2.16.1 Policy T21 states "Riverside infrastructure associated with the transport of minerals, waste and other defined materials will be safeguarded in accordance with national planning policy. The existing network of piers, jetties, slipways, steps and stairs will be safeguarded to support the potential for visitor and river taxi services and to accommodate visiting vessels, while any new facilities will be encouraged.".
2.16.2 This is clearly in conflict with the proposals in relation to Chatham Docks. In practice, it is the current occupiers at Chatham Docks which mean the lock gates giving access to the basin are kept in a condition that they can be opened (noting the issues caused periodically when disrepair means they cannot be opened). In a residential redevelopment scenario, there would no longer be tenants in the docks who would require and apply pressure to ensure that the lock gates were kept functional, nor pay a service charge connected to their maintenance. In the event Chatham Docks was redeveloped for residential use, we consider it highly likely the riverside infrastructure would be lost, in direct contravention of this draft policy. We understand that as well as the current occupiers who use the docks for the supply of raw materials and the export of finished materials via the facilities at Chatham Docks, the Royal Navy also have the ability to access Pool 2 via Chatham Docks, which would be prevented if the lock gates were fixed shut.
2.16.3 Paragraph 9.5.4 states "[t]he Riverside Infrastructure policy intends to reinforce Medway’s strategic location in the Thames Estuary. Ports, docks and wharfage will be safeguarded to support existing business sectors and to attract businesses requiring such facilities where feasible." We strongly agree with this statement. However, we consider that the draft Local Plan does not implement this conclusion when considering the redevelopment of Chatham Docks for non-maritime uses, in direct contravention of this draft policy. The draft Local Plan does not appear to have considered that the proposed residential led application would cause the docks to be lost for good. No assessment at all is given regarding the loss of Chatham Docks, not even one considering "where feasible" as stated in the policy. This is an inconsistent and unreasoned position.
2.16.4 There is no engagement with this issue in the sustainability appraisal.
2.16.5 We consider there are a number of issues with the River Medway Frontage Uses and Opportunities, which fails to properly consider Chatham Docks, in particular by appearing to failing to recognise the locational importance of the docks and appearing to assume Peel's redevelopment aspirations will come to pass without considering their uniqueness, omitting to fully consider the current activities at the docks, including significant increases in employment numbers, and the opportunities available for development of the industries currently operating rather than redevelopment.