The primary consideration in delivering a sustainable spatial strategy should firstly focus on brownfield redevelopment of the riverside and town centre. It is agreed that the support for High Streets and urban regeneration should underpin the whole strategy and this is fully supported by F D Attwood and Partners subject to the following caveats which relate to the housing capacity yield from development in this area including ;
• The historic character of the riverside has to be preserved and part of the character for this area derives from the mix of uses including employment. The document rightly acknowledges heritage value in the vision and objectives and the role of this area for tourism (see paragraph 4.2) should also not be underestimated. These factors will influence estimates of housing yield that is deliverable within the plan period.
• As well as the need to preserve the character of the area as outlined above, there are also viability considerations which need to be taken into account in this area and the likelihood that these sites may only be delivered by high density apartment construction which will not deliver a range of housing and are also subject to greater market sensitivity, that in turn affects housebuilder interest and deliverability.
The principle of adopting a sequential approach to the spatial strategy that focuses on brownfield riverside development and urban regeneration is supported but for the reasons outlined above, there must be caution in the net capacity of these areas to meet the housing need and the timescale to delivery and for this reason, we support the riverside being a component of a suite of spatial options.
As part of the sequential spatial approach, the next favoured option in terms of sustainability benefits, should be the suburban extension choices which, as previously highlighted (if planned comprehensively alongside infrastructure), would also benefit the existing urban areas adjoining these areas and in this case, could provide certainty to the whole of the Capstone corridor length.
The opportunity of a comprehensive masterplanned approach to link the existing planned building blocks within the Capstone Corridor, including Lidsing Garden Community (2,000 dwellings), Gibraltar Farm (450 dwellings) and East Hill (800 dwellings), which are also within the control of the landowner, offer a unique opportunity to deliver a wide range of planning benefits from this spatial option which places Capstone as a suburban extension ahead of the suburban alternative of Rainham which has:
• Greater acknowledged highway congestion and air quality issues on the A2 and road network around it;
• Is of a higher agricultural land value;
• Is part of a strategic gap between Rainham and Newington;
• Lies in closer proximity to the Medway Estuary SPA and its setting.
As part of a sequential approach, it would only be in the event that Medway Council cannot deliver road, open space and community/utility infrastructure alongside biodiversity enhancements to support growth in the suburban areas (alongside riverside growth), that a new community on the Hoo Peninsula should be considered as a third option, with its more limited objective to create a self-contained community in a non sustainable location.
The past ‘driver’ of LPA decision making which favoured Hoo vis a vis the Capstone Corridor (aside from the HIF Funding for infrastructure), was a perception that development in the Capstone Corridor would erode the character of the valley and its function as a green lung for the existing urban areas around it. However, successive Inspector’s (for local plan and Section 78 appeals) have disagreed with this assessment and now these planned developments can provide building blocks of a new comprehensive vision for the whole of the corridor integral to which will be green infrastructure and biodiversity enhancements that links with the surrounding communities.
Whilst the local plan evaluates objectively all spatial options to deliver the vision and agreed strategic objectives, FD Attwood and Partners consider that an alternative high-level assessment of character impact should now be utilised, which is very different to that adopted in the past in order to drive spatial decision making. This new approach is justified because it is acknowledged throughout the plan that the character of Medway on the headland, to the north of the river Medway, is very different. Whilst large new country parks have previously been offered to mitigate the impact of major growth on the headland, the siting of major development in this area will comparatively affect to a greater degree, the more remote character of this part of Medway ( which is recognised at paragraph 5.36) and is also more environmentally sensitive (protecting natural assets is recognised at paragraph 4.2 and 5.10) and important to tourism and the character of Medway in its totality as an administrative area.
For these reasons, it is asserted that, in the consideration of spatial options, major scale development on the headland should only be considered as a spatial option in the event that the suburban growth option is discounted for the reasons outlined above. Major growth at Hoo, even if it could address road capacity, rail connectivity and environmental impact considerations, is not as well placed as other spatial options to support the High Street, create more inclusive and connected communities that address current inequalities, or support tourism. The principal vision and strategic objective of major growth at Hoo is to make it “self contained” to boost its sustainable credentials and rely on the fact that it is likely to be the subject of less public objections, because it is located well way from the main populace of Medway. For these reasons, in terms of delivering the supported vision and strategic objectives, Hoo represents a third-tier option.
The Reg 18 Document at paragraph 5.41 when referencing Hoo specifically asserts that;
“Such development could also help to meet the Council’s ambition for greener growth with higher environmental standards in construction, communities better connected for walking and cycling and within easy reach of local services.” This assertion is strongly contested by F D Attwood and Partners for the reasons explained in this response.
The option of the Green Belt release in line with national guidance should be weighted a “last resort" spatial option. The fact that the Green Belt occupies only 2% of the land area of Medway; performs an important strategic function in preventing the urban sprawl of Strood and Higham and Snodland and Halling; and in addition to this, is designated as AONB, provides national recognition of the landscape quality of this area as well as its spatial GB functionality. As part of a sequential approach, this option should only be examined further when it is proven that the other spatial options cannot be delivered.
The technical work of FD Attwood and Partners can demonstrate that:
• Comprehensive masterplanning and delivering of infrastructure;
• Mix of uses;
• Quality of development including SUDS and other technical issues;
• Transport benefits and access considerations can be delivered; and
• Landscape open space and biodiversity linkages, particularly with the Capstone Country Park hub.
These matters can be fully addressed without the need for public funding and will also benefit the existing local communities and provide community cohesion.
At Para 5.35 of the Regulation 18 consultation document, there is recognition of the cross-border impacts and the fact that early masterplanning decisions via the Lidsing SPD document, will be starting to be made shortly. As highlighted earlier, we see this as an opportunity for better masterplanning output through collective working and cooperation between the Attwood family, Medway Council, Maidstone Council and Kent County Council across the entirety of the corridor including Lidsing.