2.1.1 Neither the draft Local Plan nor the supporting documents provide any reasoned conclusions for the redevelopment of Chatham Docks away from strategically significant steel manufacturing. The identification of Chatham Docks as an indicative residential-led development site is not explained. There is no indication that the Council have considered the spatial and location uniqueness of the docks, nor the consequences of redeveloping them as homes in the draft Local Plan or supporting documents. This is an inadequate approach to the loss of the last non tidal dock in the South East, with a failure to properly grapple with, or consider at all the particular features of the site in determining its future use. The draft Local Plan does not consider the impact on the UK construction industry, the carbon impacts of losing a facility for water based transport and replacing it with road based transport, the loss of skilled jobs. There is only a superficial assessment of the economic impact, a lack of proper consideration of the unique features of the docks, and a flawed employment land assessment. There is no analysis which allows a comparison of all of the relevant sustainability effects to assess the replacement of a key industrial facility, that of ArcelorMittal Kent Wire, with a housing led development. Further, there is no assessment of the "net" position where ArcelorMittal Kent Wire's operation is lost from Chatham Docks and replaced by a housing led, light industrial scheme.
2.1.2 The draft Local Plan states in its strategic objectives that growth will be directed to the most suitable locations. We submit the strategic objective itself is too vague to serve its purpose – it is unclear what it would or would not justify and therefore is not a proper basis for alternative testing or assessment of soundness. Further, as detailed in our representations, in relation to employment, critical economic infrastructure, and lack of proper alternative testing, the strategy would not put the growth in the most sustainable places.
2.1.3 There is no assessment of the proposal for the residential led redevelopment of Chatham Docks. One of the supporting documents, the Chatham Docks Employment Report, considers the economic impact of a mixed use redevelopment of Chatham Docks but in a superficial way without proper consideration of construction industry wide impacts from the loss of UK production of essential steel products. Further, it does not explain its conclusion regarding the viability of Chatham Docks, relocation costs and the use of agency staff. Noting the very widely drawn strategic objective, the Council has so far failed to produce (or rely on) any evidence which properly appraises the pros and cons of the two visions for the Site.
2.1.4 If Chatham Docks were redeveloped as a residential led development, ArcelorMittal Kent Wire's operation at Chatham Docks would be lost, alongside the businesses of other operators and the potential for future dock-based enterprises. ArcelorMittal is the world’s leading integrated steel and mining company, with a presence in more than 60 countries, and the largest operator at Chatham Docks. Through their operation at Chatham Docks ArcelorMittal Kent Wire is a major supplier of steel products essential for construction, including 30% of Britain’s reinforced concrete steel supply.
2.1.5 ArcelorMittal Kent Wire's landlord, Peel Waters, has submitted a planning application for the redevelopment of the southern part of their site. The application is currently the subject of an article 31 Holding Direction, noting the significant impacts for the British economy were the redevelopment to go ahead, with the loss of a significant part of the British steel market including products essential for construction, as detailed further above. This is issue that is not considered at all in the identification of Chatham Docks as a residential led site.
2.1.6 In addition to flaws in the consideration of the loss of Chatham Docks as a strategically important non tidal dock for transhipment and manufacturing, we note that the Council's Draft Viability Assessment, whilst containing some propositions we do not agree with including on housing delivery, finds that the residential redevelopment of Chatham Docks does not generate positive values.
2.1.7 ArcelorMittal Kent Wire strongly supports the Council’s ambitions for boosting jobs and investment in Medway in the draft Local Plan - particularly in considering the future of Chatham Docks.
2.1.8 Chatham Docks is a 400-year old commercial port and is a vibrant, working dock operating 24 hours a day, seven days a week. The docks employ over 800 people – many of whom are local. There are also existing jobs in the supply chains. Overall, there are over 2000 jobs dependent on the docks.
2.1.9 To enable ‘all people’ to ‘thrive’ Chatham Docks must be both supported and protected in the draft Local Plan. The draft Local Plan must strike a balance in identifying new sites for housing but not to the detriment of existing jobs and existing important employment generating uses
2.1.10 ArcelorMittal Kent Wire notes that ‘Medway is a leading economic player in the region’. Therefore, future housing development in Medway must not be at the expense of existing viable employment generating sites.
2.2 NPPF
2.2.1 We consider that the draft Local Plan is not in accordance with paragraph 11 of the National Planning Policy Framework (the NPPF), stating:
"Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
(a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects"
2.2.2 As detailed further, we consider that the draft Local Plan is flawed in failing to consider the development needs of the area, and the nation as a whole, in promoting the redevelopment of ArcelorMittal Kent Wire's facility, severely impacting the supply of essential construction materials. The impact of this is not weighed in the plan nor the sustainability appraisal. There is a failure to align the housing growth needed, with at a basic level the infrastructure needed to supply to relevant building materials. There is further a lack of consideration given to the loss of an industrial site uniquely situated on a non-tidal dock, which allows lower carbon water-based transport, and the consequent green house gas emission consequences from instead moving products longer distances and with greater reliance on road based transport.
2.2.3 In addition, we do not consider the draft Local Plan is in accordance with "building a strong, competitive economy" section of the NPPF, nor the amendments to the relevant sections the Government is currently consulting on. Clearly, the proposed residential redevelopment of ArcelorMittal Kent Wire's facility does not "help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development". The proposal puts at risk the whole of ArcelorMittal Kent Wire's operation at Chatham Docks, which will likely have to leave the UK if the redevelopment goes ahead, and so clearly preventing any investment in the meantime. There is a failure throughout the draft Local Plan to recognise the impact on wider economic growth, where a key producer of the steel products needed for construction would be lost to the UK.
2.2.4 In particular, the draft Local Plan does not properly identify sites for commercial development which meet the needs of a modern economy amendments, pursuant to paragraph 84(b), further demonstrating the inadequacy of the sustainability appraisal in considering alternatives, as set out further below. As detailed previously, AMKW's materials have been pivotal in high-profile, nationally significant infrastructure projects, clearly demonstrating their role in meeting the needs of a modern economy. The importance of the land use AMKW relies upon, supported by the NPPF, is not reflected in the draft Local Plan.
2.2.5 Further, the draft Local Plan does not pay sufficient attention to the proposed amendments to paragraph 85, in particular the recognition of the importance of decarbonisation and reliability in the supply chain. Chatham Docks, by virtue of its location on a non-tidal dock, is able to use water-based transport. Were the site to be redeveloped for residential led development in accordance with the draft Local Plan, the new occupiers would not make use of that water-based transport. The option to use water-based transport would be lost forever. AMKW have sought to identify alternative sites but have concluded they would likely need to relocate outside the UK. This would have both carbon consequences, as materials would need to be transported longer distances, and likely with more reliance on road-based transport, and also on supply chain security. If AMKW were forced to close, the 30% of Britain's reinforced concrete steel would instead have to be supplied from elsewhere.