5.14

Very concerned about proposed enlarging of Cuxton. The proposed site is 19 hectares and would potentially be for 800 houses. This would double the size of the existing village. another 1,600 cars exiting and entering the village during peak times would overwhelm the village causing large queues of traffic along Bush Road as they try to exit onto the A228. This already happens during the school run. Queues of traffic means a reduction in air quality. This site is wholly within the AONB and is protected metropolitan greenbelt. Its setting within the AONB and proximity to a protected rural hamlet is the reason for a previous planning application being refused. It is also not sustainable, with a 1.5 mile walk to the train station and 1 mile walk to the nearest bus stop. The road is narrow so no possible provision of a foot path or safe cycle route. this would lead to a total reliance on motor vehicles.

If a site that was previously on the list and planning permission was denied by the council and we won the appeal it shouldn't be on the list. I am referring to Hogmarsh Valley. This area is so important as a wildlife habitat so needs to be protected

It's not a high level of need. Its a high level of development which appears to be pushed by dominant and powerful developers through Central government and local government are complicit in enabling all the damage that will result to Medway residents and environment as a result.

The numbers do not make sense. Clarity on the round 3000 figure is needed.

Most of this work is unnecessary if Medway Council can successfully challenge the Government's estimates.

Sites are never too small. Extensions to Villages appears to be the first line of defence. Development briefs are problematical. Any where you are out with the Medway Towns conurbation sustainable travel is effectively negative. Small sites lose out every time when close to Villages. The Amazon development business park has many initiatives such as dedicated buses for employees. Consultations with larger employers is essential in Village localities.

The Medway Land Availability Assessment (LAA) was published on the 16th October 2023.

As set out in paragraph 3.1.6 of the Land Availability Assessment (LAA) “Medway Council would welcome information to confirm the availability of the 109 sites, otherwise such sites may not be phased for delivery in the first five years of the plan period”.

We are working on behalf of AC Goatham & Son, the owners of the site known as Bloors Farm. This site has been given the reference number RN9 in the LAA.

During the Stage 1: Identification of Sites and Initial Survey, the assessment into site RN9 concludes that it should proceed to Stage 2. It is however, included in the summary map of sites with unknown availability (Appendix F).

This representation seeks to continue the promotion of the site known as Bloors Farm and it is confirmed that it could be delivered in the first 5 years of the Local Plan period. However, for the purposes of confirming land availability Pump and Bloors Farm are available now.

Bloors Farm is circa 27.32 hectare and was submitted under the name "Land between Pump Lane & Bloors Lane, Rainham". This representation confirms that the site continues to be promoted primarily for a housing-led development scheme. The strategic location and size of the site provides the opportunity for the delivery of a major mixed-use scheme, which could be developed in isolation or more strategically with neighbouring sites, namely Pump Farm.

The LPA is now reconsidering the suitability of Bloors Farm, as it is included in the general suburban land approach advocated in the general suburban extension model advocated in Map 2 of the consultation 'Map 2 - overview of potential sites for Suburban Expansion'. An approach that is actively supported through these comments.

AC Goatham & Son confirms that this site will become surplus to requirement as orchards during the Local Plan period, which extends to 2040. It is expected over the coming years that some of the periphery orchards, Bloors Farm being one, will no longer form the main basis of their business model as the intention is to draw in operations closest to their headquarters and consolidate outlying interests. This meets the aspirations of NPPF paragraph 83, which advocates that 'planning policies and decisions should recognise and address the specific locational requirements of different sectors'.

The use of Bloors Farm with its intensive fruit farming operation has attracted significant residential complaints in recent years. Furthermore, the impending requirements for investment in replanting in the coming years will make the ongoing use of the site as an orchard unviable. The need for these sites to remain as agricultural land has been confirmed as having diminished significantly as to effectively extinguish what was formerly identified need.

The landowners are therefore releasing Bloors Farm, along with the neighbouring farm, Pump Farm, during the Local Plan process from their business portfolio of operational orchards.

1. Introduction
1.1. We are writing on behalf of our client, Kitesfield Estates Limited, in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.
1.2. This representation promotes a 1.05ha brownfield site on the southern side of Ratcliffe Highway, Hoo St Werburgh, Rochester, ME3 8QB, known as ‘The Depot’ Ratcliffe Highway and herein known as ‘the site’ for inclusion in the future Local Plan.
1.3. The site is owned by Kitesfield Estates Limited and is leased to L & P Recovery Limited. This site is considered to be an omission from the draft Regulation 18 consultation strategy, which identifies broad areas for development in the context of the forthcoming Medway Local Plan.
1.4. The site provides an opportunity to provide a development site in the Hoo Peninsula rural development area. This omission site could contribute to the Council's substantial housing requirements within the district, especially when joined with the neighbouring sites, already identified.
1.5. This brownfield site, currently trading as a vehicle sales and repair business, has never been promoted through the Local Plan process, at either the call-for-site or former regulation 18 stages. It is now being promoted through Bloomfields Chartered Town Planners, following the adjoining and neighbouring sites coming forward for large-scale housing schemes. It is considered that the site provides an opportunity for additional housing development, and hence, positive growth in the Medway area to 2040.
1.6. This representation responds to the current Regulation 18, by setting out how the site meets the aspirations and broad spatial strategy being promoted in the Local Plan, specifically in the rural area. In addition to responding to each of the headings in the consultation document, and identifying how the site can deliver the vision and objectives through sustainable development.

 
2. Context
2.1. The production of the Medway Local Plan has involved several key stages. Three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final Regulation 18 consultation before the publishing of the Regulation 19 draft plan.
2.2. The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.
2.3. It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development, but does relay key areas where development could come forward.
2.4. This representation seeks to promote a 1.05ha brownfield site on the southern side of Ratcliffe Highway, Hoo St Werburgh, Rochester, ME3 8QB. Please see the attached site plan for the full boundary of the site.
2.5. This site has not previously been promoted for development through the 2008 Call for Sites or more recently the 2023 Call for Sites exercise undertaken by Medway Council, the Local Planning Authority (LPA). On this basis, the recently published interim Land Availability Assessment for Medway (September 2023) does not include an assessment of the site.
2.6. For the completeness of this Regulation 18 consultation, the site is considered an omission and it should be included in the defined area being promoted as part of the wider rural development area in the Hoo Peninsula.
2.7. This representation confirms that the site is being promoted primarily for a housing-led development scheme. The strategic location and size of the site provides the opportunity for the delivery of a major residential-ledscheme, which could be developed in isolation or more strategically with the neighbouring site, Land At Ratcliffe Highway Hoo (associated with planning application MC/23/1934).
2.8. The area of land which surrounds the site on its western and southern boundary is currently subject to assessment as part of planning application MC/23/1934. This application for outline consent is currently under consideration and sets out a scheme for the erection of up to 240 residential dwellings, being promoted by Gladman, including 25% affordable housing, together with a new vehicular access point from Ratcliffe Highway, open space, landscaping and associated works.
2.9. As the site has not been promoted for development through any previous call for sites or Local Plan stage consultations, it is not included in the general rural development land approach advocated in the rural development sites model shown in Map 3 ‘Overview of potential sites for Rural Development’. In consideration of the consultation, it is therefore submitted that its non-inclusion is an omission.
3. Site Description and History
3.1. The 1.05ha brownfield site on the southern side of Ratcliffe Highway, is a roughly triangular-shaped site accessed from its own permanent access off of Ratcliffe Highway. The site comprises hard standing and several buildings which serve the current business uses. A further review of the Google Earth historic maps, identifies that the site has a history of commercial motor vehicle use as far back as the 1960s.
3.2. The site is located adjoining the Ratcliffe Highway to the north and on this boundary it is screened by a thick band of hedging and vegetation.
3.3. It is surrounded by agricultural fields to the south and west and there is a further narrow hedgerow which screens the site on these boundaries. These agricultural fields are subject to a planning application for outline consent (MC/23/1934) for 240 dwellings which is currently under consideration.
3.4. The eastern boundary extends to the access drive with the properties known as River View and the Mill View Cottages located on the opposing side. The site access is located between the Mill View Cottages and the eastern boundary of the site, with the shared access extending southwards to the neighbouring property River View.
3.5. The site had a planning application approved with conditions under reference (22/1498) for retrospective provision of additional hard standing and enclosure between the depot and the highway for light industrial use including car sales. This extended the area of the site northwards towards Ratcliffe Highway, increasing the brownfield area of the site significantly.
Constraints:
3.6. Current National Policy in the NPPF “the use of previously developed land, and sites that are physically well related to existing settlements, should be encouraged where suitable options exist.”
3.7. In accordance with the Local Plan Policies Map 2023 the site does not have any constraints to development. It is a brownfield site that is currently predominantly utilised for vehicle salvage/repairs and sales. The site is outside of the urban settlement boundary to which Policy BNE25 of the Local Plan applies, but it is located within a wider area identified for potential housing development in the rural development area in the current Regulation 18 consultation. The site directly relates to the adjoining housing development scheme currently being promoted for 240 residential units by Gladman under planning reference MC/23/1934.
3.8. Furthermore, the recent 2022 planning application approved on the site confirmed that the “site is not designated as a strategic gap under Policy BNE31 of the Local Plan and Magic Maps indicate the site is “other” land and not agricultural land. It is noted the surrounding area is classified as Grade 3b agricultural land. Grade 3b agricultural land is low grade with the most versatile agricultural land (as noted in the NPPF) being grades 1-3a”.
3.9. In respect of the local landscape, it is our view that there will be no unacceptable impact on the landscape value as the site is an in use brownfield site. The Council’s Medway Landscape Character Assessment (2011) (‘MLCA’) identifies that the site falls within the Hoo Peninsula Landscape Character Area, more specifically the Deangate Ridge area.
3.10. In accordance with paragraph 125 of the NPPF 125, ‘area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places’.
3.11. As an alternative to a stand-alone development, the development of the site could be considered with a comprehensive and sensitive masterplan approach with adjoining sites. Either way, both approaches could incorporate masterplanning, appropriate landscaping and suitable design codes to ensure that a suitable and necessary development could be delivered on this part of the Hoo Peninsula.
4. Deliverability
4.1. Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.
4.2. The Glossary of the NPPF defines deliverable and developable as following:
4.3. “Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
4.4. a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
4.5. b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
4.6. “Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.
Availability
4.7. Kitesfield Estates Limited, who own the site, have confirmed that the site is currently tenanted and subject to a lease which expires at the end of 2026. On this basis, and subject to its inclusion in the Local Plan, the site could become available in the first 5 years of the Local Plan period.
4.8. Suitability for Residential Development
4.9. The site is located on the main Ratcliffe Highway route, which directly accesses the Peninsula Way between the settlements of Hoo and Chattenden. It is served by good public transport services and a wide range of services/facilities. There are no constraints that could not be overcome to facilitate residential development.
4.10. The sites would be suitable for housing development, as a highly sustainable and logical extension to the settlement of Hoo. If the site were to come forward for residential development, it could also sit comfortably with the adjoining proposed major residential development scheme or be brought forward alongside it as a strategic and master-planned development scheme for the western Hoo area.
4.11. The site would form a positive approach to housing delivery in Medway on a brownfield site. At an average 30 dwelling per hectares, often advocated in rural areas, the site could have an indicative capacity of around 30 units.
Achievability
4.12. Subject to the grant of necessary planning permission, the site is realistically capable of delivering housing development in the early phases of the Plan period. Development viability will be assessed by taking into account the affordable housing requirements, other obligations and market conditions at the time when development proposals are promoted through the planning application process. At this stage, there is no indication to suggest that there will be any viability issues for housing development on this site.

Medway Council are wasting time and effort and rate payers’ money on doing unnecessary work because no one in this authority will stand up to Government dictates and work for Medway’s residents.

COMMENT ON 5.14

ArcelorMittal submitted representations to the Call for Sites consultation requesting that Chatham Docks be retained as a working, vibrant dock and be promoted for development for continued port use in line with current Local Plan policies ED1 – Existing Employment Areas and Policy E9 – Chatham Docks.

The docks employ over 800 people – many of whom are local. There are also existing jobs in the supply chains. Overall, there are over 2000 jobs dependent on the docks.

Chatham Docks must continue to be both supported and protected in the new Local Plan.

The LAA should have been available as soon as this consultation went live. Instead it was not released until a couple of weeks later.

Medway have indicated that the Local Plan would need to deliver 29,000 homes over the plan period plus an additional 2,000 homes to help meet Gravesham’s housing needs equating to a need to deliver 31,000 homes.

The Council contend that approximately 10,500 homes have been assessed as coming forward through the existing ‘pipeline’ of sites and an allowance for ‘windfall’ sites. The Reg.18 Plan states that there is an existing ‘pipeline’ of sites with planning permission which could contribute towards meeting the total need of the Plan, for approximately 7,500 homes. It is unclear at present which permissions the Council is relying on to deliver this existing ‘pipeline’ and therefore it is recommended that this is set out in the next iteration of the Plan to enable scrutiny and ensure the starting point for determine the housing allocations in the Plan is accurate and to avoid any double counting.
With respect to windfall sites, the Regulation 18 Plan states that an allowance of 3,000 homes will be provided over the Plan period which is a high allowance which is not currently evidenced in the Plan. ‘Windfall’ sites have formed an important component of housing land supply in Medway in recent years which have reflected the age of the current Local Plan. It is noted historically that the
Council has had larger sites come through as windfall. However,

We are writing on behalf of our client, Mr Richard Castle and family, of Dagenham Farm, Ratcliffe Highway, St Mary Hoo, Rochester, Kent, ME3 8RN in respect of the Medway Council Local Plan Regulation 18 Consultation Report – Setting the Direction for Medway 2040.

Mr Castle and family remain committed to the promotion of the sites at Grain Road Middle & Lower Stoke for residential development in the future Local Plan. This representation is made in this context and demonstrates a justification for designation of these sites as part of a sustainable rural expansion to meaningfully contribute to the Council’s substantial housing requirements within the District.

These sites have been promoted for housing development through the Medway Council Call for Sites 2022 in February 2023. Following the publication of the Medway Land Availability Assessment (LAA) on the 16th October 2023, the three sites at Middle & Lower Stoke (See Figure 1) have been given the reference numbers as follows:
• AS15 - Land at Middle Stoke, Grain Road, Rochester – 0.86 hectares
• AS14 – Land to the North of the A228, Grain Road, Rochester – 2.71 hectares
• AS17 – Land to the East of the A228, Grain Road, Rochester – 7.82 hectares

During the Stage 1: Identification of Sites and Initial Survey, the assessment of these sites concludes that they should all subsequently proceed to Stage 2, where the Council will carry out a more detailed assessment. The LAA confirms that work is underway on Stage 2, involving estimating the development potential and an assessment of the suitability, availability, and achievability of each site, before considering whether constraints are capable of being mitigated.

These representations confirm that the three sites could be delivered in the first 5 years of the Local Plan period, and are available now.

The production of the Medway Local Plan has involved a number of key stages. With three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final regulation 18 consultation before the publishing of the Regulation 19 draft plan.

The current consultation considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development. However, this representation builds on previous submissions by Mr Richard Castle and family, who continue to promote the three sites at Middle and Lower Stoke for residential development, in the context of the current open consultation.
Context

This representation seeks to continue the promotion of the three sites at Middle and Lower Stoke, Grain Road, Rochester, which have previously been promoted for residential development through the Call for Sites 2022 undertaken by Medway Council, and which have now been through an initial Stage 1 Assessment (MC Ref: AS14, AS15 & AS17) as part of the Land Availability Assessment (October 2023).

Prior to the Call for Sites 2022, there has been some previous promotion, as summarised below, albeit it is noted that Sites AS14 & AS17 have not been previously promoted through any earlier representations.
AS15 – Land at Middle Stoke, Grain Road, Rochester
This site was promoted through representations made in respect of the Medway Strategic Land Availability Assessment (SHLAA) 2017 under site reference 0794 and in
response to the subsequent Medway Local Plan 2012-2035 Development Options Consultation.

Most recently, site AS15 has been subject to an outline application for up to 9 dwellinghouses as part of application MC/23/0106. On 27 September the Committee voted for a resolution to approve the scheme, following the Council’s recommendation to approve subject to clarification from HSE. Such clarification has at the time of writing been received by HSE and the principle of residential development on site AS15 is considered acceptable. Respectfully, this position should be carried forward by the Council in terms of site allocation; albeit, it is accepted that the development is likely to come forward prior to any approval of a new Local Plan.

It is supported that during this Regulation 18 consultation that these three sites on land at Middle & Lower Stoke are now included as part of the defined area being promoted by Medway Council as Rural Development Sites, as shown on Map 3 within the Regulation 18 – Setting the Direction for Medway 2040 (September 2023) consultation document a having potential for providing capacity for 14,736 homes.

This representation confirms that the location of the sites on the edge of an existing settlement are considered to be sufficiently sustainable and suitable for a mixture of small-scale residential development (AS15 – Land at Middle Stoke) and for high-quality, landscape-led, low density residential development (AS14 & AS17 – Land to the North and Land to the East of Grain Road). Site AS14, by virtue of its location, could also be developed, not only in isolation, but more strategically with neighbouring sites to the north, as also being assessed through the LAA.

1.1. We are writing on behalf of our client, AC Goatham and Son, in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.

1.2. This representation promotes a site extending to approximately 13.8 hectares on the northern side of the Peninsula Way, Hoo St Werburgh, Rochester, ME3 6QE, west of the Deansgate leisure centre and east of Homeleigh Nursery.

1.3. Historically, the site has been given the reference SO2 as part of the 2018 Local Plan Development Plan Considerations in which it was identified by the Council as “A site with opportunity for development subject to availability”. The site is and will remain available.

1.4. In 2019, the site was further considered as part of the Medway Strategic Land Availability Assessment (SLAA) 2019 when part of the site (the southern part which was then the only part promoted) was identified as “Suitable, Available and Achievable”.

1.5. In 2020 Medway Council released the Planning for Growth on the Hoo Peninsula document. This, together with land to the north of the site, identified the site’s potential as part of an opportunity area of incidental growth around “Indicative Neighbourhood centres”. The extent of this was shown on the “Opportunities” map.

1.6. The site formed part of a pre-application submission (PRE/20/2978) presented to Medway Council in early 2021 and that then proposed that the southern part of the site form a business hub. The Council’s pre-application response, dated 21st April 2021 confirmed that an employment/business could be included within the wider strategic growth plans for the Hoo Peninsula and that “this area of Goatham’s land would be an ideal location for such a development given its proximity to the transport network and vehicular connectivity”.

1.7. The site, which is owned by AC Goatham and Son provides an opportunity to provide a development site in the Hoo Peninsula rural development area. This site could contribute to the Council's substantial housing requirements within the district, especially when joined with the neighbouring sites and identified as part of the plan.

1.8. It is considered that the site provides an opportunity for additional housing and or mixed development, and hence, positive growth in the Medway area to 2040.

1.9. This representation responds to the current Regulation 18, by setting out how the site meets the aspirations and broad spatial strategy being promoted in the Local Plan, specifically in the rural area. In addition to responding to each of the headings in the consultation document, and identifying how the site can deliver the vision and objectives through sustainable development.

2. Context
2.1. The production of the Medway Local Plan has involved several key stages. Three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final Regulation 18 consultation before the publishing of the Regulation 19 draft plan.

2.2. The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

2.3. It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development, but does relay key areas where development could come forward.

2.4. This representation seeks to promote a 13.8 hectare site on the northern side of the Peninsula Way / Ratcliffe Highway, Hoo St Werburgh, Rochester, ME3 6QE, the extent of which can be seen at Figure 1 below and on the attached Site Location Plan.

2.5. This site has previously been promoted for development through the 2008 Call for Sites and more recently the 2023 Call for Sites exercise undertaken by Medway Council, the Local Planning Authority (LPA).

2.6. The recently published interim Land Availability Assessment for Medway (September 2023) does include an assessment of the site, with site reference HHH19. This document recognizes the site does not comprise “Habitats Sites”, Irreplaceable habitat” and is not an “Area at risk of flooding”. It is on this basis that the site is recognized as capable of delivering 5 or more dwellings, or economic development of over 0.25 ha and which is recommended to proceed to Stage 2.

2.7. The strategic location and size of the site provides the opportunity for the delivery of a residential scheme with potential economic development which could be developed in isolation or more strategically with the neighbouring sites.

3. Site description and history
3.1. The site is well located next to existing and proposed development in a sustainable location. The proximity of a proposed pedestrian crossing to the south further supports good connections to existing and proposed bus links, pedestrian and cycle paths, which will all link well with Hoo St Werburgh.

3.2. Allocation of the submission site would form part of the “Deangate Ridge” allocation set out within the Ho Development Framework (HDF) document, recognised as forming part of a “Vibrant and Sustainable” neighbourhood. This allocation therefore supports a logical extension of the framework area.

3.3. Historic ecological assessments that have been undertaken across the site which indicate there is no likely impact as a result of the proposal. Further investigation would be carried out as development proposals for the site progress. In accordance with emerging statutory requirements, development would also provide opportunities to achieve 10% Biodiversity Net Gain in order to provide a clear and tangible ecological enhancement over the existing baseline condition of the site. In this case, given the blue and green infrastructure opportunities identified by the Council in the immediate locality through the HDF document, it is perceived that development on this site could well exceed this.

3.4. Allocation of the site for residential development would be consistent with the objectives of the NPPF which seek to support sustainable development in accordance with the environmental, economic and social objectives. Development would make a significant contribution to each of these as set out at Paragraph 8 of the NPPF.

3.5. There are no known constraints that would prevent development of the site, and further detailed assessments would be provided to accompany any future planning application to address any perceived site-specific issues.

4. Deliverability
4.1. Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.

4.2. The Glossary of the NPPF defines deliverable and developable as following:
“Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
“Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.

Availability
4.3. AC Goatham, who own the site, have confirmed that the site is available. On this basis, and subject to its inclusion in the Local Plan, the site can become available in the first 5 years of the Local Plan period.
Suitability for Residential Development

4.4. The site is located on the main Ratcliffe Highway route, which directly accesses the Peninsula Way between the settlements of Hoo and Chattenden. It is served by good public transport services and a wide range of services/facilities. There are no perceived constraints that could not be overcome to facilitate residential development.

4.5. The site would be suitable for housing development, as a highly sustainable and logical extension to the settlement of Hoo and immediately adjacent to the Deansgate leisure centre. If the site were to come forward for a mixed residential / economic development, it could also sit comfortably with the adjoining existing and proposed site uses.

4.6. The site would form a positive approach to housing delivery in Medway. At an average 30 dwelling per hectares, often advocated in rural areas, the site could have an indicative capacity of up to 415 units; and depending on any possible allocation for economic and or retail purposes.

Achievability
4.7. Subject to the grant of necessary planning permission, the site is realistically capable of delivering development in the early phases of the Plan period. Development viability will be assessed by taking into account the affordable housing requirements, other obligations and market conditions at the time when development proposals are promoted through the planning application process. At this stage, there is no indication to suggest that there will be any viability issues for housing development on this site.

1.1. We are writing on behalf of our client, Mr and Mrs R Goatham, in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.

1.2. This representation promotes a site extending to approximately 0.8 hectares on the east side of Hoo, just west of the railway line at 1 Ropers Cottage, Ropers Lane, High Halstow, Hoo, ME3 8AD.

1.3. The site is allocated the reference HHH31 in the recent Medway Land Availability Assessment (LAA) 2023.

1.4. The site was recently promoted as part of land in response to the Hoo Development Framework (HDF) Consultation document which set out how our client’s site should be allocated to support the expansion plans at Hoo which the Council is carrying forward.

1.5. The site is owned by Mr and Mrs Goatham and at this stage is being promoted solely on their behalf.

1.6. This site, located in the Hoo Peninsula rural development area, could contribute to the Council's substantial housing requirements within the district, especially when joined with the neighbouring sites and identified as part of the plan.

1.7. It is considered that the site provides an opportunity for additional housing and or mixed development, and hence, positive growth in the Medway area to 2040.

1.8. This representation responds to the current Regulation 18, by setting out how the site meets the aspirations and broad spatial strategy being promoted in the Local Plan, specifically in the rural area. In addition to responding to each of the headings in the consultation document, and identifying how the site can deliver the vision and objectives through sustainable development.

2. Context
2.1. The production of the Medway Local Plan has involved several key stages. Three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final Regulation 18 consultation before the publishing of the Regulation 19 draft plan.

2.2. The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

2.3. It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development, but does relay key areas where development could come forward.

2.4. This representation seeks to promote a 0.8 hectares of land on the north eastern side of Hoo, the extent of which can be seen at Figure 1 below.

Figure 1 – Google Earth showing extent of site promoted in the Local Plan. (emailed separately)

2.5. The recently published interim Land Availability Assessment for Medway (September 2023) does include an assessment of the site, with site reference HHH30. This document recognizes the site does not comprise “Habitats Sites”, Irreplaceable habitat” and is not an “Area at risk of flooding”. It is on this basis that the site is recognized as capable of delivering 5 or more dwellings, or economic development of over 0.25 ha and which is recommended to proceed to Stage 2.

2.6. The strategic location and size of the site provides the opportunity for the delivery of a residential scheme with potential economic development which could be developed in isolation or more strategically with the neighbouring sites.


3. Site description and history
3.1. The Hoo Development Framework (HDF) document proposes that our client’s property be surrounded by built form on all sides. The extent of this is shown below at Figure 2.

Figure 2 – Figure 5.39 in the HDF document showing the approximate location of our client’s property and the area surrounding this proposed for development - our client’s site is outlined in red immediately to the south of the railway line. (emailed separately)

3.2. Giving due regard to figure 5.45 of the HDF document on page 103, logic would be that the bottom third of this currently excluded area be allocated as high yielding residential density (up to 50 dph) the middle section be allocated for residential development with a medium yielding density (up to 45 dph) whilst the most northern third be considered employment land or even housing at a low ot medium density. This would tie in well with the currently proposed scheme set out at figure 5.38 on page 99 of the HDF document as illustrated below at Figure 3.

Figure 3 – Figure 5.38 showing the summary diagram of the propsed ‘East of Hoo St Werburgh neighbourhood area’ as proposed in the HDF document and how our client’s site could be allocated having regard to this. (emailed separately)

3.3. The site is well located next to proposed development in a sustainable location. The proximity of a proposed pedestrian areas in the locality further supports good connections to existing and proposed bus links, pedestrian and cycle paths, which will all link well with Hoo St Werburgh.

3.4. Allocation of the site for residential development would be consistent with the objectives of the NPPF which seek to support sustainable development in accordance with the environmental, economic and social objectives. Development would make a significant contribution to each of these as set out at Paragraph 8 of the NPPF.

3.5. There are no known constraints that would prevent development of the site, and further detailed assessments would be provided to accompany any future planning application to address any perceived site-specific issues.

4. Deliverability
4.1. Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.

4.2. The Glossary of the NPPF defines deliverable and developable as following:
“Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
“Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.

Availability
4.3. Mr and Mrs Goatham, who own the site, have confirmed that the site is available. On this basis, and subject to its inclusion in the Local Plan, the site can become available in the first 5 years of the Local Plan period.

Suitability for Residential Development
4.4. The site is easily accessible off the main Ratcliffe Highway / Peninsula Way highway from Ropers Lane immediately to the north of Hoo. There are no perceived constraints that could not be overcome to facilitate development on the site.

4.5. The site would be suitable for housing development, as a highly sustainable and logical extension to the settlement of Hoo. If the site were to come forward for a mixed residential / economic development, it could also sit comfortably with the adjoining existing and proposed site uses.

4.6. The site would form a positive approach to housing delivery in Medway. Giving due regard to the range of possible densities that could be adopted on the site (as per paragraph 3.2 above) the site is capable at accommodating between 25 and 35 units – more, should high rise flats be considered; and depending on any possible allocation for economic and or retail purposes.

Achievability
4.7. Subject to the grant of necessary planning permission, the site is realistically capable of delivering development in the early phases of the Plan period. Development viability will be assessed by taking into account the affordable housing requirements, other obligations and market conditions at the time when development proposals are promoted through the planning application process. At this stage, there is no indication to suggest that there will be any viability issues for housing development on this site.

It seems that much of this work may be about meeting government targets rather than local needs. It may be useful data source, but its speculative in nature.

Can only ask that the Council stand up to National Government and work for Medway residents

How about including council tax payers and residents as well as builders etc. Surely one constraint is adequate schools, surgeries,not withstanding the fact that MEDWAY Maritime Hospital is overwhelmed now let alone with 28000 odd houses at end of plan. No good getting builders to build surgeries where are the staff coming from thin air. MEDWAY will be concreted over by 2040.

Constraints are there for a reason and should not be automatically considered as a negative. Sometimes constraints are valuable to sustainability.