CPRE Kent welcomes the proposed development strategy in so far as it prioritises regeneration, makes the best use of previously developed land and directs investment to urban waterfront and centre opportunity areas.

However, we cannot support a strategy that places such significant reliance on greenfield sites (on the Hoo Peninsula).

As set out in our comments on the 2023 Regulation 18 consultation we are concerned that the Council’s strategy has been dictated by the sites submitted by developers (as part of the Land Availability Assessment).

It is CPRE Kent’s view that this is a flawed approach to plan making as, consciously or subconsciously, it places too much influence in the hands of developers who will naturally prioritise their financial interests over the genuine needs of communities.

In this respect, such an approach inevitably leads to a strategy heavily weighted towards greenfield sites. The reason for this is it is greenfield sites that are almost unilaterally promoted by developers, as it is these sites which give the greatest profit.
Such undue reliance upon developer submitted sites inevitably leads to a haphazard spatial strategy that lacks a cohesive, long-term vision. This in turn neglects important aspects such as sustainable infrastructure, environmental considerations, and the social wellbeing of residents.

A far more effective approach would be for the Council to take firm ownership of the direction of the spatial strategy and then proactively identify potential development sites to deliver that strategy.

As set out below, this could include targeted call for sites. The spatial strategy needs to be grounded in comprehensive, evidence-based planning that prioritises the environment (and identifies the positive qualities and placemaking benefits of ‘constraints’ to the environment) and the wellbeing of both current and future Medway residents, rather than short-term developer interests.

It is our strong view that such an approach would naturally lead to a true “brownfield-first” spatial strategy, spearheading the regeneration and improvement of the Council’s urban areas. Likewise, we see significant constraints with respect to the amazing environmental and ecological features that the district is blessed with, particularly on the Hoo Peninsula.