1.1. We are writing on behalf of our client, AC Goatham and Son, in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.

1.2. This representation promotes a site extending to approximately 13.8 hectares on the northern side of the Peninsula Way, Hoo St Werburgh, Rochester, ME3 6QE, west of the Deansgate leisure centre and east of Homeleigh Nursery.

1.3. Historically, the site has been given the reference SO2 as part of the 2018 Local Plan Development Plan Considerations in which it was identified by the Council as “A site with opportunity for development subject to availability”. The site is and will remain available.

1.4. In 2019, the site was further considered as part of the Medway Strategic Land Availability Assessment (SLAA) 2019 when part of the site (the southern part which was then the only part promoted) was identified as “Suitable, Available and Achievable”.

1.5. In 2020 Medway Council released the Planning for Growth on the Hoo Peninsula document. This, together with land to the north of the site, identified the site’s potential as part of an opportunity area of incidental growth around “Indicative Neighbourhood centres”. The extent of this was shown on the “Opportunities” map.

1.6. The site formed part of a pre-application submission (PRE/20/2978) presented to Medway Council in early 2021 and that then proposed that the southern part of the site form a business hub. The Council’s pre-application response, dated 21st April 2021 confirmed that an employment/business could be included within the wider strategic growth plans for the Hoo Peninsula and that “this area of Goatham’s land would be an ideal location for such a development given its proximity to the transport network and vehicular connectivity”.

1.7. The site, which is owned by AC Goatham and Son provides an opportunity to provide a development site in the Hoo Peninsula rural development area. This site could contribute to the Council's substantial housing requirements within the district, especially when joined with the neighbouring sites and identified as part of the plan.

1.8. It is considered that the site provides an opportunity for additional housing and or mixed development, and hence, positive growth in the Medway area to 2040.

1.9. This representation responds to the current Regulation 18, by setting out how the site meets the aspirations and broad spatial strategy being promoted in the Local Plan, specifically in the rural area. In addition to responding to each of the headings in the consultation document, and identifying how the site can deliver the vision and objectives through sustainable development.

2. Context
2.1. The production of the Medway Local Plan has involved several key stages. Three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final Regulation 18 consultation before the publishing of the Regulation 19 draft plan.

2.2. The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

2.3. It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development, but does relay key areas where development could come forward.

2.4. This representation seeks to promote a 13.8 hectare site on the northern side of the Peninsula Way / Ratcliffe Highway, Hoo St Werburgh, Rochester, ME3 6QE, the extent of which can be seen at Figure 1 below and on the attached Site Location Plan.

2.5. This site has previously been promoted for development through the 2008 Call for Sites and more recently the 2023 Call for Sites exercise undertaken by Medway Council, the Local Planning Authority (LPA).

2.6. The recently published interim Land Availability Assessment for Medway (September 2023) does include an assessment of the site, with site reference HHH19. This document recognizes the site does not comprise “Habitats Sites”, Irreplaceable habitat” and is not an “Area at risk of flooding”. It is on this basis that the site is recognized as capable of delivering 5 or more dwellings, or economic development of over 0.25 ha and which is recommended to proceed to Stage 2.

2.7. The strategic location and size of the site provides the opportunity for the delivery of a residential scheme with potential economic development which could be developed in isolation or more strategically with the neighbouring sites.

3. Site description and history
3.1. The site is well located next to existing and proposed development in a sustainable location. The proximity of a proposed pedestrian crossing to the south further supports good connections to existing and proposed bus links, pedestrian and cycle paths, which will all link well with Hoo St Werburgh.

3.2. Allocation of the submission site would form part of the “Deangate Ridge” allocation set out within the Ho Development Framework (HDF) document, recognised as forming part of a “Vibrant and Sustainable” neighbourhood. This allocation therefore supports a logical extension of the framework area.

3.3. Historic ecological assessments that have been undertaken across the site which indicate there is no likely impact as a result of the proposal. Further investigation would be carried out as development proposals for the site progress. In accordance with emerging statutory requirements, development would also provide opportunities to achieve 10% Biodiversity Net Gain in order to provide a clear and tangible ecological enhancement over the existing baseline condition of the site. In this case, given the blue and green infrastructure opportunities identified by the Council in the immediate locality through the HDF document, it is perceived that development on this site could well exceed this.

3.4. Allocation of the site for residential development would be consistent with the objectives of the NPPF which seek to support sustainable development in accordance with the environmental, economic and social objectives. Development would make a significant contribution to each of these as set out at Paragraph 8 of the NPPF.

3.5. There are no known constraints that would prevent development of the site, and further detailed assessments would be provided to accompany any future planning application to address any perceived site-specific issues.

4. Deliverability
4.1. Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.

4.2. The Glossary of the NPPF defines deliverable and developable as following:
“Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
“Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.

Availability
4.3. AC Goatham, who own the site, have confirmed that the site is available. On this basis, and subject to its inclusion in the Local Plan, the site can become available in the first 5 years of the Local Plan period.
Suitability for Residential Development

4.4. The site is located on the main Ratcliffe Highway route, which directly accesses the Peninsula Way between the settlements of Hoo and Chattenden. It is served by good public transport services and a wide range of services/facilities. There are no perceived constraints that could not be overcome to facilitate residential development.

4.5. The site would be suitable for housing development, as a highly sustainable and logical extension to the settlement of Hoo and immediately adjacent to the Deansgate leisure centre. If the site were to come forward for a mixed residential / economic development, it could also sit comfortably with the adjoining existing and proposed site uses.

4.6. The site would form a positive approach to housing delivery in Medway. At an average 30 dwelling per hectares, often advocated in rural areas, the site could have an indicative capacity of up to 415 units; and depending on any possible allocation for economic and or retail purposes.

Achievability
4.7. Subject to the grant of necessary planning permission, the site is realistically capable of delivering development in the early phases of the Plan period. Development viability will be assessed by taking into account the affordable housing requirements, other obligations and market conditions at the time when development proposals are promoted through the planning application process. At this stage, there is no indication to suggest that there will be any viability issues for housing development on this site.