Joint Parishes Response to the MBC Local Plan Review.

Hollingbourne Parish Council has received a copy of the response from the Joint Parishes Group the Maidstone Borough Council Local Plan Review. Hollingbourne Parish Council is a member of the local Parishes Group which covers the area to the east of Maidstone. The response was written by John Horne who is a former Mayor of Maidstone.




  1. The Joint Parishes Group (JPG) is a consortium of some twelve parish councils within the North-Eastern and South-Eastern quadrant of Maidstone Borough in Kent. Amongst their objectives are to make joint and several responses to Government and other public consultations which affect their communities.
  2. In Maidstone Borough the result of the last LOCAL PLAN was a new housing      target  of  17,600 houses. The main outline has been built. This evidences an URBAN EXTENSION in two areas: (a) The South East extension along the   A274 (Sutton Road); (b|) the North West extension along the B2246    ((Hermitage Lane).


  1. In the result; there is now an URBAN SPRAWL, which has disconnected so many communities. The social and economic fabric is being destroyed.

A pernicious argument of “urban aggregation” is now being used by planning officers to justify further accretions.


  1. The current Review of the Local Plan – Call for Sites- has referred to the Government’s standardised method for calculating the number of new homes. An additional figure of 10,000 + for Maidstone.  This excludes any allowance for previous over provision.


“3 .Numbers and types of new housing: The government’s standardised method for calculating the number of new homes results in a  minimum working figure of approximately 1,200 [ now 1,236]  homes/year for the borough. This figure which will apply from 2022 when the Local Plan Review is adopted, is a significant uplift compared with the current Local Plan requirement of 883 homes/year. This inflated rate would need to be sustained for the council to maintain its 5-year housing land supply and to continue to pass the government’s Housing Delivery test.”



HC 1923 Session 2017-2019 08 February 2019;


The key findings show that the planning system is dysfunctional and failing the local community and the premise of the Ministry of Housing,Communities and Local Government in planning for new homes is flawed.  This is a serious independent Report; from which one concludes; the planning system is not fit for purpose.

It is noted that  an Inspector holding a Local Plan Inquiry does not appear to hear evidence on water supply and, or the need for adaptive urban planning.


Yet the Government’s absolute priority would appear to be 300,000 new homes per annum whatever it takes.


What is the reality of –need- given that the 2016 population projections are lower than the 2014 equivalent – and where will  the next update take us.  The Plan end date will be at the earliest 2037. With a sustained delivery rate year on year this gives a target total of   18,540 additional homes.


  1. The simplistic formula for determining –need- appears to act counter to the Government’s avowed intention to boost the economy in parts of the UK away from London and the South East; e.g. the Northern powerhouse. Many Northern Authorities are denied the opportunity for new build; while the South East have unwanted additional housing imposed upon the Districts.


Again, the formula is dysfunctional for any major commuting  area, as median wages are judged by reference to local jobs; not taking into account the presumably higher wages that justify commuting out of the area.[Currently, there is a shortfall in new build completions for London Zone  2]


IN SUMMARY:  There should be a pause, for fully reasoned and considered answers to all the  issues raised by the Comptroller and Auditor General before the  LOCAL PLAN REVIEW proceeds in this and other Districts.




Generally, worldwide there is a stepping back from unchecked urban sprawl with all its concomitant disadvantages. We are currently witnessing the rise of the out of town shopping area and the abrupt decay of the town centre shopping.

For example; Bournemouth town centre and the loss of major anchor stores with the corresponding growth of the Castlepoint shopping complex. This has the convenience of immediate and complimentary car parking. [It is noted that in the USA there is a shift away from this model].


The past development of town centre shopping projects depended some decades ago in enticing a well-known name, as the anchor tenant. For example, The House of Fraser for the Fremlin Walk development in Maidstone. Today, with the splintering of traditional stores and their sometimes-unsuccessful fight for survival, it is a model that is no longer valid.


The New Urbanist model is now itself outdated. Yet too often town planners are themselves caught in this time warp and are unable or unwilling to recognise the need for change.


As Jan Gehl, the urban designer from Copenhagen has said- architects and urban designers should build cities for people, not cars.


  1. Previously, in response to the Reg 19 Consultation, the Report from  the JPG referred to the Copenhagen model. A presentation by the Report author, Richard Eastham,   of feria urbanism,   was arranged for the benefit of the   members and officers of     The attendance did not include any officers and few members.




The Crowther Lab, Zurich has sought to understand climate change from a global analysis of city analogues.


“By analysing city pairs for 520   major cities of the world, we test if their climate in 2050 will resemble more closely to their own current climate conditions or to the current conditions of other cities in different bioclimatic regions …As a general trend we found that all cities tend to shift towards the sub-tropics, with the cities from the Northern hemisphere shifting to warmer conditions. (We) notably predict that London’s climate will resemble Barcelona.


“These results enable decision makers to envisage changes that are likely to occur in their own city and the required action to meet these environmental challenges.

…In 2008 Barcelona experienced extreme drought which required the importation of €22 m. of drinking water.


Future Cities:Climates in 2050. Plos/One Crowther Lab 2019.



  • The need for a sustainable water supply with catchment and reduced water loss. This includes a “sponge” city and rainwater cleansing.
  • Within the current new build what measures, if any, have been put in place to achieve a lower water usage of potable water, and an application of grey water.
  • The conversion of office blocks into housing exacerbates the present water supply situation.
  • The need for cleaner air, with a reduction in air borne particulates. A  costed scheme was stated for a Maidstone town centre hydro-electric generation  to supply, for example, an MBC all electric  van fleet. This failed to proceed.  As Mark Carney, the governor of the Bank of England,stated on Channel 4 News; “ The country is moving to net zero carbon by 2050. That is a legislative objective and that is going to require some pretty major changes. Companies that don’t adapt, including companies in the financial system, will go bankrupt without question.”
  • The need for a transport revolution, which is aligned with people’s needs. This could include a spine tramway and  A I shuttles. [The current bus service is underperforming ;as also the Maidstone road system.]
  • The need to enhance natural waterways to manage flooding and provide wildlife habitat:aligned with strategic landscaping. Any development must respect the existing topography and the need to protect the Aquifers and conserve existing water courses.
  • The need to encourage urban farms and gardens which are integrated into the townscape. Importantly, sustainable farming should be an integral part of the curriculum in future city schools.




Wang Zhigao, director of the  low carbon cities programme at the Energy Foundation China has said; ——-    If we don’t get the urban form right it will be there for hundreds of years. The Foundation paid for the redesign of   Chenggong, which has reinforced a change in mindset:Chinese cities were to preserve farmland and their heritage; have smaller unfenced blocks and narrower, pedestrian friendly  streets,  developed around public transit.


The current urban sprawl whilst conducive to short term gain is not sustainable in the long term.


There can no longer be isolated indifference.    When the taps run dry, it may be too late.




  1. This is a Review of a Local Plan which is itself flawed in some aspects. Accordingly, there should be a corrective mechanism within the Review.For instance, there was a weakness of previous locational decisions and the use of low/medium density layouts that contribute to sprawl vs. higher density town centre intensification that helps limit sprawl and helps boost footfall for town centre services.
  2. There is a mismatch with present and existing development and the infrastructure needs of the current population of Maidstone Borough. This can only be exacerbated by adopting a “business as usual”
  3. During the course of the Local Plan Inquiry MBC asserted their “rights” in areas, sometimes contrary to the views of the providing authority. Having achieved a determination in their favour they must now underwrite the overall delivery within any Review.
  4. There must be a corrective mechanism within urban and rural planning to ensure the optimum safeguarding of water courses, underground aquifers, river basins, flood prevention, storm water pollution, together with the provision for the capture & storage of precipitation.
  5. There must be a respect for the integrity and purpose of local parish communities.

Individual comments of the Local Plan Review should be sent to Maidstone Borough Council by 5pm on Monday 30th September 2019 and more information is at