Spatial Development Strategy

There is no need for development of the greenbelt or arable farmland when food security is essential. Brownfield and existing sites should be the main areas for delivery of any new housing. The current transport services are not adequate or reliable enough to reduce car usage.

It goes without saying that we need sustainable growth where hopefully all sections of the community will benefit. This will improve health and outcomes. We need to ensure our green spaces are protected.
In relation to retail outlets the Council needs to stop the incursion of multiple fast food outlets and encourage local shopping with greengrocers, butchers, bakers and grocery stores for people who don’t want to go into our towns which will encourage people to not use cars. Do not allow waterfront developments and deprive the community of access to the riverfront.

Brownfield sites may be less attractive to developers, but we have lost too many trees already. New ones planted will take decades to replace the benefits of the felled mature ones. How about making it conditional that a good proportion of each development contract must include brownfield, with the tainted soil deep-buried, refilled and trees on top?

Support local businesses. Why are you proposing to close Chatham dock. Thriving businesses there. Businesses we need to build all these houses and environmental help with recycling business. Employing local people with highly skilled jobs. They need the water to run these businesses. You will be displacing many employees who have trained for years. The labour council actively opposed the closing of the Docks until they gained leadership. You say support local businesses but you are not. Also part of our heritage is at the docks. You need to leave the dock alone.

The big opportunity is to repurpose the medway city estate into a 21st-century economic hub. Think of it as an opportunity for some of London's finance and technology businesses to access cheaper labour and real estate costs, and for scientific/tech research and development to join them. A canary wharf moment for Medway.
Doing this could alleviate the need to close Chatham docks, which are more in keeping with Medway's DNA, and would mean that jobs do not need to be lost (given Arcelor steel's position that the jobs will not be retained in the UK).

Support. Regeneration is key in an urban area like Medway. Needs to be more metropolitain in culture (walking, cycling, public transport). Some areas are too car dependent. Urban regen needs to be quality design. We are seeing too many poor quality designed flats being thrown up. Landlords need to ensure properties are looked after to make sure key thoroughfares look good! Won’t attract investment with the HMOs that are destroying conservation areas.

I greatly support the councils commitment to retaining the metropolitan greenbelt, I hope that this protection greatly considers not just current potential harm, but future harm considering the lower Thames crossing and its impact on air quality in the area, where the green belt will be so desperately needed.

I greatly support the increase in rail connections across Medway to contribute to a more connected public transport network.

TMBC note that Medway Council (MC) is planning for an identified housing need for 1,658 homes a year, over the plan period to 2041 using the previous government’s standard method. Clarification is sought of the base date of the plan, and the net need over the plan period taking into account all sources of supply.

TMBC note that this consultation commenced prior to the proposed revision of the standard method for calculating housing need as set out in the Government’s consultation National Planning Policy Framework (NPPF). Clarification is sough from MC on the potential impact on revised housing numbers and programme timeframes that may result from the publication of a revised NPPF later this year and the proposed transitional arrangements put forward as part of the NPPF and planning reform consultation.

The TMBC response to the previous Regulation 18 consultation in Autumn 2023 noted a request to Medway Council from Gravesham Borough Council, to consider if there is capacity to provide up to an additional 2,000 homes to help meet Gravesham’s housing needs. TMBC would welcome clarity on whether this request remains and if it has been accommodated within this Regulation 18 Local Plan.

Misleading and none reflect national planning
all will cause environmental damage
all contrary to NPPF policy on growth, food production, environment, infrastructure

You mention the innovation centre which I thought the new council has put on hold as the cost of it was too expensive to complete. Also you talk about the train at Hoo but the £170 million funding has been pulled on that and to honest unless you have lived out on the Peninsula, you haven't got a clue about how things work. Everyone out there relies on their car as the bus service is one of the worst in Medway.

Encourage and empower us all to assist in that process

Railfuture London & South East regional branch endorses, most especially “The strategy provides for the coordination of infrastructure delivery to support wider growth. Land is safeguarded for the delivery of a passenger rail service connecting the Hoo Peninsula to the North Kent services”

--Make neighbourhoods look good and have services & amenities nearby and new residents WILL flock to Medway. It's a simple yet effective strategy.
--Please fix the tarmac on Maidstone road from the Shell gas station to Blue Bell Hill is undrivable and unsafe.
--Garbage collection would be a lot more efficient (and economical) if we had big containers every second corner instead of the door-to-door approach.

Supportive of this spatial strategy - in terms of outcomes I think theres a need more focus on affordability of housing and the need for development to ensure delivery of affordable housing, particualrly for those in Medway on low incomes.

I object to the development on Capstone Farm which is an area of rural landscape adjacent to the urban centres of both Chatham and Gillingham and very necessary to support the health, mentally and physically of residents of Medway. It is also and area that draws visitors to Medway.

"Chatham will provide the primary centre function for Medway ... ". Does Medway need a single centre for the 5 towns (6, including Hoo) ? All have discrete identities. Specifically, reviving Chatham into an attractive centre for the 5/6 seems a heroic task - currently, the High Street is dismal.

The aspirations of the Spatial Development Strategy for Medway are supported, specifically, “Outside of the urban regeneration areas, the Council will support the expansion of identified suburban neighbourhoods and villages, where the principles of sustainable development can be met, and where unacceptable impacts on infrastructure and the environment can be avoided”.
Site HHH41 forms part of a grouping of sites to the west of Hoo St Werburgh, which have been identified as suitable for residential development. Although the individual land parcels are under different ownership and could be delivered individually, these sites, when developed together, will prevent isolated development and create a new neighbourhood area which would meet the aspirations of sustainable development.

Section 2.3, sets out that “Development will respond positively to the environmental context and realise opportunities to boost biodiversity and resilience”. The HHH41 site is a brownfield site which has limited biodiversity value. The opportunity to redevelop the site will enable the provision of biodiversity enhancements and the creation of a green infrastructure which will connect the site to adjoining sites and the wider countryside. On this basis, the redevelopment of the site for residential uses would enhance biodiversity in accordance with National policy aspirations and the draft proposals in the Local Plan.

Section 2.3 – Spatial development strategy
3.10 The spatial development strategy set out within Section 2.3 of the Plan states that it prioritises regeneration, making best use of previously developed land and directing investment into urban waterfront and centre opportunity areas. Whilst BDW is not unsupportive of this strategy in principle, there are significant issues in terms of the deliverability of this strategy and how this achieves mixed and balanced communities and is in line with Vision. In particular, the strategy notes that Chatham is an important focus for urban regeneration and there are significant concerns over deliverability in this location.
3.11 The Plan states that the spatial strategy provides for a range of development needs through growth in urban, suburban and rural areas. BDW do not agree with this statement and have fundamental concerns as to how the spatial strategy will deliver the required mix of homes throughout the plan period, given that urban brownfield sites tend to primarily deliver smaller, flatted development.
3.12 Outside of the urban regeneration areas, the Plan states that the Council will support the expansion of identified suburban neighbourhoods and villages, where the principles of sustainable development can be met, and where unacceptable impacts on infrastructure and the environment can be avoided. North of Strood has been excluded as an area of expansion, despite this location meeting the principles of sustainable development supported in the spatial development strategy.
3.13 Lastly, the Plan notes that the function and extent of the metropolitan Green Belt in Medway will be retained, and the Council will ensure that substantial weight is given to the potential for any harm when considering development proposals in the Green Belt. BDW disagree with this approach and consider that exceptional circumstances which require land to be released from the Green Belt clearly exist.
3.14 Overall, it is not considered that the Plan and accompanying evidence base can be considered sound. More detailed comments on the soundness of the spatial development strategy are considered later on in these representations.

Please refer to our full submission for further details.

The Plan, as drafted, does not demonstrate how the Council will meet its objectively assessed need nor does it adequately demonstrate the robust and consistent supply of housing throughout the Plan period, noting that the Council has a significant housing shortfall and has historically under delivered against its housing requirement. The Plan, as drafted, does not identify a strong supply of available sites that are deliverable within the early part of the Plan. The SGO is likely based upon some substantial allocations, and as the Plan is progressed the SGO should include sufficient flexibility to include alternative options which can deliver housing should the larger strategic sites fail to come forward within the Plan period. Currently, given that blended SGO approach we hold substantial reservations that a SGO that is significantly reliant upon large brownfield sites is deliverable, particularly in the early stages of the Plan, where planning permissions are required.

The Spatial Development Strategy set out within Section 2.3 of the Plan states that it prioritises regeneration, making best use of previously developed land and directing investment into urban waterfront and centre opportunity areas. Berengrave Lane 2 Ltd is supportive of this strategy in principle but there are concerns regarding the deliverability of this strategy and how this achieves mixed and balanced communities and is in line with suggested expanded Vision.

The Plan states that the spatial strategy provides for a range of development needs through growth in urban, suburban and rural areas. Outside of the urban regeneration areas, the Plan states that the Council will support the expansion of identified suburban neighbourhoods and villages, where the principles of sustainable development can be met, and where unacceptable impacts on infrastructure and the environment can be avoided. We support this position, but for reasons explained in the full representations submitted to the Council, believe that the North Rainham SDS and the site-specific assessment within the ISA must be revised due the flawed methodology and consideration. The Site at RN17 is clearly sustainable development – as demonstrated by the Council’s recent approach to nearby residential development – and the focal issue is the impact upon the ALLI.

Both the Spatial Development Strategy and the preferred Spatial Growth Options are generally positive and aligned with our Clients objectives, but ultimately needs to be underpinned by a reliable supply of housing which is capable of delivering the housing numbers that are identified in the Plan. This is not currently evidence and, in any event, should not rely upon substantial brownfield allocations, which have historically failed to meet the housing supply needs of the Council over the past 20 years. The supply of housing needs to come from a range of locations, sources and scales and be underpinned by allocations which are plainly deliverable throughout the Plan - this includes RN17.

Hundreds of new houses have been built on the Hoo peninsula. No improvement has been made to infrastructure. Schools are full and one even closed! Some families cannot even get their children all in the same school meaning even more trips in the car. Teachers are difficult to recruit in rural areas so are doctors. Rural areas provide valuable habitat to our wildlife that you will destroy. Houses will go into negative equity because of the impending lack of space created by building unnecessary houses.

The dispersed and blended options will not protect environmental resources in the same way that the urban option will. Neither will they secure landscape character nor provide resilience for nature. These options will not support mental health for which a sense of open space is needed.

CPRE Kent welcomes the proposed development strategy in so far as it prioritises regeneration, makes the best use of previously developed land and directs investment to urban waterfront and centre opportunity areas.

However, we cannot support a strategy that places such significant reliance on greenfield sites (on the Hoo Peninsula).

As set out in our comments on the 2023 Regulation 18 consultation we are concerned that the Council’s strategy has been dictated by the sites submitted by developers (as part of the Land Availability Assessment).

It is CPRE Kent’s view that this is a flawed approach to plan making as, consciously or subconsciously, it places too much influence in the hands of developers who will naturally prioritise their financial interests over the genuine needs of communities.

In this respect, such an approach inevitably leads to a strategy heavily weighted towards greenfield sites. The reason for this is it is greenfield sites that are almost unilaterally promoted by developers, as it is these sites which give the greatest profit.
Such undue reliance upon developer submitted sites inevitably leads to a haphazard spatial strategy that lacks a cohesive, long-term vision. This in turn neglects important aspects such as sustainable infrastructure, environmental considerations, and the social wellbeing of residents.

A far more effective approach would be for the Council to take firm ownership of the direction of the spatial strategy and then proactively identify potential development sites to deliver that strategy.

As set out below, this could include targeted call for sites. The spatial strategy needs to be grounded in comprehensive, evidence-based planning that prioritises the environment (and identifies the positive qualities and placemaking benefits of ‘constraints’ to the environment) and the wellbeing of both current and future Medway residents, rather than short-term developer interests.

It is our strong view that such an approach would naturally lead to a true “brownfield-first” spatial strategy, spearheading the regeneration and improvement of the Council’s urban areas. Likewise, we see significant constraints with respect to the amazing environmental and ecological features that the district is blessed with, particularly on the Hoo Peninsula.

See DHA/16849 Blowers Wood Representation sent via email for full representation.

Notably, no strategic objective deals expressly with the amount of housing that needs to be delivered. In the absence of clearly setting out what the housing requirement is and whether the Plan is looking to meet Medway’s needs (which it should), the process of using the currently drafted objectives to inform the Council’s assessment of different sites and locations for development cannot be considered as “Positively Prepared” or “Justified”, contrary to the NPPF (para 35).

We support the 'brownfield first' focus in the identification of residential allocations. We note that the former St John Fisher Comprehensive School is a preferred site, identified in the spatial growth option. This site can deliver 139 residential units in a highly sustainable location.

Accordingly we support Medway's draft spatial development strategy.

There will be no net zero achievement from this, green field sites should not be considered or allowed to be built on. North Dane Way in particular should be a protected area under the Kent downs due to the growth of Blue Bells and such

The Grays of Chatham site is a brownfield site in a waterfront location within Medway’s urban area, which has long since been identified for regeneration as a residential development site. Given the site's location close to Chatham town centre, our client supports making the most of brownfield sites such as this one.

We welcome the highlighting of Chatham as an important focus for urban regeneration, with proposed development within the Centre and along waterfront sites being encouraged with the overarching goal of Chatham becoming the primary centre for Medway.

Agree to many cars in Medway , improve transport links

The Temple Waterfront (CHR20) site is a brownfield site in a waterfront location within Medway’s urban area, which has long since been identified for regeneration as a residential development site. Given that the site is in a sustainable location which has formed part of a wider historical allocation, our client supports making the most of brownfield sites such as this one.

It appears to me that based on Medway Council’s past poor record in developing Hoo, they're simply going to build urban sprawl; soul-less housing estates of cheap boxes without infrastructure, healthcare, transport nor jobs simply to meet the current government’s housing targets and provide housing for London's population, London councils and people with jobs in London. The plan proposes that we effectively in all but name only become the newest outer suburb of London but without any of London’s benefits like jobs, better health-care, infrastructure, or transport. All the declarations that Medway will retain its identity are without foundation.