2.14.1 The draft Local Plan states "[t]he integration of land use and transport planning has an important role to achieve net zero. In short, the planning of new development needs to shift from a mitigative to a creative approach, i.e. leading with a vision". However, the draft Local Plan does not put this in to practice when considering the proposals for the Chatham Docks site. Rather, it is inconsistent when proposing land uses at the Docks which do not require access to the water and would not make use of water-based means of transport, and which would force existing businesses which use water based transport for bulky industrial products to relocate. We submit that residential uses could be located in a large range of areas, without any particular need for proximity to water or a dock which would cease to be operational if residential uses replaced existing businesses. The draft Local Plan has failed to grapple with the importance in transport terms, among others, when proposing residential redevelopment.
2.15 Carbon impacts of transport
2.15.1 Whilst the draft Local Plan acknowledges that "[t]he levels of change required are unprecedented and equate to an 80 per cent reduction in carbon emissions from surface transport by 2030" there is a failure to protect the current low carbon means of transport by continuing water-based uses at Chatham Docks. The draft Local Plan does not assess the loss of the non-tidal docks and their importance for industries relying on water-based transport, with consequent carbon consequences. Current and future operators at the Chatham Docks who use water-based transport for materials and products would have to relocate and instead use road-based means of transport, potentially over longer distances, producing more carbon at a time of acute concern about the environment, and contrary to other statements in the draft Local Plan itself regarding net zero. In ArcelorMittal Kent Wire's case, were the docks to be redeveloped, they would likely be forced to relocate overseas, with products supplied to the South East travelling much longer distances with connected carbon consequences
2.15.2 We consider this failure to be material, in particular in failing to consider downstream carbon consequences contrary to the UK's transition to low carbon future pursuant to NPPF paragraph 8.