5.1

Not enough green space is being protected, there will be no area for fresh air or exercise soon in Medway. Create more parks or nature reserves

The primary consideration in delivering a sustainable spatial strategy should firstly focus on brownfield redevelopment of the riverside and town centre. It is agreed that the support for High Streets and urban regeneration should underpin the whole strategy and this is fully supported by F D Attwood and Partners subject to the following caveats which relate to the housing capacity yield from development in this area including ;
• The historic character of the riverside has to be preserved and part of the character for this area derives from the mix of uses including employment. The document rightly acknowledges heritage value in the vision and objectives and the role of this area for tourism (see paragraph 4.2) should also not be underestimated. These factors will influence estimates of housing yield that is deliverable within the plan period.
• As well as the need to preserve the character of the area as outlined above, there are also viability considerations which need to be taken into account in this area and the likelihood that these sites may only be delivered by high density apartment construction which will not deliver a range of housing and are also subject to greater market sensitivity, that in turn affects housebuilder interest and deliverability.
The principle of adopting a sequential approach to the spatial strategy that focuses on brownfield riverside development and urban regeneration is supported but for the reasons outlined above, there must be caution in the net capacity of these areas to meet the housing need and the timescale to delivery and for this reason, we support the riverside being a component of a suite of spatial options.
As part of the sequential spatial approach, the next favoured option in terms of sustainability benefits, should be the suburban extension choices which, as previously highlighted (if planned comprehensively alongside infrastructure), would also benefit the existing urban areas adjoining these areas and in this case, could provide certainty to the whole of the Capstone corridor length.
The opportunity of a comprehensive masterplanned approach to link the existing planned building blocks within the Capstone Corridor, including Lidsing Garden Community (2,000 dwellings), Gibraltar Farm (450 dwellings) and East Hill (800 dwellings), which are also within the control of the landowner, offer a unique opportunity to deliver a wide range of planning benefits from this spatial option which places Capstone as a suburban extension ahead of the suburban alternative of Rainham which has:
• Greater acknowledged highway congestion and air quality issues on the A2 and road network around it;
• Is of a higher agricultural land value;
• Is part of a strategic gap between Rainham and Newington;
• Lies in closer proximity to the Medway Estuary SPA and its setting.
As part of a sequential approach, it would only be in the event that Medway Council cannot deliver road, open space and community/utility infrastructure alongside biodiversity enhancements to support growth in the suburban areas (alongside riverside growth), that a new community on the Hoo Peninsula should be considered as a third option, with its more limited objective to create a self-contained community in a non sustainable location.
The past ‘driver’ of LPA decision making which favoured Hoo vis a vis the Capstone Corridor (aside from the HIF Funding for infrastructure), was a perception that development in the Capstone Corridor would erode the character of the valley and its function as a green lung for the existing urban areas around it. However, successive Inspector’s (for local plan and Section 78 appeals) have disagreed with this assessment and now these planned developments can provide building blocks of a new comprehensive vision for the whole of the corridor integral to which will be green infrastructure and biodiversity enhancements that links with the surrounding communities.
Whilst the local plan evaluates objectively all spatial options to deliver the vision and agreed strategic objectives, FD Attwood and Partners consider that an alternative high-level assessment of character impact should now be utilised, which is very different to that adopted in the past in order to drive spatial decision making. This new approach is justified because it is acknowledged throughout the plan that the character of Medway on the headland, to the north of the river Medway, is very different. Whilst large new country parks have previously been offered to mitigate the impact of major growth on the headland, the siting of major development in this area will comparatively affect to a greater degree, the more remote character of this part of Medway ( which is recognised at paragraph 5.36) and is also more environmentally sensitive (protecting natural assets is recognised at paragraph 4.2 and 5.10) and important to tourism and the character of Medway in its totality as an administrative area.
For these reasons, it is asserted that, in the consideration of spatial options, major scale development on the headland should only be considered as a spatial option in the event that the suburban growth option is discounted for the reasons outlined above. Major growth at Hoo, even if it could address road capacity, rail connectivity and environmental impact considerations, is not as well placed as other spatial options to support the High Street, create more inclusive and connected communities that address current inequalities, or support tourism. The principal vision and strategic objective of major growth at Hoo is to make it “self contained” to boost its sustainable credentials and rely on the fact that it is likely to be the subject of less public objections, because it is located well way from the main populace of Medway. For these reasons, in terms of delivering the supported vision and strategic objectives, Hoo represents a third-tier option.
The Reg 18 Document at paragraph 5.41 when referencing Hoo specifically asserts that;
“Such development could also help to meet the Council’s ambition for greener growth with higher environmental standards in construction, communities better connected for walking and cycling and within easy reach of local services.” This assertion is strongly contested by F D Attwood and Partners for the reasons explained in this response.
The option of the Green Belt release in line with national guidance should be weighted a “last resort" spatial option. The fact that the Green Belt occupies only 2% of the land area of Medway; performs an important strategic function in preventing the urban sprawl of Strood and Higham and Snodland and Halling; and in addition to this, is designated as AONB, provides national recognition of the landscape quality of this area as well as its spatial GB functionality. As part of a sequential approach, this option should only be examined further when it is proven that the other spatial options cannot be delivered.
The technical work of FD Attwood and Partners can demonstrate that:
• Comprehensive masterplanning and delivering of infrastructure;
• Mix of uses;
• Quality of development including SUDS and other technical issues;
• Transport benefits and access considerations can be delivered; and
• Landscape open space and biodiversity linkages, particularly with the Capstone Country Park hub.
These matters can be fully addressed without the need for public funding and will also benefit the existing local communities and provide community cohesion.
At Para 5.35 of the Regulation 18 consultation document, there is recognition of the cross-border impacts and the fact that early masterplanning decisions via the Lidsing SPD document, will be starting to be made shortly. As highlighted earlier, we see this as an opportunity for better masterplanning output through collective working and cooperation between the Attwood family, Medway Council, Maidstone Council and Kent County Council across the entirety of the corridor including Lidsing.

Eutopia Homes supports the New Local Plan’s growth strategy as ‘the Council’s starting point is regeneration and making the best use of vacant or underutilized brownfield sites’ (Para 5.19, Reg 18 document). It similarly supports the notion that ‘Urban regeneration does not mean a standard approach to density and design, but the consideration of the most appropriate approach in different areas’ (Para 5.20, Reg 18 document)

I note the change of use for some areas on the Medway City Estate. Traffic on this areas has been challenging over the years, but has recently started to improve. To introduce residential into this areas I feel would be a mistake. There will be conflicts with the mix and also business have invested a lot into the area for it to start to change becoming residential. This will cause worry and businesses may start to leave prematurely.

If proposed housing numbers are adjusted to meet only Medway's housing need we will be able to protect all of the land needing protection for both agricultural and environmental reasons

Poorly designed and delivered (or undelivered) developments have blighted Medway for decades. Priorities should be adjusted to deliver quality, affordable housing development of the correct size and scale matched to the needs of the people of Medway.

Significant growth and attention to green spaces and public realm is needed .

Mixed developments which combine local (very small scale) industry with local housing and community facilities are the way ahead , moving away from industrial estates mentality so beloved by planners. Human scale zoning should become the norm.

Trenport Investments Limited (TIL) prepared these representations to Medway Council’s (‘the Council’) Regulation 18 Local Plan consultation in relation to Land to the East and West of Church Street, Cliffe, Rochester (‘the site’). TIL welcomes the first step by the Council in advancing a new Local Plan and for the opportunity to make comment on its contents.

The Regulation 18 Local Plan document sets out the framework for the area’s growth up to 2040 and where and how new development can take place. Section 1.4 notes that this consultation does not detail policies or identify those sites preferred by the Council for new development and that detail will come in the next stage of work on the Local Plan. It is also notes in Section 5.1 that the Local Plan will
include a Policies Map which will show land allocated for new housing development. Notwithstanding the above, Map 3 on Page 22 of the Regulation 18 Local Plan provides an overview of potential sites for rural development. The Site is not included within Map 3.

Section 5.12 sets out that the housing needs for the Council over the plan period is 28,339 and figure 2 splits the potential sources for the supply into three categories - pipeline, windfall and allocations. Section 5.13 notes that there is an existing pipeline of sites for over 7.500 homes, the Site is likely not included as a pipeline site as it does not yet have planning permission. Therefore, unless the Site has
been included as a windfall, the Site should be considered as an allocation.

Section 5.14 and 5.15 notes that the Council has produced a Land Availability Assessment (LAA) to review potential sources for allocation. The LAA identifies land with potential capacity for circa 38,200 homes of which many of these sites are subject to constraints including environmental considerations. Section 5.16 goes on to note that the LAA has identified four broad categories of locations where development could take place – Urban regeneration, suburban growth, rural development, green belt loss. In this context, the Site would be considered a rural development site. However, the Site is not included in Map 3 as a potential site for rural development and is therefore likely to have been excluded from the 14,736 homes in the rural development category of the 38,200 potential housing capacity set out in Table 1. As such, it is not clear if the Site is being considered as an allocation or any other category within the Regulation 18 Local Plan.

In addition, Section 5.39 of the document notes that most of the sites currently being promoted for housing led development are large scale with the potential to provide land for hundreds of homes. On this basis, the Site should be considered as it could provide up to 250 homes along with a number of benefits outlined above and is not the subject of any environmental constraints.

TIL seeks clarity on the status of the Site within the consultation document and emerging local plan. We would strongly recommend that the Site, which has been the subject of the scrutiny of a Public Inquiry where the Council withdrew their objections, is included on Map 3 in the next version of the Local Plan and any future iteration of the policies map in the Local Plan

Chapter 5 – Developing a Spatial Strategy

‘Development needs’
15. Catesby Estates agrees that a ‘Local Plan should be positively prepared for sustainable development. It should not be used to stop development that is needed for our growing and changing communities’ (paragraph 5.2). Alongside this Catesby Estates supports the Council’s growth ambitions and advocates an unconstrained and holistic view of development across Medway, in order to achieve this.

16. The LP2040 correctly identifies that the Government directs Local Planning Authorities to use its Standard Method when determining the scale of housing required over the plan period. As the LP2040 sets out the standard method identifies a minimum need of 28,500 homes over the plan period to 2040 (1,667 dpa). The LP2040 further states that this is higher than the rates of housing building seen in Medway for 30 years (paragraph 5.3). Catesby Estates is clear that Government policy should be followed when preparing a Local Plan to ensure it is positively prepared, compliant with national policy and thus able to be found sound. At the time of writing it remains that the Standard Method is the starting point for calculating the minimum housing need and it is this calculation that the Council should therefore use when preparing the Plan.

17. Moreover, as the Planning Practice Guidance (PPG) refers, unconstrained housing need could exceed the standard method minimum:

‘The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates…
…Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;…’ (our emphasis)
(Paragraph: 010 Reference ID: 2a-010-20201216)

18. Catesby Estates therefore considers it counter-productive, given the Council’s own vision and strategic objectives which seek to transform the economic performance and prosperity of Medway, to immediately limit housing needs based on past trends – clearly the future of Medway cannot be assessed on past trends given the ambition of the Council and LP2040 into the future: to exceed the past delivery and economic performance of Medway.

19. Whilst Catesby Estates recognises the concerns of the Council regarding existing infrastructure and future capacities, the preparation of a Local Plan is the correct tool with which to address these issues. It is vital therefore that the LP2040 plans for the correct level of development, in particular housing, so the correct level of supporting infrastructure can be planned alongside.

20. Notwithstanding the above comments, Catesby Estates also notes the request from Gravesham Borough Council to provide an additional 2,000 homes to help it meets its needs. This further increases the requirement within Medway and highlights the need to plan for housing that can be delivered at all stages of the plan period.

21. Paragraph 5.12 of the LP2040 states the housing needs for Medway over the plan period pf 2022-2040 to be 28,339. Paragraph 5.3 and 5.11 subsequently note the need to be 28,500. Furthermore, paragraph 5.3 also refers to the need as 1,667 homes a year, which when taken across the 18 year plan period (2022-2040), results in a total need of 30,006 homes. With three different figures in the LP2040, it is imperative the Council are clear on the housing needs of Medway and if it has applied any reductions to the standard method figure. Notably however, a buffer will need to be applied to the correct figure as the Council confirms at paragraph 5.12 and Gravesham’s unmet need will also need to be accounted for. Catesby Estates therefore considers that the plan period need for Medway will be closer to 34,000 homes (1,888 dpa).

22. At Figure 2 of the LP2040 the Council sets out how many sites are considered to be in the pipeline (with planning permission), those it expects to come forward as windfall sites and thus the remainder it will need to allocate within the LP2040 in order to meet its needs.

23. Regarding pipeline sites, Catesby Estates notes this figure to be 7,583, which is 27% of the need across the plan period (using the Council’s figure of 28,500). This is considered significant and the Council should assess these sites to ensure they are deliverable before relying on them in a new Plan. Any planning permissions which have lapsed should indicate that a Site is not coming forward in the short term.

24. Regarding windfall sites, Catesby Estates notes this figure to be 3,000, which is 10.5% of the need across the plan period (using the Council’s figure of 28,500). The National Planning Policy Framework 2023 (NPPF) is clear that where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply (Paragraph 71). Catesby Estates therefore requests that the Council provide robust evidence that demonstrates 3,000 homes are capable of being delivered via windfall sites across the plan period.

25. Regarding the number of homes needing to be allocated within the LP2040, it is noted that this is likely to rise following the correct calculation of need across the plan period. Nevertheless, Catesby Estates suggests the Council should consider allocating more sites within the LP2040 in order to require less unplanned development to meet its needs across the plan period.

26. Paragraph 5.15 of the LP2040 notes that the Land Availability Assessment (LAA) has revealed land with a potential capacity for circa 38,200. Catesby Estates suggests that sites contained within the LAA are therefore assessed robustly and objectively to enable the Council to plan and allocate sites for the majority of its housing need.

27. Table 1 of the LP2040 demonstrates the potential housing capacity for each of the category areas, according to the LAA. It shows that a potential capacity of 11,151 homes exists within urban areas, which is considered a high level of growth. Catesby Estates considers that caution should be applied when considering whether this this level of urban growth is feasible, and whether it will deliver the right choice of homes. Complexities exist with urban redevelopment that often impact the speed and viability of delivery. In addition, such development also delivers a greater proportion of smaller sized units and the Council need to consider this carefully against the aim of the LP2040 and needs of the existing a future population of Medway.

28. Table 1 of the LP2040 also confirms that circa 40% of the potential sites fall within the rural development areas of Medway. This reflects a need for the Council to consider its growth locations and corridors holistically and not miss opportunities to allocate sites that would contribute to the vision for Medway, and provide links to different areas. The expansion of existing settlements such as Allhallows can deliver family homes with policy compliant affordable housing. Any environmental impacts can be mitigated through careful layout and design that ensures future development respects and enhances its surrounding context.

29. Paragraph 5.36 of the LP2040 discusses sites with the potential for development in the rural areas and focusses heavily on those sites put forward on the Hoo Peninsula. The LP2040 does not discuss other rural areas where sites have been put forward such as Allhallows – at this stage the LP2040 should be considering all options and assessing them against the vision for Medway. Whilst it is noted that the Hoo Peninsula can accommodate some new development, it is a notable constraint that HIF funding has been removed, and the Council comments at paragraph 5.45 that the capacity of infrastructure to support major growth on the Hoo Peninsula is a strategic consideration.

30. Notwithstanding, Catesby Estates considers that Allhallows forms part of the wider area which the Council has spent much time developing proposals for and therefore complements the development prospects on the Hoo Peninsula when viewed holistically, particularly those related to industry. Indeed, Catesby Estates recognises that such urban growth may take a long time to come to fruition, as seen elsewhere in the country with strategic development locations. Consequently, Allhallows represents an opportunity for early delivery without the need for significant infrastructure, within a wider area which has long term growth potential, helping achieve the desired long term aim of increased prosperity in the region, alongside maintaining an annual supply of homes.

Rainham lower road is heavily allocated for housing surely this is not workable its narrow has a traffic light controlled pinch point and other very narrow points no pavements,lighting or provision for cycling.

There should be no further use of land on the Hoo Peninsula unless it is brownfield and ONLY BROWNFIELD LAND. All planning applications for the development of greenfield land should be rejected by the Planning Committee.

This plan should already be visible where is it?