Prepared for a sustainable and green future

At 6.3 it is advised that ‘Establishing a vision and strategic objectives will help to select sites for allocation’. The AONB Unit therefore considers it is essential that the importance of the AONB as a nationally designated landscape and the Government’s policy for AONBs as set out in the NPPF at paragraphs 174, 175 and 176 is properly reflected in the Vision and Objectives. We consider the strategic objectives should differentiate between undesignated and designated landscapes, in line with the requirements of the NPPF and an objective to be included promoting the conservation and enhancement of this nationally protected landscape, which is afforded the same protection in planning policy as National Parks. As currently worded, there is no mention of landscape at all within the objectives, just a generic refence to the natural environment. In excluding this as a strategic objective, we are concerned that it does not demonstrate that the Council has met its legal duty under Section 85 of the CRoW Act 2000 to have full regard to the purposes of conserving and enhancing the natural beauty of the AONB.

Air quality has been an issue in Medway for many years and I have not seen any actions being taken - the local plan needs to be clear on what actions will be taken and by when. If you are going to develop on Hoo Peninsula then the air quality on Four Elms needs to be addressed before any more housing is introduced.

Trains and buses have cut down their timetable since covid. Even going to and from our capital city, trains stop running around 11pm. It's also expensive and poor value for money. Importantly, especially with strikes and delays, etc, it can't be relied upon. None of these things promote the use of public transport. Recycling needs to be made easier for residents. Many plastics used by supermarkets can't be recycled at home. It would be easier to allow residents to put everything recycleable out in 1 or 2 bins and people employed to sort through it back at the depot.

Would like to see renewable energy (preferably community owned) mentioned here. We need to incoporate identifying land for renewable energy e.g. onshore wind farms to ensure that planning permission is granted for such schemes. The Local PLan should be a net zero plan. The plan should recognise how the climate and nature crises are interlinked and addressing these is crucial for the well-being of Medway residents -everything should be done through the lens of achieving net zero, protecting and enhancing nature and reducing inequality.

We need to make sure public transport is acceptable on all new developments. As an example, Otterham Park Development does not have sufficient public transport. The 132 route could be diverted at night to go down and stop at Otterham Quay Lane leading to the A2.

I would have expected to see some reference to energy transition how this is accounted for within the plan. By 2040, with no further backpedaling, there will need to be substantial infrastructure for electric buses and wider use of more affordable electric vehicles. To meet the challenges ahead it can’t just be more houses and more of the same. Where is the vision to accompany the new world we face and how will organisations like Southern Water step up to the implications of massive increase in housing. They need to be partners in this or it will be Brown Medway.

Again, I refer back to the insane plan to cover the Capstone Valley in modern slum houses. Once this genuinely beautiful green space and haven for wildlife and greenery is gone we never get it back.

How can you address a climate emergency when you plan to build on the 'green lung' that is Medway's farmland and semi-rural areas?!

Building on the low lying soak away land will cause issues, where does the water go?? Our rainfall is increasing with more extreme weather.

To deliver proper infrastructure to support the EV revolution from 2035 too.

Recognition of importance of salt marshes as carbon sinks and co2 sequestration, funding should be made available to support salt marsh restoration.
Cycle lanes and walking routes should be part of every housing development to encourage less car use

Paragraph 119 of the NPPF sets out that ‘planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living
conditions’.
It is set out in the current consultation that “The role of the Local Plan is to plan positively for the development and infrastructure that the area needs, whilst conserving and enhancing the natural, built and historic environment”.
In order to deliver the Local Plan, it is proposing that the plan is set around strategic objectives. “The objectives will feed into the wording of policies and how sites and different locations are assessed for potential development.
The objectives are presented around broad themes for the environment, communities, economy, and investment in
infrastructure and design that is fit for the future”. This representation supports the use of objectives to deliver the strategic aims of the plan, but wishes to raise the following comments regarding the individual objectives

This objective is supported.
This representation promotes the use of the suburban expansion option, amongst others, as a way that could deliver a sustainable and green future for Medway. The use of suburban, and rural extensions will bring forward opportunities to support sustainable communities and a future sustainable transport network. It will also enable the wider and strategic aim of supporting a green and blue framework for better connectivity for wildlife and improve the quality of lives for residents within.

NHS Kent and Medway Integrated Care Board (“The ICB”) supports the Council's commitment to addressing the Climate Emergency. The links between health and climate change are well documented as are a population's healthcare benefits that are delivered from active travel, greater access to safe green spaces, improved air quality and better standards of housing. The ICB and Medway and Swale Health and Care Partnership will work closely with Medway Council through the Local Plan development process to deliver a sustainable, greener and healthier future for the population of Medway.

Please consider Green Laning / use of Byways Open to All Traffic for vehicles in your planning. Some people enjoy this activity.

For residential properties, please ensure that the build reflects the climate emergency and ensure that all new property is Eco-efficient. At the very least, they should be efficiently insulated and, if possible, have solar panels. Retro fitting inefficient property is wasteful and expensive. Pot holes are a bane on residents. They are repaired but many fail again too quickly. Highway maintenance contracts must ensure that work is undertaken to the required standard and recent repairs should be inspected to meet this standard; if not, the contractor should be required to undertake the work again at no cost.

The council do not seem to care about green spaces by allowing more and more houses to be built on the Hoo peninsula with no new infrastructure being installed eg no new domestic water supply, no new sewage or drainage systems and worst of all no new road system as it is a well known fact that the A228 on the peninsula is over capacity now so why make it worse.

Agree with the principles but feel better enforcement of environmental issues, fly tipping, fire hazards where inappropriate items are in storage.

There is a desperate need to improve the road infrastructure between the A2/M2 junctions and junction 4 on the M20. Currently any disruption on either motorway results in traffic accessing the A228 via Cuxton and Cobham villages. This was illustrated only this week with a fuel tanker fire on the M20.
CHR13
The adjacent land
- assessed as “Unsuitable due to landscape impact, including setting of AONB” (Appendix 3: SLAA 1068).
- lies within an Area of Local Landscape Importance (ALLI) known as Cuxton Scarp Foot.
- lies within the Strategic Gap identified in the Medway Local Plan 2003 “3.4.97

I agree with the overall strategic objectives, emphasising constructing flood defences and not building on flood plains around the Hoo Peninsula. All available fields should be used for modern sustainable agriculture and food production to feed local people.

The current lack of EV chargers in car parks, in local streets, lack of UTC network to control the traffic coming into the town. Lack of air source heat pumps in new housing; Requirement for Planning permission for EV's on or off road parking delays their introduction. The change from traffic impacts of:-

Predict & provide to Decide and Provide requires a change in the production of any Transport related reports. Medway will have to provide a son of Cil report that addresses this change in Policy. The NPPF Sept 2023 has still to be changed to accord with this.

Referring to transport network, the A228 from Cuxton to Peters Bridge is already under stress, with even 3 times weekly blockages causing a rat run through the narrow Halling High Street. There should be no more development leading to increased traffic volumes along this section of road which is also already dangerous for cyclists and has narrow pavements and includes the acknowledged dangerous junction of Bush Road, Cuxton onto the A228. Similarly the Lower Rainham Road is narrow and already has high traffic volumes and further housing development should be ruled out along there.

Currently when there is a high tide Strood & Pentagon floods. What is the mitigation for this?
The bus services are a farce. The National Bus Strategy outlines options other than the failed current model.
The cycle network is a joke.
Pedestrians are in danger on Chatham & Giilingham High Street.

Many roads in the more rural areas of Medway are narrow and to improve and encourage walking and cycling would mean widening them . This surely would entail purchasing land to do so perhaps compulsory and more expense.

The answer to tackling climate change lies PARTLY in providing clean, reliable public transport. This is seriously wanting in Medway. We are a long, way off getting people out of their cars, myself included. Cyclists have to negotiate pot holed roads, train travellers are at the mercy of unions. Many cycle lanes popped up during Covid and some are positively dangerous. And many, unused. The one opposite Dock Road's Gun Wharf being a good example. Narrowing car lanes to provide a cycle lane just won't cut it I'm afraid.
And how green is it to allow development on greenfield sites?

6.1. Paragraph 119 of the NPPF sets out that ‘planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions’.
6.2. It is set out in the current consultation that “The role of the Local Plan is to plan positively for the development and infrastructure that the area needs, whilst conserving and enhancing the natural, built and historic environment”.
6.3. In order to deliver the Local Plan, it is proposed that the plan is set around strategic objectives. “The objectives will feed into the wording of policies and how sites and different locations are assessed for potential development. The objectives are presented around broad themes for the environment, communities, economy, and investment in infrastructure and design that is fit for the future”. This representation supports the use of objectives to deliver the strategic aims of the plan, but wishes to raise the following comments regarding the individual objectives:

Objective: Prepared for a sustainable and green future
6.4. The objective to support action against climate change and a sustainable future for Medway is supported. This actively meets the aspirations of paragraph 153 of the NPPF which sets out that ‘Plans should take a proactive approach to mitigating and adapting to climate change’.
6.5. This representation promotes the delivery of sites in the rural area to help deliver 14,736 homes as a way, amongst others, that could deliver a sustainable and green future for Medway.
6.6. Paragraph 5.41 of the Regulations 18 consultation, sets out that “large scale development around Hoo St Werburgh and neighbouring villages could provide for planned growth, where new housing is supported by new and improved services and infrastructure. Such development could also help to meet the Council's ambitions for greener growth, with higher environmental standards in construction, communities better connected for walking and cycling, and within easy reach of local services”.
6.7. This statement is supported and the site, subject to promotion through this representation, provides an opportunity to deliver this strategy on a brownfield site.

The future is green or there is no future. The standard of recent developments in Medway do not reflect the declaration of a Climate Emergency. The administration has a backlog of sub-standard buildings needing retro-fitting even before they are completed.

The wording of this objective is vague and does not clearly define what the plan aims to achieve. Consider rewording this to say “Support the achievement of a net zero carbon Medway and tackle the negative impacts of climate change through adaptation” or “Working together for a net zero carbon and resilient future.”
• The first bullet point feels like a list of buzzwords. Please revisit some of the comments made previously around the vision in Section 3, for example:
o Establish the Local Plan as a framework to achieve significant reduction in carbon emissions. This should be the driving principle, not just environment as a theme; likewise
o elevate the significance of having clear adaptation plans to minimise the effect of the impacts of climate change (not just “seeking” measures) on people and places most at risk.
o the term “net zero carbon” should be used consistently through the document rather than intermittently with terms such as “zero carbon” or carbon neutral.
o adaptation measures are not limited to mitigating flood risk; it should also include overheating and droughts
o To deliver on Medway’s net zero carbon targets, “Drive reductions in the carbon impacts of new homes by setting minimum requirements for developers to ensure that whole life carbon costs are considered (embodied carbon of materials and processes).
o We welcome the consideration to protect vulnerable communities as these groups are most likely to feel the effects of climate change. This should be its own bullet point (perhaps under the objective around communities).
o Nature based solutions and transport are mentioned in the first bullet but should be removed from here and warrant having their own bullet point so as not to dilute the significance of them.
o Energy needs its own bullet point and there should be a commitment to determining the future energy requirements based on the development needs of Medway to support a clear and comprehensive Local Area Energy Plan, including large scale and localised renewable energy solutions. It is essential that consideration should be given to the most and least environmentally sensitive sites for deployment of solutions to avoid negative impacts.
o In the bullet about transport, it should reference the travel hierarchy to include minimising the need for travel in the first instance through spatial planning.
o In the bullet about green and blue infrastructure, more emphasis is required around addressing resilience through the creation and protection of natural assets. The current statement doesn’t quite make sense, “providing resilience for nature through better connectivity and conditions.” Also, bring in the co-benefits of enhanced biodiversity, good air quality and improved public health being realised.
o See previous comments about waste (Section 3).
o A final bullet should be to establish clear guidance and high standards for developers to adhere to which reflect the aspirations of net zero carbon and adaptation. Also, to prioritise climate change when determining development applications.

COMMENT ON PARA. 4.2, BULLET POINT 3

Chatham Docks is vital to maintaining a ‘robust…blue infrastructure network…’ The river-borne and sea-borne traffic associated with Chatham Docks allows direct sustainable connections with the rest of the South-East and with European ports, rather than just lorry deliveries in and out.

Far more comprehensive and safer cycle routes which are NOT shared wherever possible are necessary if we are to encourage more people to leave cars at home.