HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
Richard Timms,
Principal Planning Officer,
Development Management,
Maidstone Borough Council,
Maidstone House,
King Street,
Maidstone,
Kent,
ME15 6JQ
13th August 2014
Ref: 14/501105/EIASCR
Dear Mr Timms
I am writing on behalf of Headcorn Parish Council, which welcomes the opportunity to
comment on the environmental impact assessment screening application for the proposed
development known as Hazelpits Farm (Ref: 14/501105/EIASCR). Having reviewed the
evidence, Headcorn Parish Council believes that an Environmental Impact Assessment is
warranted in this case.
The Town and Country Planning (Environmental Impact Assessment) Regulations 2011
(hereafter referred to as The Regulations) states that consultation bodies for an
Environmental Impact Assessment (EIA) Screening application should include “other bodies
designated by statutory provision as having specific environmental responsibilities and
which the relevant planning authority or the Secretary of State, as the case may be,
considers are likely to have an interest in the application”.1 Its democratic mandate,
together with the statutory responsibilities of the Parish Council, means than Headcorn
Parish Council has a significant interest in this application.
Headcorn Parish Council is the elected body that represents the 3,700 residents in Headcorn
Parish. Headcorn Parish is a designated Neighbourhood Plan Area, and Maidstone Borough
Council has assigned it Rural Service Centre status. The views expressed in this consultation
response have been informed by the surveys of residents and businesses that were
undertaken by the Headcorn Matters Neighbourhood Plan Team in 2013 to underpin
Headcorn’s Neighbourhood Plan. These surveys achieved a good response rate, with 797
responses to the residents’ survey, with representation from around 38% of the 1,600
eligible households, and responses from over 35% of the 143 eligible businesses. Therefore
the views expressed in this consultation response about Headcorn’s development should be
seen as representative of the overall needs and priorities of people and businesses within
Headcorn Parish.
The developers state that the size of this project, which exceeds 0.5 hectares, means the
proposal falls within category 10(b) of Schedule 2 of The Regulations, meaning that it is
necessary to determine whether an EIA is required. Headcorn Parish Council note that this
application is for a development that is over three times the size of any other development
1
The Town and Country Planning (Environmental Impact Assessment) Regulations 2011, Part I,
paragraph 2.1.c.iv.
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
within the village and would constitute almost a 17% increase in the size of the village.
Headcorn Parish Council therefore believes that issues of scale play a significant role in this
application and that these on their own would suggest that the prudent course of action by
MBC would be to require an EIA.
The list of potential factors that need to be considered in an EIA are not prescribed by
legislation, but Schedule 4, Part 1, paragraph 3 of The Regulations notes that the aspects of
the environment that are potentially covered by an EIA include "in particular, population,
fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and
archaeological heritage, landscape and the inter-relationship between the above factors".
Having reviewed the evidence, Headcorn Parish Council believes that a full EIA is required
because of the impact of this proposed development on:
 Water management (flooding and sewage);
 Landscape and material assets;
 Traffic (including air pollution);
 Noise and light pollution; and
 Fauna and flora.
Headcorn Parish Council notes that the developer proposes that some of these issues, such
as flooding, will be dealt with by standalone reports and that they have argued that this
means a full EIA is unnecessary. However, Headcorn Parish Council does not agree with this
conclusion for two reasons: firstly because the proposed reports do not cover all the
relevant issues; and secondly because this approach fails to capture the interactions
between them, which Headcorn Parish Council believe are potentially significant.
1. Water management
Headcorn Parish Council believes that issues around both flooding and sewage imply the
need for a full EIA.
1.a. Sewage and waste water management
The evidence on sewage and wastewater management produced independently of this
application all suggest that sewage and wastewater management are a significant problem
in Headcorn that should constrain development, for example:
 Headcorn Parish Council notes that Southern Water’s assessment of all three large
sites in Headcorn (including this site) proposed in MBC’s Local Plan was that there
was no available sewerage capacity.
 The Water Cycle Study conducted in 2010 for Maidstone Borough Council, by the
Halcrow Group Limited, which is based on Southern Waters own data, states very
clearly that the headroom for further development in Headcorn is zero because of
the consented dry weather flow for the Wastewater Treatment Works.
(http://www.maidstone.gov.uk/__data/assets/pdf_file/0019/12088/Water-CycleStudy-Outline-Report-2010.pdf).
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com

Furthermore, Headcorn Parish Council notes that in MBC’s Sustainability Appraisal of
its Local Plan produced by URS2, the option of building 1,000 homes in Headcorn was
rejected in part because of the significant negative impact on water management
that development in Headcorn would produce, a judgement that Headcorn Parish
Council also believes applies to the development under consideration, which on its
own constitutes one quarter of the total housing development assessed by MBC’s SA
Report, and combined with recent planning approvals, the cumulative impact is
around one third of the total.
Headcorn Parish Council’s own evidence supports this view. The evidence shows that there
are already significant problems with the sewage and storm drainage system in Headcorn:
 Over 46% of residents rated sewage and storm drainage as “bad – improvement
needed now”, in the survey of residents of Headcorn Parish we have conducted to
support our Neighbourhood Plan. This is more than the combined total of those that
rated it as either excellent or OK.
 60% of businesses in Headcorn saw the reliability of the sewage and storm drainage
as a constraint on future expansion, in the survey of businesses in Headcorn parish
we conducted for our Neighbourhood Plan.
 Sewage has come out of the manhole at Moat Road in Headcorn on well over 10
separate occasions this year, the most recent being in early August. This manhole is
a particularly important indicator of systemic sewerage problems, because of where
it sits in the sewerage system.
 Headcorn Parish Council also notes that the type of “solution” to the lack of
sewerage capacity that have been used in recent developments have proved
unreliable. For example, the solution used in The Hardwicks development has
released foul water into the ditches on at least one occasion.
Given the clear evidence of a problem, and the unreliability of the potential solutions to
sewerage capacity that have been tried so far, Headcorn Parish Council believes that sewage
issues on their own would warrant the need for and EIA. In particular, it notes that the
pressure put on the foul sewer drainage will inevitably increase the possibility of damage to
the River Beult SSSI.
Headcorn Parish Council is also concerned that the potential failure of proposed solutions,
including the possibility of foul water discharge, would be particularly damaging in the
context of a large, high density development, because of the potential impact on human
health. The reliability of potential solutions would therefore need to be assessed in the
context of the geology of Headcorn to ensure their resilience. Headcorn Parish Council also
notes that the proposed development of this site potentially increases the risk of sewage
discharge from manholes within the village during periods of heavy rain and that this is
likely to affect additional manholes, not just the one Moat Road.
Headcorn Parish Council also notes that the potential solutions to this problem that have
been employed elsewhere in the parish involve a significant amount of hard standing
2
URS “Sustainability Appraisal (SA) of the Maidstone Local Plan”, March 2014, [hereafter referred to
as MBC’s SA Report].
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
covering holding tanks and that this would exacerbate surface water flooding and create
noise pollution. Headcorn Parish Council believes that these interactions should be properly
explored, which is one of the reasons for undertaking an EIA as noted in Schedule 4, Part 1,
paragraph 3 of The Regulations.
1.b. Flooding
The National Planning Policy Framework makes clear that development should not be
allowed that would increase the risk of flooding elsewhere.3 Headcorn Parish Council
believes that this proposed development has the capacity to exacerbate flooding issues
within the village (both fluvial and surface run off) and that significant modelling is likely to
be required to understand fully the impact of developing this site on flooding and to ensure
that adequate mitigation measures (both for the site itself and the wider village) have been
put in place. Headcorn Parish Council believes this is particularly important, as it notes that
MBC’s SA Report suggests that it will be difficult to mitigate the flood risk associated with
this site.4
Headcorn Parish Council notes that the site lies on clay and will discharge storm water into
the Hoggs Bridge Stream. In the 2000 flood, a number of nearby properties were inundated
from ground water run off due to saturated ground. A large development such as this, with
so much roof and concrete, will exacerbate this issue. No amount of water storage will
ameliorate this. Headcorn Parish Council believes that Brooklands, Orchard Glade and
Headcorn Primary School are all sites at risk of experiencing increased flooding as the result
of developing this site.
Headcorn Parish Council believes that in order to judge the impact of the proposed
development on flooding, as well as the effectiveness of any mitigation measures, a fully
worked up solution should be presented as part of the EIA that takes into account a detailed
planning proposal rather than just an outline proposal. Without this, it will not be possible to
ensure that the proposed solutions will work in practice.
Finally, the issue of flooding also needs to be explored in the context of both traffic flows
and the impact of increased traffic on the Ulcombe Road necessitated by the fact the
Headcorn Primary School is already oversubscribed and therefore, if this site is developed,
that more parents will need to use this road to take their children to Ulcombe primary
school. The Ulcombe Road is subject to flooding and is closed at times during most winters
due to deep water. Using the Ulcombe Road as the only road access to the village means
that this site will be cut off from time to time. For example, a number of cars were stranded
on Christmas Eve 2013. This is also an issue for the proposed foot and emergency access via
the western farm track.
2. Landscape and material assets
Headcorn Parish Council notes that this proposal is for a large development of up to 270
houses. This application is therefore for a development that is over three times the size of
any other development within the village and would result in almost a 17% increase in the
size of the village in one go. One of the factors that government guidelines recommend
3
4
National Planning Policy Framework, paragraph 100.
MBC’s SA Report, p88, paragraph 20.3.2.
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
should be considered as part of the landscape appraisal for an EIA is scale, and whether or
not the development would cause a material change to the appearance of the landscape or
townscape.5
Headcorn Parish Council believes the scale of this development means that it is incompatible
with a village setting and that it would significantly undermine the village landscape. A
development of this size is more suited for an urban, rather than a rural, environment, a fact
reinforced by the fact that this EIA screening application is being considered under category
10(b) of Schedule 2 of The Regulations, which is defined as “urban development projects”.
The urban nature of this development is reinforced by the proposed layout contained in
DHA Planning’s letter to Cllr Round in the context of a proposed village meeting to be held
on August 21, where it is clear from the plan that the proposed plot sizes are significantly
smaller than those in all the surrounding developments.6 Headcorn is not an urban setting,
but a country village.
Headcorn Parish Council therefore strongly believes the landscape impacts of this proposed
development should be properly explored in the context of an EIA. While this assessment
should obviously include the fact that this site is visually prominent from the Ulcombe Road
(a risk identified in MBC’s SA Report)7, it should also look at the impact of the look and feel
of this development in the context of the wider village. In this context, it is important to
recognise that over 65% of villagers, who took part in Headcorn’s residents survey, identified
“losing the sense of being a village” as the biggest threat posed by development,
significantly higher than any other risk they identified, with the second biggest threat being
seen as “development more suitable for a town than a village”. Undermining Headcorn’s
village landscape will therefore impose significant costs on residents in the form of reduced
wellbeing.
The scale of this development is likely to be a particular sticking point, as it is incompatible
with the type of development residents want to see. 72% of residents want developments to
be no more than 20 houses and almost 90% want developments to be no more than 30
houses. Indeed, 96% of residents wanted the total development in Headcorn over the next
20 years to be at most 250 houses. Headcorn Parish Council believes that smaller scale
development, spread out over time, is more sustainable for rural villages such as Headcorn:
it allows development to adapt to the changing needs of the local community over time; it
makes it easier for the newcomers to integrate with the local community; it ensures villages
like Headcorn do not lose their identity; and ensures that local work for those in
construction is spread out more evenly over time and is therefore less prone to a feast or
famine cycle.
Headcorn Parish Council believes that the scale of this proposed development and its impact
of the village landscape could also have a significant impact on people’s material assets,
which should also be explored in the context of an EIA. This could arise in various ways:
including its direct impact on property prices, as well as indirect effects caused by the fact
that this potential development is likely to undermine the viability of the local primary
school.
5
https://www.gov.uk/assessing-environmental-impact-guidance
DHA Planning’s reference: MFP/HB/10275.
7
Technical Appendix A, Appraisal of Site HO-7, p6.
6
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
In general, people move to villages, because they want a village, rather than an urban
setting. This has an impact on housing demand in villages. The survey of residential estate
agents in Headcorn undertaken by the Headcorn Matter’s team revealed that all seven
estate agents interviewed felt that large scale developments (more than 30 houses) were
significantly harder to sell in the context of a village setting. While the size of the sample
means that this evidence is anecdotal, rather than statistically robust, it raises significant
questions, particularly as all the major estate agents selling houses in Headcorn village were
interviewed. If the estate agents are correct, it would mean that a development of this scale
have a significant impact on the property prices of the surrounding houses. However, it
could also potentially act as a drag on property prices in the village as a whole, through its
potential impact on the village’s popularity and the smooth functioning of the local housing
market (for example large numbers of unsold houses within the proposed development
could make it harder to sell houses elsewhere in the village).
Given the strong links between good schools and house prices, the impact of this proposed
development on Headcorn’s Primary School could also undermine the material assets of
home owners in the village, as well as undermining the sustainability of the village as a
whole. Headcorn Primary School is currently oversubscribed and this would be exacerbated
by this proposed development, which would result in almost a 17% increase in the number
of homes in the village. This would have an impact on house prices of houses within the
village where children would currently be considered eligible, but would face potential
exclusion in future given relative distance from the school. It would also, obviously,
significantly increase the number of vehicle movements in the village at key times, as
parents would need to take their children to schools in other villages.
More worryingly, this proposed development could significantly undermine the viability of
Headcorn’s Primary School in its current location. A recent survey of parents, students,
governors and teachers undertaken by Headcorn Primary School indicated that the
preferred option to tackle the problem of oversubscription was expansion of the existing
school site, keeping Headcorn’s children together and keeping Headcorn Primary School in
the heart of the village. This preference was reinforced by the consultation with residents on
Headcorn’s emerging Neighbourhood Plan that took place on June 13th and 14th of this year,
where this proposal received overwhelming support. Achieving this would require a
significant section of land at the bottom edge of the proposed development (possibly as
much as 2.5 hectares) to be reserved for future school expansion. Without this land being
set aside for future school expansion, there is a significant risk that the entire school would
need to move to a larger site on the outskirts of the village (assuming a suitable site can be
found), undermining the sustainability of the village as a whole, with fewer properties (by
definition) in walking distance of the primary school, as well as the viability of the High
Street, which benefits from the location of the school.
Headcorn Parish Council therefore strongly believes that it is in the interests of the entire
village that this proposed development should be prevented from undermining the viability
of the school in its existing location, by preventing future expansion, and that these
considerations should form part of the EIA, given their potential impacts on material assets,
traffic movements, the wellbeing of the population (particularly the children who would
otherwise face a long commute to school) and the viability of the local economy. Even
without a decision to move the school, and instead a decision to develop a second school on
the outskirts of the village, or to fund school expansion elsewhere, Headcorn Parish Council
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
notes that this would undermine the sense of community within the village, in light of the
importance of schools for parents’ and children’s social networks.
3. Traffic (including air pollution)
Headcorn Parish Council notes that when this site was included in Maidstone’s draft Local
Plan the proposed access was via the A274. Headcorn Parish Council believes that this
remains the only viable option for appropriate development of this site, and that the
proposed access via Ulcombe Road will create significant traffic problems.
The Ulcombe Road is a narrow country lane and is entirely unsuitable to take additional
traffic movements from a 270 house development, which would include residents, visitors
and delivery vans. Due to the distance from the station and the nearest GP, for example, this
proposed development can be expected to add to a significant number of traffic
movements.8 Similarly, the impact on demand for primary school places would also increase
vehicle movements, with the likely increase in children from Headcorn being forced to
attend Ulcombe Primary school. Pressure would also be put on the Tattlebury Lane route via
Ulcombe Road to the A274. Neither of these roads is suitable for a significant increase in
traffic flows.
Headcorn Parish Council believes that these traffic issues warrant further investigation in the
context of an EIA. In addition, the close proximity of the primary school means that the
impact of potential air pollution at peak times should be considered.
4. Noise and light pollution
The size of this proposed development, which is urban in scale, suggests that potentially
urban lighting solutions will be needed in order to make residents in the development feel
safe. This would create significant light pollution and would be out of keeping with the
village environment. The interaction between safety considerations and light pollution
should be considered in the context of an EIA.
In addition, it is likely that the potential drainage solutions introduced as part of the need to
address sewerage capacity could produce significant noise pollution, because of the impact
on the amount of hard standing. Noise levels linked to hard standing are one reason why 18
out of 25 (72%) residents in The Hardwicks development that has just been completed in the
village have requested a transfer elsewhere. Again Headcorn Parish Council believes that this
issue should be investigated in the context of an EIA. Even if the proposals do not breach
noise guidelines, significant noise issues would undermine the desirability (and hence
sustainability) of the proposed development, as well as the wider village. It will therefore be
important to address this, and this should be done in the context of an EIA based on a fully
worked up plan, that considers the likely inter-relationships between different options, and
the fact that a solution for one problem could exacerbate another.
5. Flora and fauna
8
Investigation by Google maps shows that both the station and the GP are more than 800m from this
development, which if this had been correctly identified in MBC’s SA Report would have led to this
site being given a red rating for these categories.
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
The hedge rows on this site support significant wild life, including slow worms, grass snake,
lizards, bird and rodent life and the Hoggs Bridge Stream also supports a number of species.
In addition, because of its position, it is likely that this site supports wildlife within the heart
of the village. The impact of this proposed development on the flora and fauna in Headcorn
should therefore be considered in the context of an EIA, which could address for example
the potential impact of possible light pollution, or traffic movements on the ecology of
Headcorn. Headcorn Parish Council believes that this consideration should include the best
options for creating effective green corridors, making use of the existing trees and
hedgerows.
6. Land quality
Finally, as a point of fact, Headcorn Parish Council notes that there appears to be a
discrepancy in the evidence MBC have produced on the land quality for this site. While the
developer has quoted that the land is grade 4, based on MBC’s SHEDLAA, MBC’s SA Report
notes that this site includes Grade 3 agricultural land, making URS’s assessment of the
impact of land use on sustainability of the development of this site a combination of red and
amber.9 In view of the fact that these fields are still in active use, for the purposes of this
application, Headcorn Parish Council believes that the land should be treated as Grade 3
agricultural land.
Summary
The issues raised in this consultation response mean that Headcorn Parish Council strongly
believes that the evidence shows that an EIA is warranted for the proposed development of
Hazelpits Farm. Indeed its sheer scale alone and the associated impact on the village
landscape would suggest that MBC should take a prudent approach and request an EIA.
Given the significant opposition to Maidstone’s draft Local Plan from residents of Headcorn,
in part because of the scale of this particular potential development, Headcorn Parish
Council believes that MBC should go to significant lengths to make sure the evidence
underpinning this proposal is as comprehensive as possible, to ensure that they act in the
best interests of local residents.
I look forward to hearing from you.
Yours sincerely
Mrs Helen Anderson,
Parish Clerk, Headcorn Parish Council
Cc:
 Cllr Richard Thick, representative for Headcorn Ward, Maidstone Borough Council;
 Cllr Martin Round, representative for Headcorn Ward, Maidstone Borough Council;
 Mr Rob Jarman, Head of Planning and Development, MBC
9
Technical Appendix A, Appraisal of Site HO-7, p3.
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HEADCORN PARISH COUNCIL
Parish Office 41 Oak Farm Gardens, Headcorn, TN27 9TZ
Tel: 01622 892496 Email: headcornparishclerk@gmail.com
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