It is CPRE Kent’s overall view that the strategic objectives are largely positive with a strong emphasis on the need to conserve and enhance the natural, built and historic environment, which aligns with CPRE Kent’s goal of protecting the countryside. However, it is important that these objectives translate into firm actions and policies that prioritise the environment over development.

For example, whilst the Plan talks about improving transport networks, it should also consider the impact of transportation infrastructure on rural areas. Building more roads will lead to increased car dependant development and urban sprawl in rural areas, which can negatively affect the countryside.

This is a particular concern that we have with respect to the Hoo Peninsula, as made clear within our responses to the various HIF related consultations we have previously participated in and our 2023 Regulation 18 comments.

While we support the aspiration for high-quality homes that genuinely meet the housing needs of Medway, it is our view that there should be a far greater emphasis within the strategic objectives of redeveloping brownfield sites over greenfield sites.
We welcome the placement of delivering the Council’s commitment to the Climate Emergency at the top of the proposed strategic objectives. However, we would like to see this expanded to include meeting the ecological emergency.

In this regard, it is CPRE Kent’s view that the countryside itself can provide many of the solutions to tackling climate breakdown and the ecological emergency, while supporting rural communities and economies to thrive. Development should meet local need, while contributing to efforts to mitigate and adapt to the climate emergency.

Sustainable development needs to be redefined to focus on living within environmental limits and the importance of addressing the climate emergency. At the national level, CPRE is campaigning for all new development to demonstrate a net negative carbon footprint, and for all plans and infrastructure programmes to demonstrate how they will achieve a reduction in total road transport, not just the need to travel, and that climate action is a key test of soundness in the examination of all development plans.

We therefore consider that the new local plan will need to give ‘positive discrimination’ towards the environment by giving clear priority to policies which seek to mitigate climate change.

For Medway, fundamental to this will be ensuring that the overall strategy for the local plan is firmly focused upon optimising the recycling of land that has already been used for buildings by adopting a truly ‘brownfield first’ strategy. This will need to be put at the forefront of developing the Plan, so that it is clearly reflected within each of the Plan’s objectives.

Alongside this, we would expect to see ring-fencing of all environmental measures within the local plan viability appraisal as being non-negotiable fixed costs. This should include the need for all new-build residential development to be designed to achieve zero carbon homes, with a requirement for detailed carbon assessments demonstrating how the design and layout of the development has sought to maximise reductions in carbon emissions, a water efficiency standard of less than 100 litres and ensuring significant improvements in the dwelling emission rate over the target carbon dioxide emission rates.

We would also expect to see proactive policies that increase the area of habitats that sequester and store carbon and those which support projects for retrofitting existing building stock. Again, this will need to be clearly reflected within the objectives of the Plan.
Overall, the proposed objectives show a commitment to environmental sustainability, but it's essential to ensure that these objectives are effectively translated into precisely worded policies and actions that prioritise the protection of the countryside and its unique ecosystems. Furthermore, robust monitoring and enforcement mechanisms should be put in place to ensure that development does not come at the cost of rural landscapes.