here.

The parish council took the decision to submit a number of separate responses to different aspects of the review of the Local Plan, this has been done to spread the impact of our findings to a wider arena than just our objection the proposal to create “Heathlands”, which clearly is at the core of everything.

The issues we found unsound include:

  • the Heathlands proposal – the parish council submitted a detailed opposition
  • the lack of proper (or any) consultation or engagement
  • issues relating to infrastructure – specifically the M20 upgrade required at J8 and the reappearance of the new M20 junction to serve the proposed housing estate
  • the “assumption”, repeated several times, that there “will be a new station” when there is absolutely no evidence in the plan that this is the case
  • how housing need has been calculated and the inconsistent figures within the document and its appendices, especially in terms of dealing with “windfall” developments
  • the work which was required from the previous review in 2017 where the Inspector instructed MBC to work up the proposals at Leeds / Langley which remain unresolved
  • concern at the conclusions within the plan about new employment, especially at it relates to Heathlands
  • the clear political bias within the decisions drawn from the strategic assessment
  • the discrepancies around the potential development densities for the Invicta Barracks site

These representations include the Legal Submission provided by Landmark Chambers on the Strategic Assessment, the document which MBC will be relying on to justify the decision to press ahead with the so-called Garden Community at Lenham Heath.

The parish council has also been sharing all intelligence with SOHL as well as CPRE Kent and neighbouring parishes, we will all continue to work together as we move towards the public enquiry.

The following documents contain the complete response from the Parish Council to the Review of the Maidstone Local Plan 2022 - 2037.

These are the documents the parish council lodged as its response to the review including the Legal Submission from Landmark Chambers

Legal Submission File Uploaded: 12 December 2021 197.6 KB List of Responses File Uploaded: 13 December 2021 10.5 KB LPC 1 - Deficiencies in the Spatial Strategy File Uploaded: 13 December 2021 191.8 KB LPC 2 - Discrepancies in the Plan Period File Uploaded: 13 December 2021 11.7 KB LPC 3 - Different housing densities proposed at Invicta Barracks File Uploaded: 13 December 2021 116.2 KB LPC 4 - Marden - Reasonable Alternative Development Location File Uploaded: 13 December 2021 148 KB LPC 5 - Residential Windfall Allowance File Uploaded: 13 December 2021 123.6 KB LPC 6 - Leeds Langley - Reasonable Alternative Development Location File Uploaded: 13 December 2021 158 KB LPC 7 - Housing Delivery File Uploaded: 13 December 2021 117.4 KB LPC 8 - Employment Delivery File Uploaded: 13 December 2021 180.1 KB LPC 9 - Lack of Attention to Alternative Sites File Uploaded: 13 December 2021 203.3 KB LPC 10 - Wastewater Treatment - Concerns over the existing and the proposed File Uploaded: 13 December 2021 132.3 KB LPC 11 - Lack of detail regarding the cumulative impact on J8 of M20 File Uploaded: 13 December 2021 164.9 KB LPC 12 - New M20 Junction File Uploaded: 13 December 2021 15.4 KB LPC 13 - Assumptions made over housing land supply File Uploaded: 13 December 2021 33.5 KB LPC 14 - Objection to Policy Drafting File Uploaded: 13 December 2021 134.6 KB LPC 15 - Viability File Uploaded: 13 December 2021 128.1 KB LPC 16 - Lack of Community Engagement File Uploaded: 13 December 2021 133.4 KB LPC 17 - Lack of Flexibility File Uploaded: 13 December 2021 131.4 KB LPC 18 - Case Study from Uttlesford Local Plan which was found unsound File Uploaded: 13 December 2021 265.8 KB