5.15

We refer to our comments regarding proximity to public transport hubs and the assessment of sustainability outlined in Para 5.7. Furthermore, we would suggest that once sustainable options for development have been identified the notion of a sustainable phasing should be considered for inclusion in the local plan by Medway Council. This could look something along the lines of

• Phase 1 – sites within 800m of existing transport hubs and local services
• Phase 2 – river frontage sites adjacent to newly developed water-based transport systems
• Phase 3 – rural sites located around newly provided rail hubs.

This would allow time for the funding for the proposed river transport system and the rail extension into the Hoo peninsular to be identified and secured along with the design and implementation of these new initiatives.

The council should always be clear and transparent about the outcomes from the Strategic Assessments and as a matter of course openly share the documents and assessments leading to their decisions. History has shown there has been an absolute unwillingness to do this especially in terms of the proposed development of circa 800 homes at High Halstow. Be honourable going forward. Give residents confidence in your commitment to protect us.

Sufficient sites/land must be allocated in sustainable locations, focussing on urban areas and brownfield land to achieve future growth requirements and housing needs and provide for a range of sizes, types and affordability. Planning applications for development proposals need to be viewed proactively and positively and determined expeditiously to provide developers with confidence to invest and deliver the range of accommodation that is required for the future growth of Medway. Viability of development proposals, notably on brownfield land, will need to be a material consideration and a flexible approach needs to be adopted by the Council when determining such proposals.

coalescence of settlements should be avoided. The A228 is a long corridor of developments that is eroding the distinction between Halling and Cuxton. Any further development in these villages should be avoided.

It is noted in paragraph 5.15 that the LAA have identified land with the potential capacity
for c 38,200 homes. These sites will be taken forward to the next stage of detailed site
assessment. It is important that these sites are not discounted early-on before any final
housing numbers are decided.

We need to avoid too many expensive new dwellings at the expense of local residents' needs.

Development along Rochester Riverside has taken some time to build out. Many riverside footway/cycle links remain closed as a result. The reclamation of land providing opportunities' that needs to be built out much sooner than later. However developers can only sell up to 50 dwellings per year to make it financial viable. The site should be split for more developers to purchase then to build out.

Current housing development appears to be targeted at wealthy inward migration and this seems set to continue at the expense of local residents and local democracy. Please note sub-standard, poorly designed houses at Cliffe Woods selling for £800,000.

COMMENT ON PARA. 5.15

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.

ArcelorMittal notes the reference to ‘this level of housebuilding would mean the transformation of…waterfront areas…’ This should not and cannot be to the detriment of existing, viable employment generating sites such as Chatham Docks.

Evidence submitted to the Council on behalf of ArcelorMittal confirms that Chatham Docks is viable and has an important and significant role in Medway and the South-East.

In particular, the submitted economic and financial assessment of Chatham Docks by Independent Port Consultants concludes that ‘in view of the cost estimate, financial viability and impact on jobs and revenue if the operation is made to close, ending the operation to render the land available for alternative uses does not make economic sense.’

Chatham Docks is a thriving industrial dock. 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.

There are approximately 180 ship movements a year taking advantage of the non-tidal docks – it is a very sustainable operation taking full advantage of the dockside access. The dock use cannot be re-located, there is no other suitable site in Medway for its operation.

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

There is no infrastructure to support this level of development. Health, Education, Roads - these are all at capacity and are already unable to support the existing population within Medway. To take steps, through significant levels of housebuilding, to significantly increase the population further will only make this worse. Your projections on population increase are flawed as they are self fulfilling - if you build more houses, people will move into the area - and will be unable to be supported by the lack of infrastructure. Infrastructure first for the people who already live in Medway.

Currently included in the maps are areas which are not suitable for development. For example North Dane Wood on Lordswood Lane is marked in the East Hill applications as being ancient woodland but has been put forward for development. The same land owners have also used this woodland in their East Hill development as forming a neighbouring green route for wildlife to support their development. This cannot work both ways and given East Hill has approval, this woodland must remain. Also included are Hempstead Road allotments which are also vital. I therefore have concerns that due diligence hasn't taken place.

Stage 2 of the LAA is underway and involves estimating development potential of identified sites. It's critical that this should not be an exercise of applying an arbitrary / capped density per hectare thresholds for relevant sites. Such an approach would fail to optimise the use of sites which can evidently deliver high density development in accessible locations.

Applying density thresholds on identified ‘Urban Regeneration’ sites restricts the most efficient and effective use of suitable, available, and achievable sites (key criteria for Stage 2 of the LAA) without giving full consideration to its development potential through the development management process.

It is noted in paragraph 5.15 that the LAA have identified land with the potential capacity for c 38,200 homes. These sites will be taken forward to the next stage of detailed site assessment. It is important that these sites are not discounted early-on before any final housing numbers are decided.

Suggest this work is reduced in scope as it's not about meeting our actual needs for housing which are more modest than external imposed targets. A top level assessment should allow the LAA to be filtered down to a realistic level. Lets not waste money on this.

Richborough supports the clear intention to transform the Borough’s poor track record on housing delivery by seeking to meet identified needs and the acknowledgment that this will lead to “the transformation of urban centre and waterfront areas and large-scale development in suburban and rural areas”.
Richborough supports the strategic approach to the distribution of development referred to in this statement, which recognises that the scale of housing need will have transformational impacts across the entire Borough. Richborough is of the view that the identified needs can only be met if development is allocated across a range of areas, including those where development is most viable and not solely focusing on the Hoo peninsula and urban locations. This is particularly the case since the withdrawal of the HIF funding.
The paragraph refers to the Land Availability Assessment identifying a capacity for 38,200 homes which will proceed to the next stage of detailed assessment. Richborough supports the intention to assess these sites rigorously and agrees that given the Borough-wide constraints in regard to environmental considerations, infrastructure requirements and viability, many of these sites will not be found to be suitable, available or achievable.
Richborough is also of the view that rigorous viability work needs to be provided that tests all modified development management policies, including changes to Building Regulations and likely changes to the NPPF, so as to clearly evidence that they do not result in onerous requirements that would prohibit much needed sustainable development being brought forward.

Why are we meeting the needs of Londoners on good salaries. I think they themselves would prefer to reduce their commute and stay living in London if their housing needs were met there!

The RSPB understands the pressures of national targets on housebuilding in Medway, and that the HIF funding has been revoked, requiring the Council to re-examine a broad range of potential locations for development across the area. This includes assessing what level of housing can be sustainably delivered across the Hoo Peninsula given the impact of the withdrawal of this infrastructure funding. We believe this is an opportunity to reassess development needs and options and to ensure development is located in the most sustainable locations, to establish a truly sustainable strategy for the long term. We welcome the steps the Council has taken to reassess potential development sites via the Stage 1 Land Availability Assessment (LAA), the broad results of which are presented in the draft local plan consultation. It is critical that a Sustainability Appraisal (SA) of these sites is undertaken (individually and cumulatively) in order to properly understand the relative impacts of new development in the broad locations shown. This would require an evidence base for site allocation. We have serious concerns that this updated SA is not yet available for review. Given the Government guidance on the need for the SA to be undertaken iteratively and to allow assessment of reasonable alternatives to any preferred option, we anticipate that the Council will need to undertake a further consultation including this important assessment work ahead of the Reg 19 consultation, to avoid risks of the final submission draft being found unsound. We request confirmation of the Council’s intention to carry out a consultation on a revised SA well in advance of a future Reg 19 consultation.

My word the mitigation needed would be phenomenal perhaps unachievable.

I don’t accept the scale of the plan to be necessary. If this aspect is accepted then it becomes acceptable like so many of the ecological disasters which are now enveloping our ecosystem.