Arches Chatham Neighbourhood Plan - Regulation 16
Chapter 3: Policies
Policies - Housing
HO1 - Affordable housing
New developments must provide high quality, affordable housing for sale and for rent, which takes into consideration the local needs for tenure and size. Family housing is currently underrepresented, therefore the delivery of larger homes would be strongly supported.
At least 10% of dwellings in new developments of 10 homes or more must be affordable. These developments must be tenure blind and benefit the same level of access and amenities.
Where new development is required to provide affordable housing, on-site delivery should be prioritised in the first instance. Off-site provision or financial contribution in lieu would require robust justification, and such provision or contribution should be made within the Neighbourhood Area where possible.
HO1 - Rationale
The trigger for affordable housing has been designed to align with the policy requirements of the emerging Medway Local Plan 2037. In addition, a life stage modelling exercise was undertaken as part of a Housing Needs Assessment (HNA) for the Heart of Chatham project, which looked at the sizes of dwellings occupied by households at different life stages and projects the growth and decline of those household age groups over the ACNP's plan period. The results from the exercise determined that new development should be restricted to homes with 3 or more bedrooms because these size categories are so underrepresented at present compared with what the future population might be expected to need given the existing preferences of different age groups across Medway. It also suggested that an injection of larger homes would improve the offering for larger families who have few options for their next step on the property ladder, and would also widen choice in general. Affordable housing needs to be well-integrated into a mixed tenure development and indistinguishable from market housing, as national planning policy expects developments to foster social interactions between groups who 'might not otherwise come in to contact' (Paragraph 92 of the National Planning Policy Framework), and to be designed to be inclusive.
HO2 - Beautiful Design
New developments and external alterations to existing buildings requiring planning permission must be designed with regard to the Design Code (Appendix A). They should: respect the scale, density and identified valued characteristics of the Neighbourhood Area. Consideration should be given to opportunities for renewable energy and energy storage and/or orientation of buildings to benefit from solar, water efficiency measures, reuse of locally sourced building materials or integration of district heating systems.
HO2 - Rationale
Community engagement has demonstrated that local people's valued characteristics of the area derive from the traditional housing stock of the neighbourhood, rather than what has been delivered through new-build developments (see Consultation Statement). New-build developments have been regarded as harmful to the area's historic character and architectural identity (see ACNF Area Study). In addition, a 2020 survey of 150 residents revealed that 73.3% of people strongly supported the notion that new buildings should be designed to be highly energy efficient/carbon neutral (see Consultation Statement).
HO3 - Family Housing
Developments that remove family homes from the market will not be supported. Family housing can be defined as having 2 or more bedrooms with access to external amenity space. Developments that re-introduce family housing â€“ including conversions of existing properties into family housing â€“ will be strongly supported. Rear and upward extensions, as well as the combination of two homes into a larger family home, are also supported. Conversions should have regard to the standards set in the Design Code (Appendix A).
HO3 - Rationale
A Housing Needs Assessment (HNA) produced for the Heart of Chatham project illustrated the undersupply of family housing using a life stage modelling exercise. As the area comprises of a significant amount of two- up, two-down pre-war family homes, the policy defines family housing as encompassing 2 or more bedrooms with access to external amenity space. If it was to be defined as 3 or more bedrooms, the supply of this type of housing would be placed at further risk due to potential conversions of these aforementioned properties. This policy aims to bring back a greater mixed variety of different sized homes to the area, including family homes, and gives homeowners the opportunity to make their existing homes fit for growing families.
HO4 - Site Allocations
The following 8 sites are allocated for a mix of uses, which includes residential and commercial.
- The Brook and King Street land
- Former Go Outdoors
- Union Place
- 393 High Street
- Pembroke Court car park
- Arches View
- Bright Road
- Dagmar Road
Development proposals should be developed with regard to the guidance provided within Chapter 4. For any new residential development in this area, financial contributions towards the Thames, Medway and Swale Estuaries Strategic Access Management and Monitoring Strategy are required, to mitigate increased recreational disturbance on those coastal SPAs and Ramsar Sites.
New developments must be designed in line with regard to the standards set out in the Design Code (Appendix A).
HO4 - Rationale
There are a number of sites in the Neighbourhood Area which may be expected to come forward for development in the duration of the plan period. Any forthcoming proposals for these sites must adhere to the Design Code (Appendix A) and are required to avoid or minimise harm to designated and non-designated heritage assets. In the exceptional circumstance that Historic England or the Local Planning Authority express a divergence from the design code in order to respond positively to heritage assets, their conclusions should take precedence. See the Site Allocations Report (Appendix E) for the rationale and process which has led to the identification of the 8 allocated sites.
HO5 - HMO
An over-concentration of Houses of Multiple Occupation (HMO) within the Neighbourhood Area will not be supported. The threshold is defined as 20% HMO on the road of the planning application, ensuring that only 1 out of a consecutive row of 5 units is converted to C4. Two C4s should not adjoin and no C3 property should be sandwiched between two HMO.
HO5 - Rationale
HMO can play an important role in the supply of housing locally. However, concentrations of HMO have resulted in changes to the character of the area, contribute to high parking stress, produce transiency and lower the standards of amenity for local residents. In turn, this has led to concerns that the community is becoming unbalanced in parts due to the number of short-term tenants with weaker community ties. Locally, numerous clusters of licensed HMO exist, although these are in a state of disrepair (see ACNF Area Study map) and there are also some that exist without the benefit of planning permission but are now immune from enforcement action. ACNF has developed this policy guided by the successes of other Local Planning Authorities, particularly Enfield Council who share similar housing and socio-economic challenges.
HO6 - Outdoor Space
All new developments must provide high quality outdoor space for use by occupants, which can be provided via outdoor gardens, allotments, shared open space or other private outdoor spaces within the development boundary. There should be a minimum of 5m2 of open space for one to two occupants, and an extra 1m2 should be provided for each additional occupant. The design of the outdoor space should include the need to provide a net gain for biodiversity. Proposals which result in the unjustified loss of natural outdoor space, such as gardens, in order to create additional dwellings will not be supported as this would compromise the amenity of the household.
HO6 - Rationale
Friends of the Earth scored the Neighbourhood Area a rating of D and E, which means the neighbourhood is among the most deprived of green space, including gardens and parks. All housing types should provide external amenity space, measuring 5m2 for one to two occupants and an extra 1m2 should be provided for each additional occupant, in line with the Medway Housing Design Standards (Interim) 2011 to ensure a good quality of life.
HO7 - Historic Environment
Every effort should be made to avoid harm to designated heritage assets and their settings, such as listed buildings, scheduled monuments, and conservation areas, will be expected to be protected, conserved and, where practicable, enhanced where they would be affected by development proposals. In cases where harm is unavoidable, the potential benefits of the development should be weighed against the negative harm likely to come to the heritage assets. Proposals for development that will result in the loss of, or harm to a non-designated heritage asset will not be supported, unless it can be demonstrated that the benefits of the development outweigh the loss of significance of the asset and cannot otherwise be provided in a less harmful manner. The historic environment should be enhanced through the use of traditional materials, patterns or designs where appropriate, and the interpretation, alteration or use of heritage assets to better reveal their significance is supported, such as through the removal or replacement of inappropriate or unsympathetic alterations and additions.
HO7 - Rationale
In line with the National Planning Policy Framework (paragraph 190), plans should set out a positive strategy for the conservation and appreciation of the historic environment. The National Planning Policy Framework is clear that "great weight" should be given to the need to conserve designated heritage assets against the threat imposed by new developments.
HO8 - New & Improved Utility Infrastructure
Where necessary, new development proposals must demonstrate that an adequate water and wastewater capacity exists to meet the needs generated. Proposals for and including new and improved utility infrastructure will be supported in order to meet the identified needs of the community subject to other policies in the plan.
In such cases, occupation of development will be phased to align with the delivery of network reinforcement. In addition, the layout of sites will need to ensure access is maintained to any existing underground infrastructure for maintenance and upsizing purposes.
HO8 - Rationale
The National Planning Policy Framework (paragraph 28) establishes that communities should set out detailed policies for 'the provision of infrastructure and community facilities at a local level'. Furthermore, the National Planning Practice Guidance states that 'Adequate water and wastewater infrastructure is needed to support sustainable development'.
Policies - Built & Natural Environment
BNE1 - Public realm enhancement
Development proposals which take opportunities to improve the public realm of the area where justified, will be supported in principle. Examples of public realm improvements include:
- Widening and improving pedestrian routes, including high quality paving, and raised crossing points.
- Enhancing the connectivity of the neighbourhood area, including ecological connectivity through the creation of linear parks and ecological corridors.
- Where possible, incorporating permeable surfaces and/or other suitable sustainable drainage systems (SuDS) designs to reduce the risk of surface water flooding and increase local resilience to climate change.
- Increasing the frequency and quality of greenery in the area.
- Improving the safety of the public realm from road traffic collisions and anti-social behaviour.
- Contributing to the identity of the neighbourhood through public art interventions.
BNE1 - Rationale
Studies of the area, which include an AECOM area-wide assessment and the ACNF Area Study revealed that the current streetscape provides an unpleasant experience for pedestrians and cyclists. Pavements are often narrow and of poor quality materials, including tarmac, and excessive street furniture, such as pedestrian guard railing, create a 'cluttering' effect. In addition, the policy's suggested public realm improvements are demonstrably supported by residents through community consultation. This is also supported by De-Cluttering Streets in Medway 2013 report and Manual for Streets 2.
BNE2 - Local Green Space
This plan designates the following as Local Green Space:
- Town Hall Gardens
- Luton Millennium Green
Inappropriate development will not be permitted unless very special circumstances arise. See Appendix D for the rationale which supports the designations.
BNE2 - Rationale
The designation of Town Hall Gardens and Luton Millennium Green as Local Green Spaces was determined by a set of criteria, which is demonstrated in Appendix D. In addition, in a survey of 150 residents, 91.3% said that green space was important for their physical and mental well-being (see Consultation Statement).
BNE3 - Public open spaces
Developments which provide new public open spaces or enhance existing public open spaces will be strongly supported. Open spaces should be easily accessible and provide various activities for a range of demographics in the area, including sports and recreational facilities. The retention of existing open spaces is required and the location of new open spaces should ensure that it meets local needs.
Developments which remove public open spaces must replace them with increased biodiversity net gain and replacement of the function of the open space, elsewhere within the Neighbourhood Area. The only exception to this is special circumstances for the purposes of essential utilities infrastructure, where no feasible alternative site is available.
BNE3 - Rationale
There are two principal public open spaces in the area, Town Hall Gardens and Luton Millennium Green. These spaces are underused, poorly maintained and lack good accessibility to all residents. Despite this, public open spaces are important to the community and valuable in their social, environmental and economic benefits, as evidenced by national studies including the National Heritage Fund's Parks for People 2021 report.
BNE4 - Urban Greening
Development (excluding householder applications) should be designed in conjunction with Table B.1 of the British Standard 5837:2012, and designed to a minimum to:
- Achieve a future canopy cover of 25% of the site area and 0.5 ha or more. This will principally be achieved through the retention and planting of trees, but where it can be demonstrated that this is impractical the use of other green infrastructure (e.g. green roofs and walls, hedges, hedgerows and pleached trees) can be used to deliver similar benefit;
- On sites below 0.5 ha development should maximise the opportunities available for canopy cover (including not only tree planting but also the use of other green infrastructure as listed above).
In the exceptional circumstance that a tree needs to be felled (e.g. deceased, installation of critical infrastructure, etc.), it must be:
- Replaced within the Neighbourhood Area to a minimum size of Heavy or Extra Heavy.
- All new planting should be of a native species where possible, ideally those most suited to pollution absorption. This planting should be prioritised in areas of poor air quality and high density of housing.
BNE4 - Rationale
There is currently a clear lack of urban green infrastructure in the area and the limited amount in existence is not well joint up. Community-led efforts by Arches Local to introduce greenery into the dense, built-up parts of the area have proved successful and are continuing annually. Various international studies have demonstrated street trees' ability to reduce toxic air mortality, improve mental health, and encourage biodiversity (Riondato, 2020), (Wolf, 2018) and (Wood & Marzluff, 2020).
BNE5 - Protection of Designated Sites
Development proposals must demonstrably avoid harm, directly or indirectly, to the scientific or nature conservation interests of designated sites including SPA, Ramsar, SSSI and national nature reserves. They should also promote the conservation, restoration and enhancement of priority habitat deciduous woodlands located within the Neighbourhood Area (See DEFRA Central England Inventory 2022).
BNE5 - Rationale
To achieve sustainable development and to protect biodiversity, recreational pressure effects on sites designated for overwintering and breeding birds must be mitigated. Ensuring that large developments are required to demonstrate the availability of green space and blue space to help absorb recreation pressure prevents the over development of the Neighbourhood Area without regard for the wellbeing of the local community and health of local wildlife. To ensure that recreational pressure effects on sites designated for overwintering and breeding birds are appropriately mitigated, residential development in the 6km and 6-10km core recreational catchment zones will need to contribute to the recreation mitigation strategy emerging for the North Kent SPA and Ramsar. All residential developments within 6km and larger developments (comprising 100+ dwellings) within 6-10km will need to contribute an agreed per-dwelling tariff towards Strategic Access Management and Monitoring in the European sites. Furthermore, larger developments are required to demonstrate the availability of or provide for alternative greenspace / blue space to help absorb recreation pressure locally.
BNE6 - Non-designated Heritage Assets
Proposals which affect non-designated heritage assets will be considered in accordance with national policy. The Neighbourhood Plan nominates the following sites/buildings as Non-designated Heritage Assets:
- Little Crown, 346 High Street, Chatham
- 421 High Street, Chatham
- 2-4 Luton Road, Chatham
- 4a Luton Road, Chatham
- 8a Luton Road, Chatham
- 134a Luton Road, Chatham
- Invicta Social Club, 207 Luton Road, Chatham
- All Saints Church, Magpie Hall Road, Chatham
- 31 Grove Road, Chatham
- Sydney Villa, 5-7 Constitution Road, Chatham
- Town Hall Gardens, Rope Walk, Chatham
- Loxley House, 219 New Road, Chatham
- Elephant & Castle, 142 Luton Road, Chatham
- Luton Arches, Chatham
BNE6 - Rationale
These sites have been identified as being of key significance to the local community's built-heritage and identity by the Neighbourhood Forum which is demonstrated in Appendix B. By nominating these sites as Non-designated Heritage Assets, they should be safeguarded from the negative impacts of future development.
Policies - Sustainable Transport
ST1 - Air quality
Developments which provide a gain of housing, except those which involve the change of use of premises, should demonstrate how they will contribute to the improvement of local air quality. Proposals should also be in accordance with any local air quality action plan. New developments and street improvements should encourage active travel and the reduction of car dependency by including the following, where appropriate:
- Use of low emission vehicles in construction
- Street-level greenery to absorb pollution
- Tree planting (where possible native, particularly those best suited for pollution absorption)
- Freight consolidation
- Pedestrian-priority street design
- Cycle parking
- Segregated cycle tracks
- Incorporating active travel routes through sites
ST1 - Rationale
Nitrogen dioxide and particulate matter (PM2.5) are the main pollutants of concern within Medway, primarily deriving from road traffic emissions. New development is likely to put existing areas of poor air quality under additional pressure and could negate actions to improve air quality. The Neighbourhood Area partly falls within the Central Medway Air Quality Management Area (AQMA), including A2 New Road and Luton Road. The AQMA was declared by Medway Council in 2010 due to exceedances of the annual mean NO2 above the Air Quality Objective (AQO). In October 2022, Friends of the Earth analysed data on air quality across the country and found large parts of Medway, including the neighbourhood planning boundary, are commonly in breach of World Health Organisation Guidelines.
ST2 - Active travel routes
Developments which propose to revive or create new routes for active travel will be supported. These routes must be publicly accessible, well maintained and safely designed for users.
ST2 - Rationale
The provision of new or improved routes for active travel can enable increased levels of walking and cycling throughout the Neighbourhood Area, in turn reducing air pollution and improving the physical health of residents. In addition, in a survey of 150 residents, the question of 'how do you want to travel in 2030' was overwhelmingly answered as 'walking', followed by tram (see Consultation Statement). Example locations of existing active travel routes in the Neighbourhood Area include Luton Road service road (Pig Alley), Henry Street/Newnham Street estate and Market Place (between New Road and High Street).
ST3 - Humanising Luton Road
Traffic management measures along Luton Road that minimise the impact of traffic â€“ such as noise and air pollution â€“ and improve safety, particularly for the most vulnerable road users, will be supported. This includes traffic calming, long-term reduction in through traffic, reorganising existing parking provision, introducing a 20mph speed limit, and repurposing build outs for street tree planting and Sustainable Drainage Systems (SuDS). Well-designed SuDS can help meet climate targets through their ability to improve water quality while managing and mitigating both flood risk and surface water runoff created as a result of new development. Planting schemes that support reduced water runoff should be prioritised.
ST3 - Rationale
Luton Road is categorised as a C class road, although it has become a rat-run thoroughfare for motorists travelling to and from the outlying suburbs of Chatham, such as Lordswood. This is despite 43% of residents living in the Neighbourhood Area not owning a private car (Census 2011). The car-dominated public realm has harmed the experience for pedestrians and cyclists, with access to local shops and amenities hindered by the impact of traffic. A shift towards a more pedestrian-friendly environment as well as a higher-quality public realm is needed in order to revive Luton Road (see Appendix C).
ST4 - Parking
New developments should be car-lite in form and function. Opportunity and on-street car parking should be utilised where possible, supported by a parking stress survey. Car parking should prioritise disabled spaces and ensure all new spaces have active electric chargers or passive electric chargers with future capability built in. Electric car club spaces will be supported.
ST4 - Rationale
In order to achieve a human-centred and environmentally sustainable local centre, a modal shift from private vehicles to active travel and public transport is needed. The long-term reduction in car parking provision associated with new development is necessary to design out this car dependency. The absence of space taken by car dependent developments could create opportunities for additional homes, green infrastructure, parks, etc. In the instance that parking is provided, 90.9% of respondents agreed that new developments should be future-proofed with electric car charging infrastructure (see Consultation Statement).
Policies - Local Economy
E1 - Encouraging new business
Development proposals that provide new business (Use Class E(g)) spaces or the right conditions for business to flourish will be supported; this includes specific provision for social and cultural enterprises and which enable affordable workspace at rents below the market average. The right conditions include infrastructure (for example fibre to the cabinet (FTTC) or to the premises (FFTP) superfast broadband) and the repurposing of existing unused premises.
E1 - Rationale
The Neighbourhood Area is in a highly sustainable location featuring several key qualities for a successful 15-minute neighbourhood. Distance to key amenities is generally better against the Medway average and car ownership is lower, but there's a severe lack of local employment opportunities despite many vacant premises which could provide spaces for businesses. There are 84.86 claimants of Universal Credit for every locally available job compared with 6.55 complaints per job across Medway (OCSI Local Insights Profile for 'Arches Local - Neighbourhood Plan Area', November 2022). Residents support encouraging reinvestment in empty commercial spaces, as well as using innovative ideas to encourage new businesses to set up shop (e.g. pop-up cafÃ©s, co-working spaces) (see Consultation Statement). Social enterprises are businesses whose primary purpose is to address a specific social or environmental issue. Meanwhile, cultural enterprises are organisations that are underpinned by a particular artistic and cultural remit. Small and medium-sized enterprises (SMEs), including social and cultural enterprises, tend to struggle more in finding suitable premises, and therefore affordable workspace measures would support start-ups and early growth by reducing the initial fixed costs for those start-ups.
E2 - Mixed-use
Development proposals that are consistent with the principles of 15-minute neighbourhoods should be supported. These proposals, including those providing homes, should take into account the infrastructure of the Neighbourhood Area and be easily accessed by walking, wheeling and cycling from homes.
E2 - Rationale
The 15-minute neighbourhood can strengthen local economies by keeping jobs and money local, reducing car dependency and thus decreasing noise and air pollution, and improve the physical and mental health of local people (TCPA, 2021). The Neighbourhood Area benefits from close proximity to some key amenities, including GPs which have an average distance of 0.5km for people living in the area (OCSI Local Insights Profile for 'Arches Local - Neighbourhood Plan Area', November 2022). Development proposals therefore have the opportunity to further strengthen and consolidate the area's offering to meet the needs of local people.
E3 - Retail Frontages
Development proposals that involve alterations to, or the creation of, shopfronts are required to be designed with specific positive regard to the Design Code (Appendix A).
E3 - Rationale
An attractively presented, well-designed shopfront can make a positive contribution to the character and trading success of an individual business or street, as it gives a favourable impression to the business and to the area as a whole.
E4 - Healthy businesses
Businesses that harm health and well-being of the neighbourhood should not supported. Hot food takeaways must not be located within a 400m walking distance of schools.
E4 - Rationale
Examples of businesses that harm the health of the neighbourhood include alcohol outlets, hot food takeaways, payday lenders and betting shops. An overconcentration of hot food takeaways in the Neighbourhood Area was identified by Medway Council's Hot Food Takeaways Guidance Note 2014. In addition, the Neighbourhood Area partly falls within Medway Council's Cumulative Impact Policy, emphasising the issues of crime, disorder and public nuisance that derive from the area's high concentration of licensed premises. Part of the Neighbourhood Area also sits within the Chatham Alcohol Control Zone due to alcohol related anti-social behaviour issues affecting community safety and the local environment.
The Neighbourhood Area has higher cases of obesity among children and adults, and uptake of smoking is than the averages of Medway and the South East, whilst healthy eating levels (consumption of five or more portions of fruit and vegetables a day among adults) are lower than these areas. Furthermore, our Neighbourhood Area ranks poorly against Medway's averages in every category of general health and limiting long-term illness (OCSI Local Insights Profile for 'Arches Local - Neighbourhood Plan Area', November 2022).
Policies - Community Spaces
CS1 - Safeguarding existing social infrastructure
The neighbourhood forum has identified several sites and buildings which should be safeguarded for community use, including:
- Magpie Centre and Community Cafe
- St Paul with All Saints Church
- Luton Invicta Club
- Jesus Revival Ministries International
- Kent Islamic Centre Mosque
- Muslim Community Centre/Naseemia Shamimia
- Goodly Speak
- The Redeemed Evangelical Church of Christ
- Chatham Education and Cultural Centre
- Richard Cobden Irish Pub
- Kings Theatre
- The Temple of Light Spiritualist Church
- Shipwrights Avenue Multi-use Games Area (MUGA)
Development that improves these sites will be supported and those that lead to the loss of community spaces will be rejected, unless it can be demonstrated that any of the following conditions can be met:
- There is no existing or future need or demand for such uses, including reuse for other community services locally, and adequate alternative accommodation is available to meet the needs of the area.
- Replacement facilities are proposed on or off site of better functionality to serve the needs of the area.
- Where diversification through the inclusion of additional uses can sustain the existing community space.
Consideration should also be given to how best to protect assets against the effects of climate change.
CS1 - Rationale
The Neighbourhood Area experiences poor community and civic infrastructure, relative isolation and low levels of participation in community life. The Community Needs Index (Oxford Consultants for Social Inclusion & Local Trust, 2019) concluded that the Neighbourhood Area demonstrates by a high level of community need, which is valued at 103.1% - while the South East's is 60.8%. The research also found that the Neighbourhood Area scores very poorly for the presence of civic assets, which includes community spaces and libraries, at 6.1% - the score for the South East is 22.1%
CS2 - Provision of sports facilities and play spaces
Development proposals must include, or contribute to, the provision of sports facilities and outdoor play spaces where justified. Proposals for appropriate new facilities will be supported. These facilities should be easily accessible by walking and cycling and serve the widest range of community interests. Material choices for play spaces and sports facilities should be made with the cost of future maintenance in mind.
CS2 - Rationale
There are only three sports facilities and play spaces in the Neighbourhood Area - these being at Luton Millennium Green, Town Hall Gardens and Shipwrights Avenue MUGA. Providing sports facilities will encourage residents - particularly children and young people - to take part in physical exercise, thus improving their health. It is also crucial to create safe play spaces for children, as many of the schools in the area do not have outdoor facilities.
In accordance with Play England's Design for Play Guide, quality play spaces should:
- be bespoke
- be well-located
- make use of natural elements
- provide a wide range of play experiences
- be accessible to both disabled and non-disabled children
- meet community needs
- allow children of different ages to play together
- build in opportunities to experience risk and challenge
- be sustainable and appropriately maintained
- allow for change and evolution.
CS3 - Improving Green Space
Where justified, development proposals will be expected to include improvements to the provision of green spaces within the Neighbourhood Area. This could include the following measures:
- Improving signage and wayfinding interventions to improve pedestrian access.
- Linkages to other green spaces through the creation of linear parks and tree-lined, green corridors that both encourages ecological connectivity and opportunities for active transport.
- Ensuring biodiversity net gain my supporting planting of both trees and other natural vegetation.
CS3 - Rationale
Friends of the Earth scored the Neighbourhood Area a rating of D and E, which means the neighbourhood is among the most deprived of green space, including gardens and parks. Furthermore, Public Health England in "Improving access to greenspace - A new review for 2020" identifies "that older people, those in poor health, with a physical disability, of lower socioeconomic status, ethnic minorities, and those who live in deprived areas â€“ continue to use greenspace less often and so continue to have less opportunity to benefit from it."