5.2

The plan should also be precise about how existing housing will be protected from noise (already very high in Strood, for instance), air pollution, light pollution, when new houses are built. The plan should also include a rule of planting one tree / plant for each tree / plant that is destroyed when building new houses. In my 11 years in Strood, I have seen a lot of green spaces destroyed and very little replanted.

We support this statement however we would suggest adding a sentence specifying that homes jobs and services are located in sustainable locations well served by public transport and green networks.

Need to see a definition of "sustainable development". Dislike the implication that a Local Plan could be used to stop 'development'.

Chatham Docks is employing directly 800 people with over a 1000 more in the the supply chain. To redesignate the land use to allow developers would drive unemployment.

You must not resort to anti-motorist policies to tax and fine the motorist to raise this money. Neither should you keep raising Council Tax. Everyone is cutting back and making financial efficiencies so should the Council focus on the bottom line of quality value for money services. You need to look at new services that can bring in revenue like a Council filming and events section for example.

All Metropolitan green belt land should be preserved and not considered for development. All development should be sustainable with good transport links and not considered unless local roads are suitable and safe for cycle and pedestrian use so that reliance on motor vehicles is reduced. Walking over a mile to the nearest bus stop/train station is not a sustainable option as this is not something most people do.

In developing the spatial strategy, the existence of the AONB designation should influence the plan in terms of the strategic location of development. In considering allocations, para 174 of the NPPF states that planning policies should protect and enhance valued landscapes in a manner commensurate with their statutory status. The NPPF also highlights the need for local planning authorities to differentiate between land of the highest environmental quality and that of lesser quality, and to allocate development accordingly to areas of lesser environmental value (paragraph 175).
Decisions on allocating sites within the AONB should be ‘landscape led’. This requires a robust understanding of landscape including the key characteristics, history and settlement patterns of the wider landscape. The PPG advises that “To help assess the type and scale of development that might be able to be accommodated without compromising landscape character, a Landscape Sensitivity and Capacity Assessment can be completed. To demonstrate the likely effects of a proposed development on the landscape, a Landscape and Visual Impact Assessment can be used” (Paragraph: 037 Reference ID: 8-037-20190721). The Kent Downs AONB Management Plan 2021 to 2026 is a key document to understanding what makes the area special and therefore what qualities need to be conserved and enhanced when deciding the location, scale and design of new development. Medway Council will also need to consider the cumulative impact of any proposed allocations within the Kent Downs AONB.
To comply with the NPPF any allocations within the AONB should be small scale. Paragraph 177 states “Permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:
a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated”.
Whilst paragraph 177 specifically refers to permissions, it has also been considered relevant by Local Plan Inspectors to allocations within Local Plans. Legal advice provided to the South Downs National Park Authority by Landmark Chambers also concluded that “it would arguably amount to an error of law to fail to consider paragraph 116 (now 177) at the site allocations stage of plan making for the National Park. The consequence of doing so would be to risk allocating land for major development that was undeliverable because it was incapable of meeting the major development test in the NPPF”.
Tests a) and b) of paragraph 177 are indeed more appropriate to determine at plan-making stage when the needs for development are established and alternative options for provision fully considered. The scope for this to be done at planning application stage is much more restricted. The starting point of this policy is that major development should only be permitted in an AONB “in exceptional circumstances, and where it can be demonstrated that the development is in the public interest”. This is a separate requirement to the tests set out at a), b) and c) and set a very high bar. When applied at Local Plan stage test a) should not assume that general housing needs must be met within the AONB. To justify major development on the basis of meeting objectively assessed housing needs for the local planning authority area is a circular argument at plan-making stage because the impact of the scale and distribution of development on the AONB should be taken into account in deciding the level of housing provision. If such levels can only be achieved by allocating major development, which by definition will have “a significant adverse impact on the purposes for which the area has been designated” then this is a good indicator that the impact on the AONB provides “a strong reason for restricting the overall scale, type or distribution of development in the plan area” (NPPF paragraph 11).
The assessment for test a) should rather be based on robust evidence that directly relates to the AONB and relevant settlements within it. This is supported by the findings of the Inspector for the West Oxfordshire Local Plan, who recommended deleting four allocations in the Burford – Charlbury sub-area, which forms part of the Cotswolds Area of Outstanding Natural Beauty (AONB) on the basis that there was no housing need figure for this specific sub-area and that that “soundly-based decisions on the balance of the benefits and harms of further housing development in this area can only reasonably be reached based on the detailed evidence submitted as part of specific planning applications” .
Test b) should robustly explore all available options outside the AONB, and whether the need can be met in another way, such as on smaller sites within the AONB. Test c) can be harder to apply at Local Plan stage when the details of the scheme are not known, but sites that are significantly constrained by environmental, landscape or recreational factors should be avoided. Again Landscape Capacity / Sensitivity Studies and Landscape and Visual Impact Assessments carried out in the context of Strategic Environmental Assessments or Sustainability Appraisals can be useful tools to inform this test if used alongside other relevant evidence such as ecological and heritage studies

Need to define what sustainable development means and how developers will be held to account to deliver this.

We need more houses and the council should not give into NIMBYism or care about "protecting views"

If correction is needed then certain developments should be stopped. Going in with such precedents on existing developments could make things worse, especially when there is no public transport option for hub connectivity or to schools. Given the focus is so solely geared towards housing I cannot see how business and jobs fit in to this. If they are dealt with as an afterthought they will never happen.

Right, so you have approved or intend to approve a development that is not linked at all to the public transport network, is accessed by a road that barely fits 1 vehicle at a time down and to destroy a beautiful local feature without any actual improvement to local infrastructure

Please take account of changes to estimated growth graphs.

Seems largely toothless then. I don't understand from this who uses it or how it is used to 'direct and manage growth'. Should it be the first benchmark used to assess planning applications?

Protect the important areas and sympathetically develop brownfield sites.

A good number of people moving to new developments in the Medway Towns are coming from the London area. These are not Medways needs.

Can the Local Authority really stand up to unsustainable development? I feel that it should!

The development out in Hoo affected by Nightingales and land covenants on the golf course, will need a Development Corporation or major increases in Planning Officers to support any such future development proposals. Managing Growth requires man/women/officer power not wonderful words. The latest Organogram on planning officers requires more officers to reach any such goals.

In protecting the area's natural resources there should be no development in Medway's Area of Outstanding Natural Beauty (AONB) as along Bush Valley and around Upper Bush. This area has already been subjected to Planning Inspectorate study and rejected for development of winery and tourism facilities. AONB should afford the highest possible protection and any development suggestion should be rejected at the earliest possible stage.

The local plan must determine what the actual needs of our growing and changing communities are, as the basis for future sustainable development and make a distinction between local need and pressures for inward migration.

Whilst it is appreciated the council are required to make a plan for a growing and changing community, this plan must consider all aspects. The main focus is always on housing, but this can only be carried out with consideration for a supporting infrastructure. The roads in Medway currently do not cater for the community (and are being dug up 90% of the time). There are not enough schools, doctors/doctors surgeries, the hospital can't cope (and is in the wrong place) and there are enough leisure facilities. You can't have one without the other.

It should include to direct and manage growth not only by providing land but opportunities for brownfield development and opportunities to re-use vacant buildings.

I agree.

I agree.

A good local plans is needed for the area, but unless we can challenge the housing numbers set by national government my fear is that we will not be able to meet the targets each year, and then developers will be able to come into other areas that we have not included. We need to establish what Medway’s housing needs is and what is achievable, this will then protect the area and will assist how local residents and the local planning authority what the area to develop.

Implies that future development must be truly matched to the needs of Medway and its communities (e.g. small scale, low rise house, with provision for the local industry and services that build communities (rather than faceless housing schemes and industrial estates.)

A sustainable Medway does not seek development at any cost or to meet arbitrary political targets imposed from outside.

Spatial Strategy

Redrow would strongly encourage Medway to prepare a Local Plan that seeks to deliver the homes required, as derived by the standard method. As indicated in the Regulation 18 draft Local Plan, the Government considers that this method is appropriate to meet its housebuilding ambitions to tackle pressures in the housing market and there is a housing crisis, particularly regarding affordability. There is an absolute need to deliver the homes required when and where they are needed to meet Medway’s growing needs and the requirements for those desperately needing a good quality home. The Local Plan must set out a strategy to achieve this. This requires a wide range of sustainable housing allocations at different scales and locations that can be delivered at different rates and times.
Redrow would agree that consideration should be given to potential impacts on the environment and strategic infrastructure needs. However, these should not simply be seen as a constraint to new housing growth as the focus should be to assess how negative impacts could be avoided, or mitigated, such as through the co-ordinated delivery of new services and enhancements to landscapes, heritage and biodiversity.

Urban sites will have an important role to play, but they are not always available and will often deliver the smaller homes (1 and 2 bed flats), with less affordable housing as demolition, conversion or land decontamination is often required and, as such, development of such sites tends to have higher costs for these reasons. As the Regulation 18 Plan recognises, this can affect viability and hence the type of development that can be delivered and when it is delivered.

On the other hand, suburban expansion sites are located in close proximity to the urban areas, are usually available and can deliver larger family homes with policy compliant affordable housing. There are potential environmental impacts but this can be mitigated through careful layout and design.

Redrow would agree that development on the green field sites in this category would be expected to be built quicker as the site constraints are more limited than brownfield sites. It is also recognised that development of large sites in this location, or smaller sites that are comprehensively planned, could provide opportunities to enhance sustainable travel options, making it easier and more attractive for people to walk, cycle and use public transport. New housing in these locations could support existing services and facilities and deliver more if required.

It is noted that development to the east of Rainham would erode the strategic gap between Rainham and Newington and add further to the congestion and pollution issues on the A2 and that larger scale development would not be appropriate to the south, around the Capstone Valley as this would potentially adjoin the development of the proposed ‘Lidsing Garden Community’ in Maidstone. As such, there should be more focus on the potential land to the north of Rainham, with detailed consideration given and discussions held with land owners to identify how potential impacts could be appropriately mitigated and integrated development secured.

I disagree with the prospect that the local plan can be used to bulldoze through unsustainable developments in the name of 'housing needs'. Sustainability should be at the forefront of the local plan as it will be the younger generations living with the decisions being made today, when many of those making these decisions will not even see out the plan completion.

A Local Plan should only support truly sustainable development in areas where the ecosystems cannot be destroyed. THE NATIONAL GOVERNMENT DEFINITION OF SUSTAINABILITY IS DEFINITELY NOT SUSTAINABLE, ask any untainted scientists.

The development of housing in particular should be evidence based but we the local people have not been allowed to see the vital reports prepared by consultants into the transport strategy and the ecological assessment, amongst others. This is a scandal.
Developments should be spread evenly and fairly across Medway not concnetrated on the peninsula in what has clearly been a bad case of NIMBYism up to now. I am hoping for better