5.27

You must also consider Parking. Parking is already a nightmare in the roads around Chatham. On road parking does not provide enough space, so people are parking on grass verges and other areas where they shouldn't be. It's not their fault, they need to park their cars. This must be considered when building houses - specific car parks on the land should be provided.

Medway council should consider the sustainable benefits of mixed-use communities and developments across the urban, suburban and rural development allocations these developments should include:
• Ease of access to public transport hubs
• Services
• Social infrastructure
• Lesuire facilities
• Open green space
• Green transport routes (footpaths and cycle ways)

In areas of significant housing growth, appropriate funding must be consistently leveraged through developer contributions for health and care services in order to meet growing demand. We request that when setting planning obligation policies, the Council seek to address strategic as well as local priorities in planning obligations and engage the NHS in the process as early as possible.

These comments are supported and the Council's objective should be for development of brownfield land ahead of greenfield release.

Yes, any development must be sustainable with appropriate infrastructure.

Nobody will disagree with that sentiment however without a tangible idea of how you plan to do it its impossible to comment further

NHS Kent and Medway Integrated Care Board (“The ICB”) supports the focus in the consultation that provision is made through the Local Plan for investment in expansion/ upgrade of existing healthcare facilities and additional healthcare facilities to support a growing and changing population. The ICB and Medway and Swale Health and Care Partnership will work with Medway Council through the Local Plan development process to inform and secure future healthcare infrastructure plans and requirements as part of the healthcare infrastructure estates strategy for Medway.

The developments that we have already, aren’t adequately and conveniently supported by services. The Local Plan must address the needs of the existing residents who lack convenient non-private-car based access to schools and health facilities.

Our client supports the aim to deliver sustainable development, which can be achieved on the Site by providing a mixed-use development including potential for a foodstore albeit with flexibility on uses to ensure that homes are supported by appropriate services and facilities, subject to commercial viability.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

The developments that we have already, aren’t adequately and conveniently supported by services. The Local Plan must address the needs of the existing residents who lack convenient non-private-car based access to schools and health facilities.

New item for inclusion under Issues and Constraints – Higher temperatures are more prevalent in urban areas. Increasing temperatures are already being experienced, and for longer, as a result of climate change. Consideration will need to be given to the design and balance of development against the need for green infrastructure to mitigate urban heat islands through cooling and shading. Similarly consideration will be required to mitigate the likely increase in impermeable surfaces and subsequent surface water flooding, through appropriate SuDs and/or green infrastructure.

There is insufficient health infrastructure to support the existing population within Medway. Prior to any significant increase in new housing/population, this must be addressed first - to do otherwise is recklessly risking the health and lives of Medway Residents.

Yes, it is essential infrastructure including transport, health and education provision are guaranteed before any new homes are agreed.

We support the objective to encourage the re-use and redevelopment of previously-developed land. Such redevelopment should seek to preserve existing mature trees and protect existing habitats on biodiverse brownfield sites. It is also important that urban sites have good green infrastructure. High density housing should seek to accommodate trees along boundaries, paths and in areas of public space. We recommend a requirement to retain and incorporate existing trees, plant more and maximise the use of green walls, urban hedgerows, green roofs and SUDS.

Whilst Richborough agrees that residential development in urban areas presents opportunities for regeneration, the quantitative and qualitative needs for housing in Medway cannot be met only in these areas.
The PPG provides guidance (paragraph: 018 Reference ID: 3-018-20190722) on assessing the suitability of sites and highlights the following factors for consideration:
• appropriateness and likely market attractiveness for the type of development proposed;
• contribution to regeneration priority areas;
• environmental/amenity impacts experienced by would be occupiers and neighbouring areas.
Urban core developments are typically high density apartment-led schemes, which deliver smaller homes with limited private amenity space.
Table 6.1 of the Local Housing Needs Assessment (LHNA) (October 2021) provides the overall annual dwelling type and tenure mix recommendations and shows that 15-20% of new housing is recommended to be 1 bedroom flats and 20-25% 2 or more bedroom flats. While this shows that there is an identified need for smaller flatted development in Medway, the majority of the need remains for larger houses. These typologies clearly do not accord with town centre locations.
Paragraph 5.11 of the LHNA confirms that the expected housing choice for 65.3% of older households is to downsize. The stakeholder engagement summary provided at paragraph E9 suggests this is a desire to downsize to bungalows or small units in “community-based” developments. These identified needs do not necessarily align with significant urban area growth and would more likely be met through suburban development.
In respect of affordable housing need, Table C9 of the LHNA provides a comparison of existing affordable housing stock against annual need by bedroom numbers and it is clear that there is a particular shortfall of 4 or more bedroom affordable dwellings. Given the high density nature of residential developments in urban locations, due to land availability and viability pressures, it is unlikely that this shortfall in qualitative affordable housing need is going to be met in urban areas. Richborough is also concerned about the potential for such schemes to deliver any affordable housing at all given the possible viability issues. Further work is needed to be able to demonstrate that the affordable housing need can viably be met at both a Borough-wide level, but particularly on sites in the urban area. If affordable housing cannot viably be delivered in these areas, additional residential allocations will be required in more viable suburban or rural areas to ensure the Borough’s qualitative housing needs are met.
With regard to the delivery estimations for land in the urban area, such as Chatham Waterfront for example, there are inherent risks associated with relying on new residential markets to emerge in town centres in order to meet a Borough’s housing requirement. This approach places significant burden on these locations given the context of them not being established residential locations with appropriate services and amenities and being reliant on developers providing or contributing to new residential markets from a standing start. It would therefore be prudent for the emerging Local Plan to progress with conservative estimations on delivery in these unproven locations so that if delivery falls short this does not undermine the delivery of the Borough-wide housing requirement. It is for these reasons that Richborough has suggested applying a non-implementation discount to sites in the urban area. For instance, the Submission Version Local Plan for Dover District Council has included a 5% non-implementation discount on sites in certain areas within the housing trajectory.
The urban areas have acknowledged availability and viability challenges and an out of date Local Plan that has relied too much on residential development in this location has failed to address the market attractiveness of the claimed supply. Richborough are therefore promoting a mixed spatial strategy for residential development, with growth being appropriately spread across the Borough to urban, suburban and rural locations.

The needs of existing residents who do not have access to convenient non private car based transport and services also need consideration

This is a key point. Vast housing estates with few or no facilities certainly won’t encourage a healthy life style and a sustainable community.