5.36

Given that the existing urban and suburban sites have the capacity to provide in excess of 19,000 homes between them and that development in rural areas will demand a significant transport infrastructure for which funding no longer exists. It is important that the focus of the local plan is on the urban and suburban areas where sustainable communities adjacent to existing public transport hubs are more easily achieved.

Development of the rural areas should only be proposed if development of 1900 homes over the plan period cannot be fully provided for within the urban and suburban areas and only if funding has been secured and implemented for the public transport hubs as outlined in the now failed HiF bid.

There is a large amount of so called available land for development on the Hoo Peninsula, you will ruin our wildlife and the reason that the rest of the people in the villages live here, to be rural! In a time where our environment, wildlife hangs in the balance this is a disgrace to have so much land turned into housing! There are plenty of other spaces around Medway, leave our Peninsula and it's wildlife in peace!

So very sad that Medway Council has no consideration for the environment and wildlife, you will kill this area with all the sites and amount of homes you want to build. Our children are going to grow up in a world with no wildlife and live in concrete jungle, the world is in serious decline around the environment and wildlife and England has the worst history of environmental declines in the world. I am so sadden that in 50 years time my children and grandchildren will be facing more impending doom.

It is important to ensure there is a suitable formal informal sporting infrastructure available to support the expansion in rural communities This will in part be driven from the evidence base provided by playing pitch and sports facility strategies.

Some of these sports could be equestrian, water sports, shooting, fishing and cycling and motorsports. Sports which are not easily accommodated in the urban settings.

Any rural development is unacceptable and unnecessary.

The potential rural population expansion on the Hoo Peninsula seems excessive. The quoted HIF figure of "up to 12,000" new homes by 2040 represented an increase of up to 121% on the 2021 HP census population of 23,699 (excluding Upnor and Frindsbury), using the ONS figure of 2.4 persons/dwelling in England and Wales in 2021 to give 28,800 persons for 12,000 homes. Specifically, for Allhallows, the LAA states a potential 705 new homes (excluding The Reeds) - + 100% vs. the 2021 census (1,692/1,683), using the ONS figure - &, for Stoke, 1,572 - + 146% (1,572/1,080).

Correction to my earlier representation. The LAA Stoke potential new homes figure is 655, not 1,572 (the potential population increase).

I'm concerned that there is a small orange blob on the map in Upnor but I can't zoom in enough to see where this is located - I hope it's not Hogmarsh Valley again.

Sites of special interest and areas with wildlife must be protected at all cost. Ours not right to further devastate our wildlife and countryside. These things are important to our wellbeing.

These areas are of international importance and current threats to their support for birdlife, biodiversity and natural habitat must be removed including all proposed large scale future housing development on the Hoo Peninsula. Depending on what emerges at Regulation 19 of the Local Plan will shape the need to record in detail the wildlife on the Hoo Peninsula before it is further adversely impacted by development

Building in these areas that are not designated greenbelt are important to the overall deliverability of the plan and without rural development the plan is unviable.

As these are of international importance current threats to their support for bird life, biodiversity and natural habitat must be avoided including all proposed large scale future housing development on the Hoo Peninsula.

the council has a duty to protect and I would suggest enhance this national and international area.
these plans would have a destructive impact on this area

By 2040 half of the peninsular will be under sea water.

These areas are of international importance and current threats to their support for birdlife, biodiversity and natural habitat must be removed including all proposed large scale future housing development on the Hoo Peninsula. Depending on what emerges at Regulation 19 of the Local Plan will shape the need to record in detail the wildlife on the Hoo Peninsula before it is further adversely impacted by development.

The site, at High Halstow, is identified within ‘Map 3 – overview of potential sites for Rural Development’. Paragraph 5.40 identifies that there is significant land for potential development for homes, jobs and services on the Hoo Peninsula. Hoo Peninsula represents a sustainable location for growth. Importantly, the site, at High Halstow (situated on the Hoo Peninsula) can deliver an important number of new homes, including affordable housing and supporting community facilities as part of a high-quality scheme that respects the village and local area and improves the environment.

The planning application for the site demonstrates that proposals at the site, in High Halstow, would contribute towards achieving sustainable development – in relation to social, economic and environmental objectives – and it would deliver a range of significant benefits. The site is deliverable, it is available for development now, it is suitable for development and development is achievable.

Lack of transport links and only one Road off they peninsula will restrict the capacity. Developing the land to the north west of the A228 will leave this community cut of from the local facilities and dependent on the car.

Making rural suburban is not the answer. The loss of this land to bricks and concrete will greatly impact the lives of existing residents negatively. Building in these areas is not sustainable as reliance on cars is inevitable. Crime and anto social beywill increase and the wellbeing of existing residents and potential new residents will be impacted. Changing the landscape in these rural areas must not be allowed - the Greenfield sites will be lost forever. The resulting sprawling estates ruin sites of importance.

These villages need to have their identity protected. People who live within our villages have chosen to for their rural location. We need to be sensitive to that and not over develop in these areas. Some very small villages may want some development to retain their services, but careful planning, talking with the parish councils to ensure it is not too much, too quick which will change the character and way of life for the residents.

The Reg.18 document states there is the potential for development in the rural areas to provide capacity for 14,621 homes. The majority of the potential rural sites are located on the Hoo Peninsula. The recent decision by Homes England and the Department for Levelling Up, Housing and Communities (DLUHC) to stop the £170m programme of Housing Infrastructure Fund support greatly impacts the ability to deliver sustainable homes on the Hoo Peninsula. This funding was aimed at unlocking homes by funding the construction of new roads and a new railway station and passenger service that would have connected the wider Medway and Gravesend areas.

A high-level review has revealed that those sites identified in the North of the Hoo Peninsula, which were assessed in the 2019 Medway Strategic Land Availability Assessment (SLAA), were reliant on HIF support, with a particular reliance on the delivery of sustainable transport measures and unlocking capacity on the surrounding road network. Without this support, the sites remain isolated without access to services and are considered unsustainable and therefore unsuitable for development. We understand that without the new railway station any development would be dependent on an improved bus service, however, a bus service would not be enough to unlock the residential sites required to meet the Council’s housing requirements and would put further strain on the local road network.

We also understand that National Highways are concerned the strategic highway network and the number of trips at Junction 1 of the M2, and that further development in the rural areas of Medway would be reliant on delivering a solution to the Strategic Road Network. This further emphasises that the sites identified in the further reaches of the Peninsula are currently unsuitable.

While it is recognised that to meet the Council’s housing requirements, development on the Hoo Peninsula may be necessary, the loss of HIF support undoubtedly impacts the ability to deliver a significant quantum of housing in parts of the Peninsula that are isolated and lack the services, infrastructure and public transport that are necessary to achieve sustainable development that meet the economic, social and environmental objectives, as set out in Paragraph 8 of the NPPF (2023).

Development of the Hoo Peninsula requires careful planning and considerable wider investment which is likely to take years to develop and implement. In this respect, the Hoo Peninsula represents a possible opportunity for longer term growth, but not an effective solution to delivering housing in the short term.

Other Rural landholdings

CCE appointed masterplanners to undertake initial feasibility studies for the smaller rural settlements, all submitted to Medway’s February 2023 call for sites process. The initial findings demonstrate that, taking into account the sites and their individual opportunities and constraints, the following sites could be suitable for development, including for residential use:

1 Land West of Allhallows (call for sites submission ID 294, SHLAA ref. AS21) - the site presents an opportunity for a sustainable extension to the existing Allhallows settlement. As the site is sustainable and accessible with no overriding constraints, we consider that there is scope for mixed use development including residential of up to 390 dwellings, tourism and leisure uses, open space and associated infrastructure. Development of this site would, therefore, represent a sustainable residential extension to the existing Allhallows settlement to support the existing primary school, local shops and doctor’s surgery.

2 Lower Stoke (call for sites submission ID 295, SHLAA ref. AS13) - the site presents an opportunity for a sustainable residential extension comprising around 655 dwellings to the west of the existing settlement, either side of Cuckolds Green Road, to support local shops and services. Depending on the scale of development, social infrastructure could be provided, but this would be dependent on the wider strategy for the surrounding Hoo Peninsula area. As the site is sustainable and accessible with no overriding constraints, there is scope for residential-led mixed-use development and open space.

3 Mackays Court Farm (Middle Stoke) (call for sites submission ID 302, SHLAA ref. AS16), Land at the Street (Stoke) (call for sites submission ID 301, SHLAA ref. AS11) and Land at Sharnal Street (call for sites submission ID 304, SHLAA ref. HHH28) – these three sites are sustainable and accessible, with no overriding constraints. It is considered that these sites present the opportunity for small scale residential development to diversify and strengthen the Local Plan’s housing trajectory, which should appropriately be made up of a range of large strategic sites (such as the Hoo Rural Town), and smaller sites.

4 Burney’s and Nord Court Farm - the site totals approximately 0.25 hectares and is located to the west of Stoke Road. CCE previously submitted a pre-application request in May 2023 (ref. PRE/23/1196). The Council concluded that the site could be suitable for residential development given its location on the edge of the village of Lower Stoke. The site is located in a sustainable location and is well related to the village of Lower Stoke which is served by a primary school, a GP Surgery, a church, a convenience store, a pub as well as a Post Office. A Site Location Plan is appended.

This representation therefore confirms that land within CCE’s ownership is suitable, available and achievable and could be identified to assist in meeting the housing requirements and development needs of the Borough. CCE support that these sites are all identified by Medway on Map 3 ‘potential rural development sites’ in the consultation document. CCE would be happy to engage with officers to discuss these sites and any required assessment work, masterplanning, infrastructure requirement analysis and phasing – which would be in the later stages of the Local Plan period.

In addition, CCE would also welcome the retention of a Policy in the Local Plan supporting the re-use of buildings in the countryside, similar to adopted Policy BNE27. However, it is recommended that existing criteria (vi)(a) which requests that applicants demonstrate ‘every reasonable attempt has been made, without success, to secure a sustainable business reuse for that property’ should be removed. Paragraph 152 of the NPPF states that the reuse of existing resources should be encouraged, including ‘the conversion of existing buildings’. Under paragraph 152, there is no prerequisite to adopt a sequential approach or to give preference to other uses. Furthermore, paragraph 80c of the NPPF is supportive of the reuse of redundant or disused buildings for residential use. Many of CCE’s rural landholdings above include agricultural buildings appropriate for conversion, which could assist the Council with meeting its identified housing needs in a varied way alongside larger strategic allocated sites.

Phasing

Delivery of the above sites could be achieved by first (in the short to medium term) expanding Hoo St Werburgh as a rural town for the Peninsula and then, in the medium to longer term, growing the existing smaller settlements. This will help the Council to meet their housing requirement and ensure that development is focused in accessible locations that support and enhance the local community and existing services.

Land to west of Pump Lane, Rainham

As stated above, Redrow has an interest in approximately 24Ha of land to the west of Pump Lane, Rainham (SLAA site: RN9).
It is considered that the land has good potential as an accessible, suburban expansion site, to deliver sustainable housing development that would accord with the draft Local Plan’s Vision and Objectives. There will be some constraints to development that need to be overcome/mitigated, but that is likely to be the case, in some form or other, across the Medway Council area. In this case, it is considered that these constraints could be appropriately addressed, through well considered proposals and a criteria-based allocations, for the reasons set out below.

A high-level illustrative layout, demonstrating how a scheme could come forward at land to the west of Pump Lane, has been appended to this representation.

Availability

As Redrow have an interest in the land and are promoting the site for residential development on behalf of the landowner, we can confirm that the land is available for early delivery. Redrow would be keen to engage with officers to discuss how this land could deliver new homes in the shorter term, while mitigating environmental and heritage impacts. In the Local Plan, these could be covered by a criteria-based policy linked to an allocation of the land for housing.

Addressing Potential Constraints

Redrow are aware of the appeal decision on this site (ref. APP/A2280/W/20/3259868) - the appeal site measured approximately 50Ha, whereas Redrow’s proposed allocation is only half of this, at 24Ha.Redrow are also aware of the concerns raised in the Reg 18 draft Local Plan regarding potential development in this broad area. However, it is considered that a carefully and sensitively design scheme could address the highway capacity issues and the harms identified by the Inspector.

Highway Capacity, Sustainable Transport and Access

The appeal inspector found that the residual cumulative impacts on subnetworks 3 and 7 would not be severe, but that is not the case for subnetwork 2. The residual cumulative impacts on that subnetwork would, in her view, be severe, particularly during both the AM and PM peaks. She recognised that those impacts would be confined largely to the peak hours and that the subnetwork forms only a part of the wider network.

A Transport Technical Note (TTN) has been prepared in support of these representations. The TTN outlines the multi-modal access strategy that could be achieved should a planning application come forward on this site; considers the accessibility of the site; quantifies the likely vehicular trip generation of the proposed development; and identifies appropriate and proportionate mitigation measures. In doing so, it addresses the reasons for refusal of the previous planning application and appeal concerning the wider landholding of relevance to highways and transportation.

The vehicular trip generation and distribution exercise presented below confirms that the impact of the proposals in this regard would be much-reduced relative to the previous scheme. It is further demonstrated that ongoing shifts in travel behaviour away from traditional peak period commuting, together with both ‘soft’ and ‘hard’ travel planning measures and ‘decide and provide’ mitigation strategies, will ensure that there would be no ‘severe’ residual highways impacts, in accordance with Paragraph 111 of the National Planning Policy Framework.

The note concludes the site represents a viable and sustainable location for development in transport planning terms and that the highways reasons for refusal of the previous outline planning application can be overcome.

Landscape

The site forms part of the Gillingham Riverside Area of Local Landscape Importance (ALLI). The area is characterised by scattered dwellings/clusters of dwellings, as well as the small hamlet of Lower Twydall, which sits to the west of the site, with the small village of Lower Rainham, which straddles the Lower Rainham Road to the northeast. Both settlements are designated Conservation Areas. Beyond the railway line, to the southwest, is the urban settlement of Twydall/Rainham with shops, services and good public transport links. To the north, east and west, the site is surrounded by agricultural land which extends up to the Medway Estuary. The Medway Landscape Character Assessment (MLCA) recognises that the Lower Rainham Farmland Character Area (LRFCA) identifies the area has value as an extended buffer to the Country Park and protected Estuary coastline, which lie to the north.

The Planning Inspector regarded the change in character as ‘distinct and abrupt’, as opposed to it being an area of ‘transition’ between town and country. The Inspector also noted that the development would, as a matter of fact, comprise a ‘significant and large scale development’. As such, she was of the view that the development proposed would be uncharacteristic and of a significant scale.
However, the Inspector noted that the site is generally well contained by mature vegetation, including woodland and tall hedgerows, limiting available views and extent of visibility. She also noted that the landscape effects would be experienced from a relatively constrained area around the site. It would, therefore, be possible to reduce the impact on the landscape with a less significant scheme for the site, that was designed to be more transitional - with pockets of development with an enhanced framework of landscaped breaks and buffers. A landscape led proposal (as shown on the attached plan appended to this representation) for the site could provide an attractive setting to the Lower Rainham and Lower Twydall Conservation Areas, with attractive views from the river and railway, forming a green backdrop in views from the Estuary.


Pump Lane

As an additional concern, the Inspector noted is that Pump Lane is an unlit, narrow, sometimes single-track country lane with no footways. Towards its northern end, it is fronted on one side by a small group of dwellings, but for the most part, it is lined along both sides with mature hedges/hedgebanks. She added that it is identified as a rural lane by policy BNE47 which, among other things, seeks to protect the landscape value of such lanes.

The Inspector went on to note that, for the appeal proposal, four new junctions were proposed on Pump Lane to facilitate its crossing by the proposed estate loop road and, in total, the new junctions on Pump Lane would require the removal of around 175m of hedgerow. The layout of the southern junctions would require any replacement planting to be set back significantly to allow for forward visibility and, at that point, the lane would cease to be narrow and it would no longer be enclosed by hedgerows. She therefore concluded that the highway would have the character and appearance of a residential access road, as opposed to a rural country lane.
However, on review of access proposals to the land, it is considered that there only needs to be a relatively small incursion on Pump Lane, at the southern end, to allow for emergency access, pedestrians and cycles to access the facilities to the south of the railway line. As such, that should not be a constraint to development and should be regarded as a benefit.

Heritage

The Inspector considered the extent of the development proposed would effectively subsume the village of Lower Rainham, and its Conservation Area, into the extended urban area of Twydall/Rainham, with the consequence that it would lose its separate identity and character as a rural village.

The Inspector found that there would be harm towards the middle of the less than substantial range to the special interest and significance of the grade II listed Chapel House, and to the heritage significance of Lower Rainham Conservation Area, with harm identified to other of the designated assets to be at the lower end of the scale. Any harm to the significance of the non-designated Bloors Oasts would be very minor.

Overall, the Inspector concluded that the very substantial benefits that would arise from the appeal scheme, primarily the delivery of much needed new homes, to be sufficient to outweigh the heritage harm identified both individually and collectively. A smaller, well design scheme could avoid any heritage harm.

Conclusion

Overall, it is proposed that a high quality, sustainable housing scheme, delivering policy compliant affordable and family housing to meet short term needs, that would meet the Vision and Objectives for the Local Plan could be achieved on land to the west of Pump Lane, Rainham.

We trust that these representations will assist in ensuring sustainable and deliverable development within Medway to help meet the Council’s vision and strategic objectives as set out in the Regulation 18 Local Plan.

Richborough are promoting a Rural Development Site for a mixed use residential-led development of around 800-900 dwellings, a local centre and new primary school. The Site is Land off Lower Rochester Road and has been given the Site Reference SR17 in the Land Availability Assessment (LAA). The Site is shown on Map 3 – overview of potential sites for Rural Development. However, it should be noted that the Stage 1 Land Availability Assessment proforma for Site SR17 classifies it in the ‘Suburban’ Group.
Richborough submitted the site to Medway Council as part of the Call for Sites consultation in 2023, and included a Vision Document with the submission which presented a technical assessment of the site, a review of constraints and opportunities and also an Emerging Concept Plan.
The Site comprises approximately 48.3ha of land to the north of Wainscott and predominantly comprises agricultural land. Blacklands Farm lies in the south eastern corner with a residential dwelling and six farm buildings. There are Polytunnel structures situated in the eastern extent of the Site. Agricultural buildings and hardstanding associated with Sole Street Farm lie within the south western corner of the Site.
The Site is bound to the:
• North west entirely by Dillywood Lane
• North east and east by Higham Road/ Bunters Hill Road and rear gardens of properties along Higham Road
• South by the A289 Hasted Road, residential properties and a tree belt
• West by the B2000 Lower Rochester Road, residential properties (Springfield Cottages) and agricultural land
Beyond the A289 Hasted Road to the south is the settlement of Wainscott, whilst to the north, east and west is agricultural land with scattered residential dwellings and farms. The Site lies close to the boundary with Gravesham Borough Council. The boundary with Gravesham also forms the Green Belt boundary to the north, with a small section of Green Belt within the Medway Council authority area, to the west of the Site.
There are existing amenities and services nearby which can be reached on foot, bike or public transport, although the scale of the proposed development ensures the Site is relatively self-sufficient with provision made for a local centre and school.
The Site is also located close to existing public transport links to Wainscott, Chatham and Strood, although there is an opportunity to introduce a bus service through the development; this will most likely take the form of a circular service connecting the Site with Wainscott, Strood Railway Station and Strood Town Centre, with a 30-minute frequency considered to be viable.
There are two railway stations close to the site, Higham and Strood, both stations have regular services to London St Pancras, Luton Airport, Gravesend, Ebbsfleet Maidstone and Chatham. The Site is clearly sustainably located.
The Consultation Document highlights that much of the Hoo peninsula is the subject of statutory designations and highlights its national importance in respect of ecology. The Site promoted by Richborough is not affected by any statutory ecological designations such as SSSI’s, SPA’s or Ramsar sites.

Land at Allhallows, Rochester, Medway

31. Catesby Estates is promoting Land at Allhallows, Rochester, Medway (“the Site”) for residential-led development through the LP2040. The Site is identified in the Council’s LAA as one of the sites put forward within the ‘rural areas’. The enclosed Site Location Plan details the extent of the Site and a Vision Document providing more detail regarding its context, opportunities and constraints, and development potential is also enclosed with these representations.

32. The Site directly adjoins Allhallows’ southern and eastern boundaries and has the opportunity to deliver new homes and facilities to support the growth and function of Allhallows as a self-sufficient and sustainable year-round community, alongside supporting nearby employment growth at Hoo St Werburgh, Grain and Kingsnorth. The Site has the capacity to accommodate circa 350 new homes, via a landscape-led development approach.

33. Figure 3 within the accompanying Vision Document details the Site’s immediate context, opportunities and constraints. It also demonstrates the significant caravan/holiday park accommodation that is located within Allhallows, which is considered an issue for its year-round vitality and social prosperity. Given the vision of the LP2040 is to boost economic activity and promote inward commuting patterns, existing settlements such as Allhallows have the opportunity to accommodate new sustainable growth that will benefit existing residents, helping to spread the vision across Medway. Moreover, Allhallows already has key infrastructure such as a primary school, community facilities and a GP surgery, therefore the proposed development will help complement the existing services and facilities, making Allhallows a more sustainable community.

34. Figure 7 within the accompanying Vision Document demonstrates the emerging context of Medway following the publication of the LP2040 consultation. Hoo St Werburgh and the Hoo Peninsula are key areas for Medway, alongside the areas of planned employment growth at Kingsnorth and Isle of Grain. Allhallows is situated on the northern coastline, approximately equidistant from Kingsnorth and Isle of Grain. The Site’s location therefore provides a choice of new homes within a commuting distance of two planned employment growth areas, helping link up existing communities with future economic prosperity.

35. These new homes and year-round population will assist in sustaining the existing services and facilities within Allhallows, as well as supporting enhancements in the range of local services and facilities and therefore the general future sustainability of the settlement. It should be noted that enhanced services and facilities are likely to boost the seasonal population of the holiday parks and lead in to an increase in tourism trade for Allhallows and the surrounding areas.

36. In addition, Investment in on-demand public transport links between Allhallows, the Isle of Grain, Kingsnorth and importantly Strood (for train links and secondary education facilities) will all be explored as part of the development proposals to further reinforce the sustainability and connectivity of Allhallows within the Hoo Peninsular.

37. The Site is considered to support the Councils four strategic objectives set out within the LP2040, as detailed on pages 12 and 13 of the accompanying Vision Document, but in particular support for development on the Hoo Peninsula and at Allhallows.

38. Marrons and our client Catesby Estates would be pleased to discuss the Site and its development potential further with the Council, as appropriate.

These areas are of international importance and the current threat to their support for birdlife , biodiversity and natural habitat must be removed including all large scale future housing development on the Hoo Peninsula.

it is noted that there is identified site located in close proximity to the existing wharf operations at Cliffe. To confirm any future proposed development at this site must give close consideration to the Agent of Change principle included in paragraph 187 of the National Planning Policy Framework (NPPF) (2021) which states that existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established, and where the operation of an existing business or facility could have a significant adverse effect on new development in its vicinity, the applicant should to provide suitable mitigation to address these matters. This must be referenced within the Local Plan.

Development of the Port Medway Marina would cause the naturally defined boundary between Cuxton and Strood to be further eroded. By connecting Cuxton to Medway Valley Park through development would close the natural buffer between the two and could provide a footing for future developments to merge the areas and allow for Cuxton to fall victim to becoming engulfed by an expanding Strood town. The M2 and HS1 is a defined boundary between the two and the remaining undeveloped land provides the buffer, this development will remove the buffer.

Sites of Special Scientific Interest (SSSI) across the peninsula, which are of national importance. The coastal marshes and mudflats and areas of woodland shape the distinctive character and feel of the peninsula. These landscapes are valued for their sense of place and remoteness, all the more special, given their proximity to urban Medway and must be protected at all costs.

We should avoid building on rural land unless it can be demonstrated that it is no longer viable for agricultural land.
Developments should be kept small to avoid overwhelming existing residents.