Full text:
The RSPB understands the pressures of national targets on housebuilding in Medway, and that the HIF funding has been revoked, requiring the Council to re-examine a broad range of potential locations for development across the area. This includes assessing what level of housing can be sustainably delivered across the Hoo Peninsula given the impact of the withdrawal of this infrastructure funding. We believe this is an opportunity to reassess development needs and options and to ensure development is located in the most sustainable locations, to establish a truly sustainable strategy for the long term. We welcome the steps the Council has taken to reassess potential development sites via the Stage 1 Land Availability Assessment (LAA), the broad results of which are presented in the draft local plan consultation. It is critical that a Sustainability Appraisal (SA) of these sites is undertaken (individually and cumulatively) in order to properly understand the relative impacts of new development in the broad locations shown. This would require an evidence base for site allocation. We have serious concerns that this updated SA is not yet available for review. Given the Government guidance on the need for the SA to be undertaken iteratively and to allow assessment of reasonable alternatives to any preferred option, we anticipate that the Council will need to undertake a further consultation including this important assessment work ahead of the Reg 19 consultation, to avoid risks of the final submission draft being found unsound. We request confirmation of the Council’s intention to carry out a consultation on a revised SA well in advance of a future Reg 19 consultation.