Land to west of Pump Lane, Rainham

As stated above, Redrow has an interest in approximately 24Ha of land to the west of Pump Lane, Rainham (SLAA site: RN9).
It is considered that the land has good potential as an accessible, suburban expansion site, to deliver sustainable housing development that would accord with the draft Local Plan’s Vision and Objectives. There will be some constraints to development that need to be overcome/mitigated, but that is likely to be the case, in some form or other, across the Medway Council area. In this case, it is considered that these constraints could be appropriately addressed, through well considered proposals and a criteria-based allocations, for the reasons set out below.

A high-level illustrative layout, demonstrating how a scheme could come forward at land to the west of Pump Lane, has been appended to this representation.

Availability

As Redrow have an interest in the land and are promoting the site for residential development on behalf of the landowner, we can confirm that the land is available for early delivery. Redrow would be keen to engage with officers to discuss how this land could deliver new homes in the shorter term, while mitigating environmental and heritage impacts. In the Local Plan, these could be covered by a criteria-based policy linked to an allocation of the land for housing.

Addressing Potential Constraints

Redrow are aware of the appeal decision on this site (ref. APP/A2280/W/20/3259868) - the appeal site measured approximately 50Ha, whereas Redrow’s proposed allocation is only half of this, at 24Ha.Redrow are also aware of the concerns raised in the Reg 18 draft Local Plan regarding potential development in this broad area. However, it is considered that a carefully and sensitively design scheme could address the highway capacity issues and the harms identified by the Inspector.

Highway Capacity, Sustainable Transport and Access

The appeal inspector found that the residual cumulative impacts on subnetworks 3 and 7 would not be severe, but that is not the case for subnetwork 2. The residual cumulative impacts on that subnetwork would, in her view, be severe, particularly during both the AM and PM peaks. She recognised that those impacts would be confined largely to the peak hours and that the subnetwork forms only a part of the wider network.

A Transport Technical Note (TTN) has been prepared in support of these representations. The TTN outlines the multi-modal access strategy that could be achieved should a planning application come forward on this site; considers the accessibility of the site; quantifies the likely vehicular trip generation of the proposed development; and identifies appropriate and proportionate mitigation measures. In doing so, it addresses the reasons for refusal of the previous planning application and appeal concerning the wider landholding of relevance to highways and transportation.

The vehicular trip generation and distribution exercise presented below confirms that the impact of the proposals in this regard would be much-reduced relative to the previous scheme. It is further demonstrated that ongoing shifts in travel behaviour away from traditional peak period commuting, together with both ‘soft’ and ‘hard’ travel planning measures and ‘decide and provide’ mitigation strategies, will ensure that there would be no ‘severe’ residual highways impacts, in accordance with Paragraph 111 of the National Planning Policy Framework.

The note concludes the site represents a viable and sustainable location for development in transport planning terms and that the highways reasons for refusal of the previous outline planning application can be overcome.

Landscape

The site forms part of the Gillingham Riverside Area of Local Landscape Importance (ALLI). The area is characterised by scattered dwellings/clusters of dwellings, as well as the small hamlet of Lower Twydall, which sits to the west of the site, with the small village of Lower Rainham, which straddles the Lower Rainham Road to the northeast. Both settlements are designated Conservation Areas. Beyond the railway line, to the southwest, is the urban settlement of Twydall/Rainham with shops, services and good public transport links. To the north, east and west, the site is surrounded by agricultural land which extends up to the Medway Estuary. The Medway Landscape Character Assessment (MLCA) recognises that the Lower Rainham Farmland Character Area (LRFCA) identifies the area has value as an extended buffer to the Country Park and protected Estuary coastline, which lie to the north.

The Planning Inspector regarded the change in character as ‘distinct and abrupt’, as opposed to it being an area of ‘transition’ between town and country. The Inspector also noted that the development would, as a matter of fact, comprise a ‘significant and large scale development’. As such, she was of the view that the development proposed would be uncharacteristic and of a significant scale.
However, the Inspector noted that the site is generally well contained by mature vegetation, including woodland and tall hedgerows, limiting available views and extent of visibility. She also noted that the landscape effects would be experienced from a relatively constrained area around the site. It would, therefore, be possible to reduce the impact on the landscape with a less significant scheme for the site, that was designed to be more transitional - with pockets of development with an enhanced framework of landscaped breaks and buffers. A landscape led proposal (as shown on the attached plan appended to this representation) for the site could provide an attractive setting to the Lower Rainham and Lower Twydall Conservation Areas, with attractive views from the river and railway, forming a green backdrop in views from the Estuary.


Pump Lane

As an additional concern, the Inspector noted is that Pump Lane is an unlit, narrow, sometimes single-track country lane with no footways. Towards its northern end, it is fronted on one side by a small group of dwellings, but for the most part, it is lined along both sides with mature hedges/hedgebanks. She added that it is identified as a rural lane by policy BNE47 which, among other things, seeks to protect the landscape value of such lanes.

The Inspector went on to note that, for the appeal proposal, four new junctions were proposed on Pump Lane to facilitate its crossing by the proposed estate loop road and, in total, the new junctions on Pump Lane would require the removal of around 175m of hedgerow. The layout of the southern junctions would require any replacement planting to be set back significantly to allow for forward visibility and, at that point, the lane would cease to be narrow and it would no longer be enclosed by hedgerows. She therefore concluded that the highway would have the character and appearance of a residential access road, as opposed to a rural country lane.
However, on review of access proposals to the land, it is considered that there only needs to be a relatively small incursion on Pump Lane, at the southern end, to allow for emergency access, pedestrians and cycles to access the facilities to the south of the railway line. As such, that should not be a constraint to development and should be regarded as a benefit.

Heritage

The Inspector considered the extent of the development proposed would effectively subsume the village of Lower Rainham, and its Conservation Area, into the extended urban area of Twydall/Rainham, with the consequence that it would lose its separate identity and character as a rural village.

The Inspector found that there would be harm towards the middle of the less than substantial range to the special interest and significance of the grade II listed Chapel House, and to the heritage significance of Lower Rainham Conservation Area, with harm identified to other of the designated assets to be at the lower end of the scale. Any harm to the significance of the non-designated Bloors Oasts would be very minor.

Overall, the Inspector concluded that the very substantial benefits that would arise from the appeal scheme, primarily the delivery of much needed new homes, to be sufficient to outweigh the heritage harm identified both individually and collectively. A smaller, well design scheme could avoid any heritage harm.

Conclusion

Overall, it is proposed that a high quality, sustainable housing scheme, delivering policy compliant affordable and family housing to meet short term needs, that would meet the Vision and Objectives for the Local Plan could be achieved on land to the west of Pump Lane, Rainham.

We trust that these representations will assist in ensuring sustainable and deliverable development within Medway to help meet the Council’s vision and strategic objectives as set out in the Regulation 18 Local Plan.