2.13.1 There are superficial references to the use of waterfront site for regeneration and tourism aims, without proper consideration of the unique locational characteristics of Chatham Docks. Due regard is not had to properly identifying sites for commercial development which meet the needs of a modern economy, pursuant to paragraph 84(b) of the National Planning Policy Framework and the amendments proposed to it. Further, this policy does not take into account the proposed amendments to paragraph 85, in particular the recognition of the importance of decarbonisation and reliability in the supply chain. The draft Local Plan fails to engage with these emerging national requirements. Draft Policy S14 identifies Chatham Docks as a site where "locally distinct clusters of cultural facilities, venues and related creative uses" will be supported. This policy clearly indicates a failure to engage with the significance of the non-tidal docks and the opportunity they provide for businesses who require access to water and cannot easily relocate, or in fact be accommodated elsewhere in the region. Further, there is no balancing of the carbon impact of losing water-based means for industrial sites. There is no detailed assessment of the current uses and the likelihood of a cluster of cultural uses being successful or even likely here. The policy does not appear to be based on any more detailed assessment than an assumption that cultural facilities near water would be visually attractive, without recognising the unique facilities from a carbon and industrial perspective which would be lost. The sustainability appraisal does not grapple with this at all, in a clearly inadequate manner.
2.13.2 This is contrary to National Planning Policy Framework paragraph 86(b), which requires planning policies should "set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period". Instead, a rather superficial approach appears to have been taken.