Heathlands Garden Community, Lenham Heath:

Unsustainable, undeliverable and unviable

Contents

3 Introduction 14 Unviable 4 Location 15 Viability Assessment 5 Policy Context

6 Unsustainable 16 In Summary 7 Employment & Economic Need 17 Community Engagement 8 Biodiversity & Environment 18 Garden Community principles 9 Water 19 What your experts say

10 Undeliverable 11 Transport 13 Land Ownership & Assembly

Introduction Lenham is not the right place for a garden community

Save Our Heath Lands (SOHL) is an Our findings are conclusive. The independent volunteer-led campaign council-led Heathlands development is group made up of concerned residents unsustainable, undeliverable and of Lenham and the surrounding unviable. villages, under threat by Maidstone This document sets out evidence- Borough Council (MBC)’s Garden based, factual information that must Community proposal to build a new be considered by MBC’s planners and town of over 5,000 homes on those politicians responsible for beautiful, green heath lands at the making strategic planning decisions. foot of the Kent Downs Area of Outstanding Natural Beauty. MBC’s role as scheme promoter has created significant mistrust in the Our work over the last twelve months community it seeks to serve. since MBC announced their intentions to investigate Lenham Heath as a It is time for our local council to start prospective development site has listening to local residents. explored the constraints and opportunities of this location.

Location

Lenham’s rural setting and distance from existing major settlements makes it an unsuitable location for new major development.

Lenham is located at the centre crossed east-west by the A20, of Kent, the heart of the garden the M20, the Kent mainline of England. railway and the High Speed 1 line which run approximately The parish largely comprises parallel to, and south of, the high quality rural landscape, Kent Downs AONB. being roughly equidistant Our work over the last twelve months since MBC announced their intentions to between Faversham, Ashford, The area to the north of the A20 investigate Lenham Heath as a prospective development site has explored the Headcorn and Maidstone, forms part of the Kent Downs constraints and opportunities of this location. approximately 15km from each AONB, while the area of these locations. immediately south of the A20, to the east of Lenham village, Lenham is the source of two of provides the setting of the the county’s most important AONB and is a very attractive rivers; the Stour and the Len. area of open countryside. Lenham village has the only The area to the south of the working medieval village square mainline railway, to the east of in Kent, which has remained Lenham village, lies in an area of without significant change to more intricate but still very the enclosing buildings since the attractive scenery, including 16th century. areas of woodland, agricultural Lenham has historically fields and the hamlets of benefited from east-west routes Lenham Heath, Sandway and including from London to the Platts Heath. continent and the Pilgrims Way Lenham Heath is where (North Downs Way). Maidstone Council propose This pattern continues to this siting the Heathlands Garden day, and the Parish is now Community.

Policy Context

The Heathlands Garden Community proposal is not in conformity with national, borough or local neighbourhood policy. It will place new residential development in an isolated location with heavy reliance on the private car and with insufficient mixed use to reduce the need to travel.

Lenham Neighbourhood Plan National Planning Policy Maidstone Local Plan (MLP) (LNP) Framework (NPPF)

The NPPF is focused upon achieving The Maidstone Local Plan recognises The Neighbourhood Plan demonstrates sustainable development and promoting Lenham as a Rural Service Centre. how the Parish can deliver a notable travel by sustainable modes. amount of development with supporting The 2017 Local Plan focused new infrastructure while at the same time The NPPF sets out a range of objectives for development ‘principally within the protecting the countryside, by ensuring achieving sustainable development including Maidstone urban area and at the strategic growth is in appropriate locations. the potential impact on the transport network development locations at the edge of town and opportunities for sustainable travel. . It and to a lesser extent at the five rural service In particular, the LNP makes provision of also states in paragraph 17 and 21 that new centres of Harrietsham, Headcorn, Lenham, Policy CP1 (Countryside Protection). This developments must: Marden and Staplehurst consistent with their states that “development proposals should range of services and role.’ seek to protect the rural environment of the “actively manage patterns of growth to make Parish, such that there are no adverse the fullest possible use of public transport, Lenham has an allocation of approximately impacts upon the character of the walking and cycling , and focus significant 1,000 new homes in the current plan period countryside. Proposals which fail to development on locations which can be made which along with the 364 new units already demonstrate that any such impacts can be sustainable.” and “set out a clear economic committed nearly doubles the size of the mitigated will not be supported.” vision and strategy for the area which village. No other rural service centre has positively and proactively encourages committed such relative growth. The Heathlands proposition is beyond the sustainable economic growth.”. Lenham parish settlement boundary and The Heathlands proposition would swell the consumes the hamlet of Lenham Heath, one Selecting Heathlands as a future parish to nearly seven times the existing of which this specific policy seeks to protect. development site as part of the emerging number of households. This is clearly review of the Maidstone Local Plan would be unacceptable and a divergence from existing Heathlands is not policy compliant at a deliberately selecting a pattern of borough policy, even with Lenham as an neighbourhood planning level. development and land use which is heavily identified broad area of growth. unsustainable.

Employment & Economic Need

Unsustainable

Lenham is an inherently unsustainable location

Employment & Economic Need

There is no evidence to support the proposition that the market would be able to provide close to 5,000 jobs, or indeed any significant employment, at such an isolated location. Lenham Heath is not the right location for a sustainable employment settlement.

Heathlands’ promoter currently Such few jobs will lead to the The Council’s Sustainability system and the promoter is yet propose around 850 new jobs true vision and purpose of a Appraisal notes that the to make any case as to how the for the site. This is made up of garden community not to be strategic location to the scheme could cope with the 420 jobs in the B1c/B2 and B8 realised. Government guidance motorway network of residential motor car trips before use classes, a further 230 non-B requires garden communities to Heathlands and Lenham Heath even considering heavy good class jobs and provision in the facilitate residents living, could make it a suitable site for vehicle movements on an form of managed workspace working and playing in the warehouse/distribution however existing unsuitable road that will provide space for 200 development to reduce external this would go against the network. workers, providing space for the trips. principles of creating a low self-employed, those spending carbon integrated transport Even if thousands of jobs could some time working from home. be provided at Heathlands the Arguably the development is majority of those are likely to be only proposing to create 650 low-wage positions. This would jobs. This is well below the require workers travelling long TCPA guide of 1:1 jobs to distances, mainly by private houses ratio. motor car, from their homes in Maidstone, the Medway towns, For the aspirations set out in the Ashford or further afield to masterplan to be realised, reach employment at considerably more employment Heathlands. Meanwhile, would need to be delivered. residents of Heathlands, Recent research found that inevitably in higher earning garden communities on average brackets and able to afford the deliver 35m2 of employment “executive homes” that would space per dwelling2. For no doubt feature heavily, would Heathlands, this would equate be travelling away from the area to 35 acres of space required to higher paid employment. This compared to the current would create a dormitory town. proposed 27 acres.

Biodiversity & Environment

The rural setting and rich biodiversity at the foot of the Kent Downs AONB are to be robustly protected. The use of over 700 acres of predominantly green space is not an acceptable location for a new settlement like

Heathlands. The loss of biodiversity, farming land, and wildlife is intellectually and morally bankrupt.

The proposed site for The Sustainability Appraisal Heathlands garden community is therefore determines extremely complex from a Heathlands as performing landscape, ecology, and least well of all garden biodiversity perspective. community proposals across the range of sustainability Parts of the site have high objectives. landscape sensitivity with other parts benefiting from rich arable A significant area on the farming (grade 3 and above). western half of the proposed scheme will be visible from the A number of designations for AONB and that the topography areas within the proposed site and natural vegetation will be are omitted from the Council’s unable to mask the full extent of own designations map and the scheme. The eastern part of include parts of the National the scheme has a restricted view Habitat Network and and its impact on the AONB Countryside Stewardship from a visual perspective is at Agreement Management Areas this stage less. as well as ancient protected woodland. The site is also home to a number of native wildlife The Council’s own Sustainability including the verified presence Appraisal of Spatial Options of slow worm, common lizard highlights the considerable and bats which would be concern on sustainability contrary to Planning Policy grounds of the Heathlands Statement 9: Biodiversity and proposal not least it’s locality to Geological Conservation. the Area of Outstanding Natural Beauty (AONB).

Water

Water is one of the most significant constraints for this site. This includes the protection of the River Stour which is under protection order for nutrient neutrality as well as the siting of the Lenham Water

Treatment Works which is at the centre of the proposed development and not planned to be relocated.

The water environment within demonstrate how they will The masterplan makes little We would expect the Heathlands the Stour catchment, which the ensure nutrient neutrality and provision for the "cordon development to meet this Heathland site entirely falls remove or offset the impact of sanitaire" policy water companies requirement which would result within is one of the most new development. comply with. in a considerable acreage of what important for water dependant is now presumed to be building wildlife in the UK. The promoter is currently The recommended buffer zone land having to be set aside. This reviewing what intervention is between a wastewater treatment reduces the viability and Natural England have raised required and a report is site and any housing is 400 deliverability of the scheme, concern with the potential expected ‘imminently’. Whatever metres. At present, all waste- particularly the second and third impact new growth is having on mitigation is proposed, it is water treatment sites in Kent build phases. further deterioration of the going to be at considerable cost conform to this requirement. designated sites. This and not factored into the uncertainty is one reason that existing precarious financial the wastewater treatment works, appraisal. such as the one at Lenham, discharging into the River Stour Sewage Treatment Works and surrounds are subject to an Heathlands has a Sewage investigation of their impacts Treatment Works (STW) located and connection with Stodmarsh within a substantial part of the designated sites under the proposed site. There is little Environment Agency Water detail in the promoters’ Industry National Environment submissions which explains how Programme (WINEP) that will they intend to mitigate the report in 2022. risks/issues associated with the proximity of the STW with the This causes potentially a planned residential dwellings significant constraint on the and other uses associated with Heathlands site and the the proposed housing area. promoter is required to

Undeliverable Undeliverable Significant constraints make Heathlands an undeliverable

proposition

Transport

SOHL commissioned an independent transport assessment of the Heathlands proposal. It concludes that the development is undeliverable as the removal of the motorway access results in a significant and unacceptable increase in local traffic impact which cannot be mitigated by sustainable travel alternatives.

The first masterplan for key centres of Maidstone, Ashford In the absence of a new motorway Heathlands promised a new and Canterbury. junction the traffic impacts of the 15km motorway junction at Lenham development on the A20 corridor of carriageway requiring Heath as well as a connection to Information submitted thus far for and surrounding rural lanes would dualling to cope with traffic the High Speed Rail line with a Heathlands has lacked any be severe and appropriate generated by Heathlands new station. indication of anticipated traffic mitigation such as dualling the A20 generation. Our consultants have is considered to be undeliverable The second stage masterplan assumed a conservative estimated and financially unviable. indicates that the above proposed peak trip generation for the infrastructure improvements are no development. This concludes two- New rail station 2,400 longer being considered as part of way traffic flows in excess of The second stage masterplan refers number of additional car trips the development. This significantly 3,400-3,600 vehicles from the to a ‘potential’ new rail station generated by Heathlands impacts the deliverability potential development on the A20 during within the proposed development. in the morning rush hour of the project. the highway peak hours without No engagement has taken place accounting for existing planned with the promoter and Network Despite numerous requests, MBC residential growth in Lenham and Rail with regard to feasibility and have failed to make available the more modest growth in other deliverability. 17 years full Transport Assessment that has villages along the corridor it took for M20 Junction 10a been produced for Heathlands. For including Harrietsham and Charing. It is not evident that a new station to go from submission to government to this reason, SOHL has chosen to would be acceptable given the being built and completed at a cost of £105m commission independent To put this level of traffic into proximity to existing stations at consultants to undertake an context, the theoretical maximum Lenham and Charing and if so objective assessment with publicly capacity of the A20 corridor is would potentially act as a 70 minutes available information. between 2,400 and 3,000 vehicles replacement to these existing and two-way. Traffic flows in the order important facilities which serve time it would take to cycle from Heathlands to Highways impact of those conservatively estimated existing communities. The A20 Ashford Road is the main above could simply not be Maidstone Town Centre connector for local traffic between accommodated on the A20. Stantec’s assessment states that a dedicated rail station would be fundamental to the development villages would rely on public and that this should be in place transport or private car use. from the outset to encourage and ingrain sustainable travel behaviour. The masterplan proposes a This would require a new station to potential bus rapid transit (BRT) be in place by 2030. Based on scheme between Maidstone & previous recent examples of new Ashford as well as enhanced feeder stations on the national rail electric bus services to surrounding network, at least a 15 year delivery rural areas. It is unlikely that the timetable is more realistic. MBC are Maidstone to Ashford BRT scheme yet to speak to Network Rail to find would generate a satisfactory out if a new station is deliverable. transport business case given it would replicate an existing rail line. Sustainable Travel Strategy The Heathlands Masterplan sets out Internalisation an ambitious strategy for walking, The limited employment cycling and public transport use. opportunities created in the These forms of travel are limited by proposal site along with the the distance the development would absence of secondary/higher be from key employment centres education facilities reduces the and services. ability to maximise internalisation potential for walking, cycling and Walking and cycling would, for the public transport trips. This results majority of residents, not be a in the continuing dominance of the suitable mode of travel for trips private car to reach services other than those within the outside of the development and development and to local centres limits any potential sustainable namely Lenham and Charing. transport strategy. Destinations beyond these

The site is located in an inherently unsustainable location with regards to access to necessary employment, goods, services, and sustainable modes of transport. The proposed sustainable transport strategy is considered inadequate to overcome these deficiencies.

Land Ownership & Assembly

Heathlands has the most complicated land ownership arrangements of any other proposed garden community nationally. Principal landowners have not agreed any terms and the volume of small landowners will make it almost impossible to assemble phases 1 and 2 without compulsory purchase.

The proposed site’s current landownership is Existing Sewage Proposed Phase 1 extreme complex. Treatment Works 1600 homes by 2037

(to be retained according to • 3 principal landowners Eight principal landowners have been in promoter) • Over 20 small landowners discussion with MBC for some time although • Includes Lenham Heath progress of an agreement has stalled in the last quarry currently being 12 months. No principal landowner has signed restored but not to heads of terms at this stage. development standards

Whilst the principal landowners do own a significant proportion of the overall site, there are a large number of small landowners, particularly in phase 1, which are vital to unlock the site’s opportunity for development.

The vast majority of the 30+ small landowners are not in support of the scheme. Small landowners shaded in orange on the map to the right have requested removal of their landholdings from the masterplan with immediate effect. Proposed Phase 3 Proposed Phase 2 Assembling such a multitude of ownerships and 1,500 beyond 2050 1,000 homes beyond 2037 land types is an insurmountable task in SOHL’s • Known as western parcel • 3 principal landowners opinion and also affects the viability of the • 1 principal landowner • Over 12 small landowners scheme. • Sewage Treatment Works • 1 major landowner (blue)

at the centre of phase. is land with The site also has the M20 motorway to the • Mineral safeguarded site archaeological south as well as the High Speed Rail line running for soft sand. Extraction significance parallel. Each provide significant severance issues expected to last until at • 1 major landowner is and construction constraints. least 2050. south of M20 and

Unviable

“The greatest risk of Heathlands is the marginal viability” – Stantec

Viability Assessment

Heathlands is unviable. The proposal is wildly ambitious in its expectations and fails to acknowledge fully the challenges of the development and the inevitable financial costs. The estimated costs versus the likely revenue from the proposal quickly turns it into a loss-making scenario with insufficient risk accounted for.

We have asked for greater Land values No cost has been accounted for Development quantum transparency from the promoter Land around in the Maidstone in order to upgrade or relocate The promoter currently assumes on its financial appraisal of the area already has significant the Water Treatment Works 5,000 homes are built and sold project but regrettably to no “hope” value for residential use, which is inevitable. by 2042. Factoring in a number avail despite the project being which would yield values of of constraints such as the funded by the taxpayer. £500k-£1,000,000. Principal Risk/Contingency required buffer zone for the

landowners will accept a Contingency of 5% is assumed Water Treatment Works and the In the absence of a project discount for the certainty of a for the project with no material loss of a large proportion of financial appraisal, SOHL have clear route through the planning contingencies in individual development land in phase 1 built their own financial model system: but if they get too little items. from landowners who do not for the scheme using publicly they have the option of waiting wish to sell their land, the available information along with for the next opportunity. It is public sector best practice number of homes is anticipated estimates and assumptions for early stage projects to to significantly reduce. typically used in the industry. £140,000 per acre is the require big contingencies which maximum the promoter is able should reduce as project We estimate the removal of land The promoter has publicised an to offer on land purchase definition increases. In this in phase 1 would result in the ambitious build and sale however this is assuming the full instance, the HM Treasury loss of 990 houses which would programme. They assume a 15 cost of the infrastructure Green Book recommends 40% equate to c£255m in sales and year build period starting in required has been factored in. contingency and this is qualified which when compared to the 2027 and with the final house We believe this has been grossly by major infrastructure total scheme revenue of £1,1bn sale in 2042. This is wildly underestimated. providers. is equivalent to a loss of 23%. optimistic given the biggest parcel of land (the western Infrastructure Costs Making the sensible assumption Our overall assessment confirms parcel in phase 3) will not For transport, costs for on risk/contingency would make an overall loss on the proposal if become available until all significant infrastructure the Heathlands proposition a realistic appraisal is completed minerals have been extracted, improvements have not been completely unviable. Council with suitable infrastructure costs estimated to be in he 2050s. accounted for. The cost of a officers have therefore chosen for the investment required to new railway station at c£12m is to keep contingency low to make Heathlands a garden conservative given more recent provide the most optimistic of village. built examples nationally. business cases.

In summary

Heathlands is not

the solution

Community Engagement

The Lenham community have rallied against such an audacious assault on their village. They do not and will not ever support Heathlands.

Genuine consultation is at the core Initial answers from the Council’s of the NPPF, which is intended to leadership. allow “people and communities back into planning.” Helen Whately MP has been outspoken against the A key requirement of the development saying it is too big Government’s garden communities and in the wrong place. Her survey initiative is that proposals are of over 1,000 residents in her locally supported and locally led, constituency concluded with 96% and the Council has failed to against the garden village. engage with the local community on this proposal right from the Heathlands is not supported by beginning. the local community.

The Council have made no attempt to meaningfully engage with the local community. In fact, it is SOHL’s view that they have 4,500 actively attempted to avoid any people signed our petition engagement until the site has been calling for a re-think on secured in the Council’s emerging garden communities Spatial Strategy where it will be harder to argue against it. 96% The opposition in Lenham and of 1,091 respondents said surrounding villages is strong. Over 300 people turned up to a that Lenham Heath was community event in January the wrong place to build organised by SOHL to get some 5,000 new homes

Garden Community Principles

The Government is clear that new Garden Communities should not be about creating dormitory towns, or places which just use ‘garden’ as a convenient label. This is exactly what is proposed in Heathlands. Away from major urban centres with an insufficient mix of land uses to ensure people can live, work, and play in the development. Heathlands does not meet garden city principles, a requirement of new communities.

The ‘Garden City principles’ MBC have failed to engage with the affected community Land value capture is proposed to fund the development’s are a framework for good infrastructure costs. However many landowners within the in any form to date. place-making and the site do not want to sell their land and are at threat of The Masterplan has changed twice in 12 months and has lost key visionary components like the High Speed rail delivery of high-quality compulsory purchase. This approach to land assembly and value capture is far from beneficial to the local community station in this time. places which provide good outcomes for people and Ambitious claims made in the the environment and are Due to its isolated location, Heathlands masterplan for white-elephant will be a car-dominated development. initiatives like a community garden underpinned by a financial Proposals for a new rail station in the centre and every resident gifted a model that pays for these centre go some way to encourage tree. Little substance on longevity. positive outcomes in the sustainable travel but will only be suitable for trips to Maidstone, Ashford. The masterplan commits long term. These principles to 40% affordable homes. are advocated by central Internal movements may be made by walking, cycling and bus but unlikely for However, the financial Government as anything outside of the development. viability of the scheme requirements for new hangs on a thread. The garden communities and assumed market value Walkable neighbourhoods are ranges for properties are supported by MBC in unable to be created without between £150,000 and their New Garden local jobs, services and £395,000 are likely to Communities Prospectus. shopping facilities. The require inflating to cover masterplan makes insufficient the project’s costs. Our assessment of the provision for jobs, leisure and shopping to maximise internal Insufficient mix of land uses proposed Heathlands movements. Cultural elements including employment means that development against these weak with the Water Treatment very few jobs will be within easy Works a major disruptor of the principles is presented and sustainable commuting distance. public realm in phase 3 shows weakness in many of Travel to work will rely on the car the key principles. for many with Heathlands becoming a dormitory town. The loss of hundreds of acres of existing green field and open space along with native wildlife, hedgerows and habitats, there is little opportunity to enhance the natural Significantly high housing densities typically found in town centres and around transport hubs are proposed for environment. Instead, MBC are proposing to ‘offset’ the impact by proposing a new country park on the other side of Heathlands resulting in high-rise apartment blocks with no the motorway away from the proposed new development. private gardens.

What your experts say

Maidstone Borough Council commissioned a garden community assessment as well as a Sustainability Appraisal of the Local Plan Spatial Strategy options. Both expert opinions raise considerable concern with the deliverability and suitability of Heathlands and confirm that it performed least well against objectives.

Stantec Garden Communities Assessment Sustainability Appraisal (SA) Options for Spatial Strategy, Site Allocations & Garden Settlements Paragraph 7.5.8: The greatest risk for this scheme is the marginal Paragraph 8.9: The SA found that the garden settlement option that viability due to unknown costs and significant abnormals, this will performed most strongly in sustainability terms was Lidsing, followed by North need to be properly monitored and actively managed if it was taken of Marden; Heathlands performed least well across the range of forward. sustainability objectives.

Paragraph 4.3.2: The 850 job total is below the TCPA guide 1:1 jobs to Paragraph 4.58: Heathlands […] could take a long time to deliver, which houses ratio and represents a lost opportunity to make a much means that additional sustainable transport infrastructure would not be larger contribution to the Council’s employment land needs. provided for in the early years of the plan period. Furthermore, research of practical experience elsewhere85 has concluded that garden settlements can Paragraph 4.4.8: It is more than certain that without the [new rail] become car dependent and create more traffic on local roads. station, offsite vehicle impacts could be double those outlined by RSK, and that would lead to car reliance and ingrained unsustainable travel Paragraph 4.67: Heathlands would have a negative effect on the ‘conserve patterns, contrary to the Garden Communities Prospectus and government borough mineral reserves’ objective as the location is located within a Mineral guidance. Even in a best case some 1,000 trips in each direction on the Safeguarding Area and also contains a safeguarded mineral and waste site. A20 to Ashford and Maidstone would lead to significant traffic problems and impacts. Paragraph 4.74: Heathlands location lies within Grade 3 agricultural land […] there is the potential for new development to harm the Borough’s best and Paragraph 7.2.14: For the purposes of the draft plan we would suggest most versatile soils in both locations. that the Council caveats the deliverability of the current masterplan proposal on the successful delivery of the station. Paragraph 4.108: The Heathlands garden settlement location overlaps several Local Wildlife Sites and areas of Ancient Woodland. Therefore, significant Paragraph 4.6.10: There are still a considerable number of land parcels negative effects are identified for this option. that are not included within the ownership or control of the promoter and which are fundamental to achieving the design and masterplan proposed Paragraph 5.83: [..] approximately a third of the Heathlands site is at […] Uncertainty about the inclusion of all the land within the red line high risk of groundwater flooding. As such, significant negative remains a key issue going forward and risk to the delivery of the scheme. effects are anticipated. {more than all other garden community sites]