3.2.1

Agree that SGO 3 is my preferred option.

Urban Focus is my preferred option, and I think most residents would rather keep their natural spaces too.

If you care about the heritage of the area so much, then don’t build over it. Nature is integral to our culture and history and the council can never replace them. Medway’s environment is precious. It is about more than Rochester’s tourism - its farming, agriculture, public footpaths, the countryside.

You do not need to build homes here, you can provide enough through the urban plan. Lead by example and protect our environment like you claim to want to do.

For me living in Hempstead in order to maintain the village ‘feel’ the only suitable option is the Urban Focus. With the threat of Lidsing being thrust upon us from Maidstone Borough Council, plus numerous suggested additional building around Capstone, Lordswood etc, our green fields and open spaces will disappear and we will become part of another new urban sprawl. Although we are fighting the Lidsing build, this has not been taken into account at all for the people of Hempstead when looking at Medway Local Plan. We will be suffocated from all sides if this goes ahead and therefore I am favouring the Urban Focus which minimises the building in this area. It is much better to use brownfield sites in my mind as much as possible, with better use of transport systems and less use of cars.

As a resident of Allhallows I am horrified with the proposed development here. We have no extra drs, dentists, shops, nothing. This village is empty of any facilities mentioned in your proposals. The only thing we have here in abundance is nature. The wildlife here is diverse and precious. Hoo is being housed over at a rate of knots. Areas for wildlife gone. I see plans for housing on an area we call the Brimp, this is another green space gone. There are no areas for recreation here other than Crosspark? And the maps provided are blurry, is this intentional?

In addition to my previous comment. Option 1 should be the preferred one, with a view to protecting the peninsula and it’s outstanding birdlife here and farm land. There is also the issue of one road only onto the peninsula. It cannot support any more traffic, or into Allhallows.

I am very concerned about growth in the Lordswood, Darland, Lidsing area. Maidstone Council are also looking to build a Garden Village here. There are many environmental concerns about how much green land will be lost to urban spread. The biggest practical issue I see here is traffic management. The areas between Luton, Hale, North Dane Way, Ash Tree Lane and Pear Tree Lane already see huge traffic jams at peak times. Public Transport is not going to be used in the short term at least, it will mean more cars.

I live next to Rede Common.
Taking the common would, destroy wildlife habitats pushing an already vulnerable eco system to live in an urban environment where there will inevitably be conflict, ruin my and my 93 1/2 year old mothers standard of life, cause flooding due to run off, devalue my property (will we be compensated for losing the common), attract crime, take away common land that is meant to be for the people not for the council to make money by developing, increase pollution, deny the residents opportunities as a community. Has The Commons Team in Bristol been contacted.

Railfuture London & South East regional branch endorses this.

As a resident of Allhallows village I feel there is little or no infrastructure to sustain the proposed plans of housing, we have one road in one out, our water supply is constantly broken leaking. We have one tiny school now as the other school in Lower Stoke was closed. We have a satellite doctors surgery which is only open for limited hours, no shops. The Haven holiday Park has grown now covering the lower half of the Thames peninsula. Development will not be council housing ,all of this would put pressure on an already struggling infrastructure!

--Whatever the option, people need to have services & amenities nearby. Nobody really wants to move into a neighbourhood here you need to drive for everything. Provide services & amenities + offer clean streets and new residents will surely flock to Medway. In essence, it is simple.

SGO 3 on balance appears to be the best outcome - providing sustainable medium density growth in core urban areas and more sustainable suburban growth. However a significant step change in sustainable public transport is required - current policy path will not acheive this.

Additional housing in the Allhallows area is likely to put an additional strain on an already stretched availability on doctors appointments which are nearly impossible to get already, there is only limited schooling options with one already closed down, there are constant water leaks along the one of only two roads leading to the village, and numerous power cuts as all the power cables are above ground and at the mercy of the weather. The infrastructure is already creaking and extra housing in this area is not viable. Also, there is no employment opportunity's in this area.

Concerns for development near binney road/stoke road are:
No one seems to be slightest bit concerned about flooding and general failures that exist with the infrastructure. 2.already there is so much traffic in the village it hinders access for emergency vehicles and more traffic could be a danger to horse riders cyclists,children pedestrians.3.it is devastating for those people of which I am one who have recently been sold their homes with paramedic views only to find they will be directly looking at a housing estate. The new 9 houses built on a farm in binnney road have not all been sold yet,I believe the in adequate transport system and commuting is to blame. 4. So much for no farmers no food ,you can not grow food on a housing estate, what happens years down the line when we do not have enough land to grow food. Because we are over populated.5. We have a very limited dentist and doctors appointment system, we have to complete basic doctor information ourself on our mobiles( tale blood pressure etc) 6. Land line/mobile/Internet communications is poor. 7.we have a water leak at the bottom of binney road combined with the flooding that happens every year, the ice on the roads is tretcherous. 8. The binney road lane is not suitable for loads of traffic.9. The sewage house smells and is often temporary fixed by pumping it out using several large lorries on a single track lane. The village can not take any more. We are inundated with cars heading for the holiday park. The village also gets cut off in bad weather and road accidents. 9.the four elms round about and surrounding roads and round abouts are appalling at busy times now,(from 14.30) let alone with 1 more house being built on the Peninsula god forbid there is an accident at any one of the mentioned, we are sitting there for several hours sometimes. The area cannot take much more, a new school has been situated right near the medway tunnel(maritime) we are yet to see what chaos this brings to the elms round about. The infrastructure that you have planned for allhallows is too much and the area will not cope.

I am deeply concerned about the proposal to build a major development in Allhallows. The village already struggles with limited services and infrastructure. The statement on the Catesby website claiming that Allhallows has a wide range of facilities and services is misleading.
It’s clear that developments are inevitable in Medway, but this particular project would significantly alter the character of Allhallows. Given the scale of the development relative to the size of the village, it would transform Allhallows beyond recognition.
Additionally, this development would further harm local wildlife, which is already under significant pressure from ongoing projects throughout the peninsula.
Finally, I want to mention how challenging it has been to submit these comments. The process seems unnecessarily complicated, and I worry that many less computer-savvy residents will find it nearly impossible to provide their input. Perhaps this is intentional?
Thank you for taking the time to read my concerns.
Many thanks.
Jamie.

Reluctantly, I support SGO3 (Blended), as a compromise - ideally, SGO1 (Urban Focus).

Under SGO3, the maximum expansion of Allhallows is 705 houses, including only AS21 and 23 - roughly doubling the current population.

Restricting AS21 westwards to a line due north of Stoke Road would neatly reduce this.

Section 3 ‘Spatial Growth Options’:- The choice of the preferred option ‘SGO 3’ is supported. This option blends regeneration and greenfield development, specifically with a 'brownfield first' focus. Site HHH41 is a brownfield site, that would meet the aspiration of this growth option. The redevelopment of the site would provide a better outlook and amenity for its current neighbours, and as previously stated would enable an increase in biodiversity and habitats on the site.

Paragraph 3.1.5:- In considering options for sustainable development in Medway, the Council has sought to direct growth to brownfield sites first. This seeks to make use of previously developed land, and secure investment in regeneration. This position is supported. However, this regeneration agenda, which has been integral to Medway's change and growth in recent years, has focused on the evolution of town centres first. Future regeneration should not lose sight of sites that do not fall within the traditional Medway conurbation towns if there are also brownfield sites that would support the ‘brownfield first’ approach in the rural area.

I would like to object to the plans for the development of allhallows .this will lead to overcrowding of a small village and the facilities we have will not be enough for more people .
The roads will not sustain so much more traffic and our green spaces will all be taken .

Section 3.2 – Preferred spatial growth option
3.15 BDW does not agree with the Council’s preferred spatial growth option and fears it will fail the tests of soundness set out under paragraph 35 of the NPPF (December 2023).
3.16 As set out previously within these representations, the Plan period should be extended to 2042 and land for a minimum of 1,658 additional dwellings be sought, with the overall need increasing to 28,186 dwellings across the plan period. The preferred spatial growth option must ensure that this quantum of housing can be actually delivered in the plan period. This is likely to necessitate those sites where there are uncertainties over delivery within the plan period to be identified as having the potential to be brought forward within the plan period, but not as committed numbers in the delivery pipeline. At present, it is not apparent that the Council has undertaken the research necessary to determine the capacity of the chosen sites and whether the spatial strategy can deliver the number of homes suggested.
Reasonable alternatives
Housing target
3.17 Notwithstanding the above, the Regulation 18 Interim Sustainability Appraisal Report (June 2024) which accompanies this consultation only considers two “reasonable alternatives”. Option 1 meets Medway’s Local Housing Need and Initial Objective Assessment of Employment of 22,643 homes and 274,663sqm of employment land across the plan period. Option 2 delivers the same level of employment land and 2,000 additional homes of Gravesham’s Unmet Housing Need.
3.18 The Planning Practice Guidance (PPG) states that sustainability appraisals are integral to the preparation and development of local plans. Paragraph 11-018-20140306 of the PPG requires reasonable alternatives to be “sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made”.
3.19 The two options assessed in the Sustainability Appraisal are not considered to encompass all reasonable alternatives which should be assessed, nor are they sufficiently distinct. Option 2 does not assess a different level of employment land provision to Option 1 and includes only an 8.8% increase in housing numbers based on neighbouring unmet need.
3.20 Option 1 is stated as being chosen due to it placing less pressure on transport, social infrastructure and lesser impacts on the environment. Option 2 would deliver only an additional 2,000 homes across a 16-year plan period, a marginal increase. The Sustainability Appraisal does not adequately consider the ability of development to mitigate these impacts nor the ability of development to make a positive contribution to infrastructure which goes beyond benefits to new residents but also to existing communities. Neither does it propose an alternative level of employment land provision.
3.21 When taking into account the anticipated supply of housing from windfalls and extant planning permissions, the Council is proposing a total supply of 27,854 across the plan period until 2041. This allows just under a 5% buffer to allow for market flexibility. Notwithstanding our belief that the plan period should be extended to 2042, it is not considered that this allows for a sufficient buffer in the event of delays to the delivery of strategic sites, or those impacted by viability. The housing target proposed in the emerging Plan should therefore allow for a higher buffer of between 10% and 20% more homes. In order to be positively prepared and justified, the Council should, as a minimum, account for this within the reasonable alternatives.
3.22 Further, in order to be positively prepared and justified, the Sustainability Appraisal should consider a more ambitious higher growth scenario which will contribute towards the Council’s Vision of strengthening the District’s economic position regionally as well as increasing housing choice for mixed and balanced communities.
3.23 Therefore, in order for the emerging Plan to be considered sound, the Council should revise the Sustainability Appraisal to consider and assess an option with a sufficient buffer and also additional reasonable alternatives which achieve more ambitious levels of growth.
Employment driven housing need
3.24 The level of employment land assessed under both reasonable alternatives has not been adequately evidenced, nor is it justified. The Sustainability Appraisal refers to an Initial Objective Assessment of 274,663sqm of employment land. However, the Council has not published any evidence as part of this consultation which would indicate where this assessment of need has come from.
3.25 The Employment Land Need Assessment – Update (October 2020) notes a need for 293,112sqm of employment floorspace, higher than the level tested in the Sustainability Appraisal under Options 1 and 2. This Need Assessment notes that historic growth in manufacturing indicates considerable potential for future growth and diversification. Similarly, logistics and distribution are identified as a strong growth area given Medway’s geographical positioning with access to a considerable population. Further, the Lower Thames Crossing (which is due to be determined by 4 October 2024) is noted as having the potential to provide a significant new driver to the local market.
3.26 The all points to the ability of Medway to realise the vision of strengthening itself as being regionally important economically. However, as set out in paragraph 7.2.1 of the Regulation 18 Local Plan, the Council admits that it has not carried out the necessary evidence gathering to determine the employment needs of the District. This information is critical to determining whether the emerging Plan is firstly delivering the levels of housing growth which can support economic growth, and secondly, whether the spatial strategy, through allocating existing employment land for housing, is jeopardising economic growth.
3.27 Without this information, the Sustainability Appraisal cannot be considered to be positively prepared, justified, evidenced or consistent with national policy.
Unmet need from neighbouring authorities
3.28 Historically, local authorities in Kent have agreed not to take need from other neighbouring authorities, with need to be met within each local authority area. However, this has caused issues with inspectors at examination (for example, Sevenoaks). Whilst Medway’s housing need under the revised LHN has decreased marginally, neighbouring authorities have seen increases in their LHN and, when compared with current deliver rates, these authorities will struggle to deliver their need without cross-boundary collaboration.
3.29 Local Authority 3.30 Existing LHN 3.31 New LHN 3.32 Current delivery
3.33 Gravesham 3.34 661dpa 693dpa 3.35 363dpa
3.36 Maidstone 3.37 1,220dpa 1,344dpa 3.38 1,379dpa
3.39 Swale 3.40 1,040dpa 3.41 1,061dpa 3.42 900dpa
3.43 Tonbridge & Malling 3.44 820dpa 3.45 1,057dpa 3.46 446dpa
Figure 2: Table showing the existing and revised local housing need of neighbouring authorities against current delivery.
3.47 Whilst it is not clear what the most up to date figure for Gravesham’s unmet need is, given that there is no statement of the Duty to Cooperate nor a Statement of Common Ground with Gravesham, it is clear that Gravesham is a heavily constrained borough and the SA has already considered a scenario where Medway can assist in accommodating some of this unmet need.
3.48 Tonbridge and Malling Borough Council is in the process of preparing a new local plan and is a borough which is constrained by the Green Belt and the Kent Down National Landscape. Tonbridge and Malling’s housing need is set to increase significantly, by nearly 450dpa through the revised Standard Method. As such, the Council will need to engage with Tonbridge and Malling to determine whether these needs can be accommodated within Tonbridge and Malling, or if Medway can assist in meeting any unmet needs.
3.49 The Government is clear that local planning authorities need to work together in a productive and pro-active way to ensure that housing need is met in full within regions. Therefore, Medway will need to engage meaningfully with neighbouring authorities, including Gravesham, to take any unmet need. This should be reflected in the next iteration of the Sustainability Appraisal and emerging Plan. The Council should update the Sustainability Appraisal to consider a wider range of growth options, including higher levels of housing delivery.
Spatial Growth Options
3.50 The Sustainability Appraisal then goes on to set out 12 “spatial delivery options” and from these, three spatial growth options have been formed.
3.51 “SGO1 - Urban Focus” seeks to maximise development on brownfield sites in urban centres and waterfront sites through increased density. The Council acknowledges that there are not enough brownfield sites to deliver against the LHN and, therefore, limited greenfield development adjoining larger settlements has been considered, including Strood, Rainham, Lordswood and Hoo.
3.52 The Council considers that this option raises issues with conflicts with design guidance such as the Chatham Design Code and the negative impacts of high-density development on heritage assets.
3.53 One of the areas for housing growth is the redevelopment of existing employment sites at Chatham Docks and areas of Medway City Estate. However, it is noted that there are potential issues with viability on brownfield sites and reliance would limit range of housing types to meet needs, including delivering family homes.
3.54 “SGO2 - Dispersed Growth” allocates more limited land through regeneration and excludes Chatham Dock and some town centre/waterfront opportunity sites as they have not been actively promoted.
3.55 Instead, this option proposes a higher release of greenfield and Green Belt sites including Hoo Peninsula, North of Rainham, Medway Valley and sites close to sensitive environmental areas. The Council highlights that this creates sustainability issues through a higher reliance on car-based transport and greater loss of good quality farmland.
3.56 “SG03 - Blended Strategy” is the preferred option presented by the Council as it blends land for regeneration and greenfield development. The Council state that this option will deliver a brownfield first focus with regeneration in urban centres and waterfront locations and range of sites in suburban and rural areas. Half of development is proposed to take place on brownfield land.
3.57 The Council state that this will deliver a range of housing types and densities, with heights in regeneration areas able to reflect design guidance and heritage constraints.
3.58 Whilst BDW does not disagree with the principle of the chosen strategy of a “blended” approach, there are a number of significant concerns which call into question whether the spatial strategy has been positively prepared, is justified and effective, and consistent with national policy.
3.59 The Council has acknowledged that there are not enough brownfield sites to deliver the number of homes required in the Plan period and there is a requirement for some greenfield land to be released. Further, the Council acknowledges that overreliance on brownfield sites can negatively impact the range of homes delivered due to land constraints and viability concerns. BDW agrees.
3.60 Spatial Growth Option SGO1 is noted as the redevelopment of existing employment sites at Chatham Docks and Medway City Estate. At Table 5.1 of the Sustainability Appraisal, we can see that development in these locations is also proposed for the preferred Spatial Growth Option SGO3. It is unclear how the redevelopment of existing employment sites helps contribute towards the Council’s Vision of strengthening Medway’s position economically in the region and also the delivery of employment land as set out under Option 1 of the Sustainability Appraisal.
3.61 In addition, without having prepared an up-to-date Employment Land Need Assessment, the Council does not know how much land it needs for employment uses and how the allocation of existing employment sites for residential development will impact this.
3.62 Spatial Growth Option SGO2 also notes that Chatham Docks and some town centre and waterfront opportunity sites have been excluded due to the sites not being actively promoted. Notwithstanding this, Chatham Docks and all Urban sites are included in the preferred option SGO3.
3.63 The NPPF at Annex 2, states that for sites to be considered deliverable (i.e. brought forward within five years), the site should be available for housing now. For sites to be considered developable (i.e. beyond five years and within the plan period), there should be a reasonable prospect that the site will be available.
3.64 Tables 8.14 and 8.15 of the Sustainability Appraisal provide a list of development sites and the reasons why they have been selected or rejected as part of the development strategy. When comparing this with the October 2023 Land Availability Assessment (“LAA”) Interim Report, there are a significant number of sites selected for development which are either not in the LAA or have not submitted for consideration as part of the Call for Sites.
3.65 Without publishing an update to the October 2023 LAA, it is not possible to fully interrogate the site selection as part of the chosen spatial strategy to determine whether they are available. In addition, without a housing trajectory, it is not possible to determine whether the Council can maintain a rolling five-year housing land supply and the deliverability of individual sites. Further, without evidence to the contrary (and as alluded to by the Council itself), a large number of sites cannot be considered available and suggests that the chosen spatial strategy is not deliverable, effective or positively prepared.
3.66 The Council has also not provided any detailed information which underpins the capacity of the brownfield sites chosen as part of the spatial strategy. Without this, it is not possible to determine whether the estimates of housing numbers can be considered accurate or sound.
3.67 In addition, a large proportion of the sites set out in tables 8.14 and 8.15 are noted in the October 2023 LAA as having extant planning permission. It is not clear whether these sites should be considered as being commitments rather than allocations and included within the 5,363 homes of existing supply commitments and anticipated windfall supply set out at paragraph 3.2.1 of the Sustainability Appraisal, or within the required yield of 22,491 homes. If they are to be considered as allocations, then there are questions as to why these sites have not already come forward for development if they benefit from planning permission. In order for the Plan to be considered positively prepared, effective, justified and consistent with national policy, this should be clarified and further evidence produced which allows for sufficient interrogation of the sites selected.
Housing Trajectory, Deliverability and Supply
3.68 As previously noted, the Council needs to produce a detailed housing trajectory of all the sites chosen for allocation in order for them to be scrutinised sufficiently to be considered sound. This detail needs to be provided in order to determine whether the Council will have a five-year housing land supply upon adoption of the Local Plan, and can maintain this throughout the plan period.
3.69 This is crucial given the Council’s historic record of delivery and supply. The most recent Housing Delivery Test results (published December 2023) show that the Council is only delivering 79% against its current need. Whilst this is up from the previous monitoring years, it shows persistent issues with delivery within Medway. The Council’s Acton Plan (June 2024) predicts that the Council will not pass the Housing Delivery Test before the adoption of the emerging Local Plan.
3.70 This is particularly pertinent given that the Council’s latest published housing land supply shows that as of 31 March 2023, the Council can only demonstrate 3.3 years of housing land supply. Further, the housing trajectory contained within the 2023 Authority Monitoring Report (“AMR”) at page 32, shows a significant tailing off in housing delivery post 2026/27.
3.71 The Council’s Housing Action Plan (June 2024) notes that a third of the land within Medway is designated as international or national importance for the environment, which presents a significant constraint on development. In additional, it notes that development on brownfield sites has taken longer to build out.
3.72 At paragraph 2.10, it states that there has been a notable decrease in permissions granted, with only two sites over 100 dwellings being permitted in the monitoring year 2022/23 and that this trend is expected to continue in 2023/24. This will mean that delivery rates are likely to also decrease without consenting sites which can deliver early on in the plan period.
3.73 Perhaps indicative of the issues Medway has had with building on brownfield sites are St Mary’s Island which was first identified back in 1988 and planning permission granted in 1996. A total of 1,629 homes out of the 1,760 consented homes were completed by March 2021. Similarly, Rochester Riverside was also identified in 1988, with just 73 units built in 2012. The remainder of the 1,473 homes could take 20 years to build out.
3.74 Despite the incredible amount of time that these two sites have taken to come forward with new homes, the Action Plan at paragraph 3.48 notes that the Council plans to allocate additional sites of similar size through the emerging Local Plan. This raises significant concerns about the selection of brownfield land for housing delivery within the early stages of the plan period to address the chronic housing delivery and supply issues which Medway faces. As noted previously, the Council has not presented any detailed evidence which sets out the capacity of these brownfield sites, clearly showing the constraints and how these constraints are to be overcome in order to deliver homes consistently across the plan period. Without this information, the Plan cannot be considered sound.
Viability
3.75 The Viability Assessment published as part of this consultation has not been updated since 2021 and is based on a version of the emerging Local Plan which was not published. The Council notes in the explanatory note, that the policies contained within this Plan are very different to what is being consulted on as part of this Regulation 18 consultation.
3.76 The information within this Viability Assessment has very limited, if any value, in understanding the viability of the emerging Plan and the viability of the proposed Spatial Growth Option. The information within it is very outdated and is not able to take into consideration the substantial increases in interest rates and construction costs, issues with the supply of materials and labour, or the in-practice costs of delivering biodiversity net gain.
3.77 It is critical that the Viability Assessment is updated to test the potential spatial growth options put forward in the emerging Plan, particularly the ability of urban sites to deliver a mix of housing and affordable housing, and for larger sites to deliver infrastructure. Without this information, the spatial strategy cannot be considered sound.
Hoo Peninsula
3.78 SGO3 also allocates development towards the Hoo Peninsula. It is noted as being “partial” rather than “full” as set out in SGO2. The Hoo Peninsula spatial delivery option is stated as being the worst performing spatial delivery option assessed within the Sustainability Appraisal. From the policies map, it appears that the Council is still intending to allocate significant levels of development in this area through SGO3 (including Cockham Farm HHH12, Angel Farm HHH22, and land either side of the A228 including HHH3, HHH6, HHH8 and HHH11).
3.79 If the Council is still intending to bring forward development in this location, then it is unclear how it aligns with the Council’s Vision or strategic objectives, given that this spatial delivery strategy scored so poorly against these objectives in the Sustainability Appraisal.
3.80 The Viability Appraisal shows significant costs relating to the delivery of the Hoo Peninsula, principally, section 106 costs are assumed to be in the region of £225 million, working out at £27,557 per unit. This is significantly higher than the other strategic sites which are assumed to require a contribution of £5,600 per unit. In addition, the Viability Assessment notes that the money which had been provisionally secured through HIF bid had been deducted from this £225 million. The £170 million fund for the Hoo Peninsula was pulled in February 2024 meaning the cost per unit is likely to be significantly more than £27,557 per unit and this calls into question whether the proposals in this location can be considered viable and deliverable.
Land North of Rede Court, Strood
3.81 Land North of Rede Court, Strood was included within both SGO1 and SGO2, however, it was not included within SCO3. It is not clear as to why the Site was considered suitable for both an urban focus and a dispersed growth spatial strategy, but the Site, along with all other sites north of Strood, were removed as part of the blended strategy.
3.82 As set out within these representations, the removal of the Site from the Green Belt and its allocation for residential development would constitute sustainable development and would support the Council’s Vision and Strategic Objectives.
3.83 The Site was rejected through the Sustainability Appraisal due to the loss of Best and Most Versitile (“BMV”) agricultural land, its location within the Green Belt, the potential for coalescence between settlements and the Site being beyond a reasonable walking distance to current public transport services.
3.84 The Site’s contribution to the Green Belt is dealt with in our responses to Questions 7 and 8 of this Consultation. However, it is considered that the Site does not perform strongly against the purposes of the Green Belt and would make a logical expansion to the settlement of Strood.
3.85 The detailed assessment of the Site at Appendix C of the Sustainability Appraisal scores a minor negative for the Site in terms of its agricultural land classification. The Agricultural Land Classification Map London and the South East (ALC007) shows that the vast majority of land within Medway is within Grades 1-3. The loss of BWV also needs to be balanced careful with the other benefits such as contributing towards sustainable development and mixed and balanced communities. The map provided by Natural England is also at a large scale and is not always up to date, meaning that the Site may have a different agricultural land classification.
3.86 Further, the Site does have connections to public transport services and development would have the potential to enhance active travel through pedestrian and cycle connections into Strood. In addition, the detailed assessment of the Site at Appendix C of the Sustainability Appraisal shows that the Site performs positively in terms of access to a bus stop, pedestrian and cycle connections and local services. Access to public transport is noted as neutral. As such, it is not considered that connection to public transport is a justified reason for dismissing the Site as an option for development.
3.87 The Site only scores one major negative within the Sustainability Appraisal after mitigation (pollution and waste), however, it is not considered that impacts from the A289 nor Gravesend Road could not be adequately mitigated so as to be considered acceptable.
3.88 The assessment of North of Strood as a Spatial Delivery Option within the Sustainability Appraisal is considered to be unduly negative, and does not take into account the ability of this option to deliver a range of housing early on in the plan period.
3.89 The Hoo Peninsula scores negatively against almost every strategic objective within the Sustainability Appraisal, however, it is chosen as a preferred spatial delivery option. The urban spatial delivery option alongside Medway City Estate and Chatham Docks also score relatively negatively against most of the strategic objectives, however, they are given positive assessments against the economy and employment objective, despite the substantial potential loss of employment land. Further, the assessment does not recognise the that the ability of these sites to deliver a range of housing types within the first five years of the Plan is severely inhibited.
3.90 Overall, it is considered that the assessment within the Sustainability Appraisal is not justified in terms of the assessment of both North of Strood as a Spatial Delivery Option and the Site itself under SNF1. The North of Strood and SNF1 should not have been discounted and should instead be considered as a preferred option for development.

Please refer to our full submission for further details.

I am worried that you are considering building on the docks. I think there has been far too much development in Rainham. We have such a lack of doctors and schools for these and in all fairness the plan does not adequately deal with this. Option 3 is out of the options the best but is far from perfect.

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. 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.

Binney rd development floods - no infrastructure- each house will probably put 2 cars on the road. When children are old enough they will drive of course nowhere to park these cars! 9 new houses in Binney 2 still empty more than a year later. Houses do not sell well here either. The village is cut off when the weather is bad and accidents. Took 5 hours to get to Hoo cos of an accident. Only took 4 hours to get to Yorkshire! Habitat to nature. Health asset to the community. Walking riding cycling etc.

States her to make best use of brownfield sites and bring forward the transformation of the waterfront and town centres. The only option that maximises the vision in this way is the urban option.

Dear Sir/Madam

THE MEDWAY LOCAL PLAN (REGULATION 18, 2024)
WRITTEN REPRESENTATIONS ON BEHALF OF TELEREAL SECURITISED PROPERTY GP LIMITED

We write on behalf of our client, Telereal Securitised Property GP Limited (hereafter: “our client”), with respect to the Council’s Reg. 18 Public Consultation on the emerging Medway Local Plan (2024) [hereafter: “Draft Local Plan”] and specifically regarding Medway Telephone Exchange, Best Street, Chatham, ME4 4AB (Indicative Site Allocation CCB49). This submission follows previous representations made in relation to the earlier Reg. 18 consultation in October 2023 (see Appendix 1).

Introduction & Background
Our client is the landowner of the Medway Telephone Exchange, Best Street, Chatham, ME4 4AB (“the site”). As set out in our previous submission, the site constitutes brownfield land in a sustainable development location, is under single ownership and expected to be surplus to operational requirements by 2031 (or earlier). As such, it will become available for redevelopment over the Draft Local Plan period.

The Draft Local Plan is of significant importance to our client who has a strong interest in ensuring that it creates a strong, flexible and ambitious planning framework to facilitate the sustainable growth the Council requires and maximises the development potential of suitable sites and areas as set out in its preferred spatial growth option (‘SGO3’).
As the Council will be aware, for Local Plans to be found sound, we note that in line with Paragraph 35 of the National Planning Policy Framework (“NPPF”, 2023) it is important that they are:

- Positively prepared: Providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
- Justified: Based on an appropriate strategy, taking into account the reasonable alternatives, and proportionate evidence;
- Effective: Be deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
- Consistent with national policy: To enable to delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

3.2 Spatial Growth Options, Sustainability Appraisal Appendix E & Emerging Policies Map (Site CCB49)

The Council identified a series of Spatial Growth Options in Section 3 of the Draft Local Plan setting out that its preferred option is SGO3 comprising a blended urban regeneration and greenfield approach. In light of the evidenced need for housing (and the Government’s proposed revised standard method to determining such need set out in the consultation on modifications on the NPPF in July 2024), it is considered that SGO3 is the only realistic option to achieve the required growth and housing numbers.

It is positively noted that, following the previous Local Plan consultation, the site has been identified as preferred indicative site allocation ref. CCB49. Our client wishes to reiterate that it is the sole landowner of the site which is deemed deliverable, suitable, available and economically viable (in line with the definition of deliverable housing sites set out in NPPF Paragraph 69 and its Glossary). Whilst currently operational as a telephone exchange (sui generis), it is anticipated to become surplus to BT’s operational requirements by 2031 or earlier which requires a forward-thinking strategy to ensure this brownfield site is effectively used once vacated by the current occupier and therefore avoids a long-term period of vacancy. This should be awarded significant weight in line with NPPF Paragraph 121.

The site is considered to be capable of making a significant contribution towards the Council’s housing target, particularly as the site constitutes previously developed, brownfield land to which Chapter 11 of the NPPF seeks to direct future development (and intensification) with a view of making as much use as possible of previously developed land (Paragraph 123) and giving substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs (Paragraph 124). This is further emphasised in the consultation on changes to the NPPF published on 30th July 2024.

To demonstrate its commitment to bringing the site forward once its current operation ceases (either directly or via a development partner/developer), our client has undertaken initial feasibility and viability studies to assess likely development capacities and scenarios. This study has considered the site’s main constraints/surroundings (including its topography and proximity to surrounding heritage assets likely necessitating a heritage- and design-led approach) and developed high-level development scenarios ranging from demolition and redevelopment (Option 1) to conversion and, where appropriate, extension alongside new build elements within the wider site (Option 2).

Realistically, and taking into account current sales values and development viability considerations, it is considered that the site may either come forward as a conversion/extension or full-scale redevelopment, as set out above. However, it is too early at this stage to determine the most realistic and viable development option.

Therefore, to avoid an overly prescriptive site allocation (i.e. targeting a capacity which may neither be deliverable nor viable) which may undermine the viability of one of the future development options, it is strongly recommended to consider safeguarding both options at this stage alongside revised capacity assumptions of circa 50 (conversion/extension) to 100 (full-scale redevelopment) new homes.

Having reviewed Appendix E: Reasonable Alternative Site Assessments of the Sustainability Appraisal (June 2024; “the SA”) accompanying the Medway Local Plan, our client considers that carrying forward an indicative development capacity of 50-100 new homes should be maintained to take into account both development options for the site as well as development viability at the time of a planning application coming forward (i.e. there may be changes in build costs, sales values, etc. which will have an impact on the overall approach).

Clarifications, where necessary, on the SA’s assessment of the site in its Appendix E are however provided below:
‒ Climate Change Adaption: Subject to an appropriate flood risk and drainage strategy which ensures that surface flooding is not increased outside the site’s boundary it is not considered that this should affect the future redevelopment potential of the site.
‒ Biodiversity & geodiversity: The site is sufficiently distant from European sites and SSSI with any impact likely to be mitigated at application stage.
‒ Landscape & townscape: It is agreed that there are no significant townscape or landscape constraints affecting a future redevelopment of the site.
‒ Pollution & waste: It is noted that all sites capable of delivering 100+ new homes are shown as having a potential adverse impact on air quality/pollution. However, it is considered that air quality impacts can be fully considered and mitigated through an air quality (neutral) assessment at application stage. In addition, based on our commentary above, it is considered that a more realistic development capacity of 50-100 new homes may mitigate this risk further and allows the Council to assume that no potentially adverse impact on air quality/pollution will be caused by this site.
‒ Health & wellbeing: The site is identified as being >1.5km from the nearest leisure centre. This is noted, however, it should be recognised that Medway Park Sports Centre is only marginally (+600m) further away than the identified threshold and easily reachable by foot and bicycle. The pedestrian route to the leisure centre leads through open space (Great Lines Heritage Park) and therefore constitutes a welcoming access route with limited exposure to road traffic. It is considered that the site should be assessed as having a minor positive impact in this regard.
‒ Cultural heritage: The site is assessed as potentially altering the setting of and/or having a minor negative impact on nearby heritage assets (Conservation Area; Grade II listed building). It is considered that this risk is not significant and can be adequately mitigated through a heritage- and design-led approach to redevelopment or, even more so, in a conversion scenario (including potential extensions and/or lower scale new build elements within the wider site). Cultural heritage is therefore not considered to have a significant impact on the acceptability of a redevelopment of the site.
‒ Transport and accessibility / Education: As noted by the Council, the site is in a very sustainable development location having excellent access to public transport and education provision.
‒ Economy and employment: The site is identified as having a potentially adverse impact on employment floorspace provision (assumed due to the perceived loss of such floorspace). However, it should be noted that the site provides limited on-site employment currently. Whilst most telephone exchanges (including this site) are a key part of the UK’s communication infrastructure via their copper and fibre networks and have historically provided ancillary offices and related accommodation (such as catering facilities), the ancillary office elements have not been (or only been in limited) active use. This is also the case for the Medway Telephone Exchange. Openreach engineers and other Communication Providers who have equipment located at site simply attend the property to maintain, upgrade or install their equipment (in irregular or regular intervals).

Any office-based staff are located in separate fit-for-purpose office buildings. The site is therefore much more similar to a data centre accommodating communication equipment (racks, cable chambers, plant, etc.). With Openreach withdrawing copper-based technology in favour of fibre in the coming years, it will result in a consolidation of BT’s Exchange portfolio, including the decommissioning and closure of Medway Telephone Exchange.

As such, the site has been underutilised and mostly empty in terms of (ancillary) office use for a significant amount of time, not accommodating any regular on-site employment. Any redevelopment of the site, due to the reasons set out above, will therefore not result in a loss of active or existing employment floorspace.

Given the wider assessment of the site in the SA, the information provided in Appendix 1 in October 2023 and clarifications set out above, it is therefore considered that the site should be allocated in the next iteration of the Draft Local Plan for residential-led conversion or redevelopment with a site capacity of at least 50-100 new homes. A site allocation not only demonstrates that the site is capable to make a significant contribution towards meeting, or indeed exceeding, the Council’s minimum housing target, but also to provide comfort to our client and/or a future developer that a conversion/redevelopment of the site is supported in-principle once its operation as a telephone exchange ceases in 2031.

A short description of development and design principles to be secured in a future draft site allocation is set out below:

Proposed Site Allocation Design and Development Principles
‒ CCB49: Telephone Exchange, Best Street, Chatham, ME4 4AB
(i) Description: Comprehensive Residential-led conversion (with extension/new build elements) or redevelopment of the site once its current use a telephone exchange ceases (in 2031 or earlier)
(ii) Justification for option: The conversion or redevelopment of the site could help to meet the need for new homes and/or other non-residential uses (subject to need/demand) in the borough.
(iii) Anticipated phasing of development: Post-2031
(iv) Evidence of deliverability: Site surplus to operational requirements from 2031 (or earlier).
(v) Indicative number of homes: 50-100
(vi) Design Principles:
‒ Any conversion or redevelopment of the site should take into account the setting of surrounding heritage assets and consider a heritage-led approach to design, height and massing to protect and enhance their setting. Taller elements should be set back from the Lord Duncan Public House.
‒ Subject to a redevelopment being the most viable and desirable option, the site is considered suitable for tall building elements with final building heights to be confirmed at planning application stage and subject to robust heritage, townscape and environmental testing. Impacts on local townscape should be mitigated through high quality architecture.
‒ A conversion or redevelopment should take into account the level difference between Best Street and New Road and work with the site’s topography to ensure both primary frontages are positively addressed and activated.
‒ Opportunities to improve the pedestrian connectivity between New Road and Best Street should be explored.

Conclusion
Overall, it is therefore considered that the site offers an ideal opportunity to facilitate a sustainable future development proposal in an appropriate, brownfield site, particularly when considering that the fall-back position constitutes a vacant telephone exchange once its existing operation ceases.

The site is considered to be suitable, available, deliverable and economically viable to deliver new housing during the Draft Local Plan period. As such, it is recommended to include the site in the emerging Draft Local Plan in the form of a Draft Site Allocation for residential-led conversion or redevelopment, maintaining flexibility to consider the most viable approach to development as and when a planning application will come forward.

Our client and we are willing to engage in positive and pro-active discussions with Medway Council where this would assist in preparing a justified, sound, and deliverable new Local Plan.

For the reasons set out in our earlier representations, it is clear to CPRE Kent that Medway’s new local plan should embrace a true “brownfield-first” spatial strategy. That is, before any greenfield land is released, far more needs to be done to demonstrate that brownfield opportunities have been maximised.

The Council know that those sites on its brownfield register are simply a list of sites already known to it, either as a consequence of a planning application or an existing local plan allocation. These add nothing in terms of identifying future additional supply.

It is also the case that very few brownfield sites will ever come forward as part of a call for sites exercise as these are usually in locations where the principle of development is already acceptable, meaning there is very little point in a landowner going through the unnecessary expense of promoting their site through the local plan process. Instead, the real profit is to be made from the promotion of greenfield sites, where the principle of development has not been agreed, hence why these naturally dominate any call for sites exercise as set out above.

A far more proactive approach needs to be undertaken. Key to this will be a full, detailed and up-to-date Urban Capacity review that robustly identifies where further development opportunities are within the urban areas.

Alongside this, we would want to see a brownfield land specific call for sites that is advertised as widely as possible. This should include local communities and the general public being actively encouraged to identify brownfield sites, with the Council working alongside to identify and overcome existing delivery constraints.

As an organisation we are happy to work proactively with the Council on this, utilising the CPRE Brownfield Land Register Toolkit which has been developed specifically for this purpose https://www.cpre.org.uk/resources/brownfield-land-register-toolkit/ . Likewise, we would welcome working with Medway Urban Greenspaces Forum to identify where there may be further opportunities for regeneration that’s welcomed by communities and developers alike.

With respect to delivery, it has always been our opinion the HIF Funding of £170 million being directed to releasing development on greenfield sites on the Hoo Peninsula was a massive, wasted opportunity. Instead, Medway Council should have been doing everything it could to get this funding re-directed so it could bring forward the various stalled brownfield sites within the Medway Urban Areas.

We are therefore extremely pleased to see that Medway received £3,968,371 from the first phase of the Department for Levelling Up, Housing and Communities Brownfield Land of £60 million to help release brownfield sites, including the Strood Waterfront and the Debenhams building in Chatham. With the second phase of monies also released and a total fund of £4.8 billion available, we would expect to see evidence of the Council having been fully engaged in securing the necessary funding to bring forward both the brownfield sites that have currently stalled and new sites identified.

We would also expect to see Medway’s leaders partnering with Homes England to bring forward identified brownfield sites and regenerating Medway’s high streets, where an increased residential offering will be anticipated. We would also expect to see evidence of the Council having fully engaged with all possible delivery partners before deciding that any sustainably located brownfield site is not deliverable.

CPRE Kent is calling on the new Plan to maximises the development potential (by density) of those sites located within the most sustainable areas. This needs to come hand in hand with good design, sufficient infrastructure and in particular sufficient active travel and public transport options that provide a realistic alternative to car dependency, along with sufficient well designed green spaces and inviting public realm environments. Higher density certainly does not have to come at the expense of good planning.

Overall, unless such proactive steps are undertaken, we are not going to accept the usual argument given to CPRE Kent that there are insufficient brownfield sites available for development, leaving no option but to allocate further greenfield land.

The higher the density, the more benefits accrue, and the more (greenfield) land is saved. High density building does not equate to high rise apartment blocks. CPRE London published a report in 2019 on this issue called ‘Double the density , halve the land needed’ which sets out both the benefits of higher density design along with providing examples of higher density developments being achieved by a variety of means. This includes a mixed-use residential development at Springhead Park, Ebbsfleet, Kent where 160dph is being achieved.

As set out above, we believe it is wrong to simply continue sacrificing yet more greenfield land in an attempt to accommodate what is an unsatisfiable external market demand. We would therefore firmly object to any further allocation upon the Hoo Peninsula beyond that accepted by the existing communities, as needed to maintain and support them.

This position is in recognition that the Hoo Peninsula is a largely rural area, containing significant environmental constraints including ancient woodlands, SSSI’s, SAC’s SPA’s and RAMSAR sites. It is also predominately Best and Most Versatile agricultural land and has significant areas of intrinsically dark skies, the loss of which should be strongly resisted. The ecology upon the Hoo Peninsula is extremely sensitive, containing one of the largest breeding sites in the UK for the nightingale population, highly protected water voles along with recently proven habitats of the rare purple emperor butterfly and dormouse. Medway also has at least six red listed rare birds sheltering in its boundaries including the Black Tailed Godwit, the Curlew and the Pochard and many more on the amber list. We note only last year, surveys on the Isle of Grain discovered the extremely rare Shrill Carder Bee only known to be found in seven areas across England and Wales and never before discovered in Kent.

It is also the fact that the Four Elms Hill and Peninsula Way through Chattenden suffers significant levels of air pollution, hence it being designated an Air Quality Management Area (AQMA). The proposed development associated with the £170 HIF funding bid largely sought to justify itself on the basis it was needed to help fund this new road infrastructure. With car ownership and usage rates on the Peninsula already much higher than the rest of Medway, our responses to the various HIF consultations strongly objected to the principle of the building yet more traffic inducing new roads that facilitate building, or “unlocking”, greenfield sites.

The benefits of new roads schemes are extremely over-stated and in reality, generate traffic above background trends by inducing traffic, which leads to permanent and significant environmental damage. Specifically, and as set out in our report ‘The end of the road? Challenging the road building consensus’, March 2017 https://www.cpre.org.uk/resources/transport/roads/item/4543-the-end-of-the-road-challenging-the-road-building-consensus, the building of new roads to accommodate further growth is just going to significantly exacerbate the Peninsula’s accepted existing problem with ingrained car dependency.

We remain unconvinced that the selection of the Hoo Peninsula for any substantial housing development beyond what is needed to support existing communities would survive the scrutiny of the Local Plan process. Focus must now be on mitigating the worst effects of the unplanned windfall development that has taken advantage of the HIF Funding debacle and are now coming forward without any plans for the necessary mitigation being put in place. As a minimum, Medway must be doing all it can to resist these developments as they continue to come forward. The first step to this will be making it as clear as possible, as early as possible, that Medway’s new local plan will not be looking to allocate any further significant development upon the Hoo Peninsula

For any allocations upon the Hoo Peninsula to be considered remotely acceptable by us, they would need to be demonstrably sustainable with very genuine levels of self-containment and deliverable sustainable transport options. This may include alternatives to the previously proposed rail station such as zero-emission dedicated bus routes that we are beginning to see elsewhere in Kent, such as Dover’s new Fasttrack service between Whitfield and Dover - https://www.dover.gov.uk/Planning/Regeneration/Fastrack/Dover-Fastrack.aspx.

In terms of the dispersed growth element of the blended strategy, CPRE Kent could support growth adjoining the existing urban areas to the south and east of Medway if it was demonstrated a true brownfield first approach had been undertaken, vital greenspaces were maintained and enhanced, and that sufficient infrastructure was to be provided. However, we are concerned that much of the area identified is Best and Most Versatile land. As set out within CPRE’s recent report “Building on our food security” in the past 12 years England has lost over 14,000 hectares of Grade 1 and 2 agricultural land to development, the equivalent to the productive loss of around 250,000 tonnes of vegetables. It also appears that this figure is increasing. Nationally there has been a 100-fold increase in 2022, from that built on in 2010. This loss cannot continue to be ignored. This issue will need to be given significantly more consideration with respect to the allocations which do make it to any submission version of the plan.

Specifically, we would want to see and understand what sequential measures have been undertaken to minimise loss of Best and Most Versatile land. We would also want to see how this significant constraint has been given the due regard necessary with both the setting of an appropriate housing figure for Medway and then the site selection process, informing which sites are taken forward to allocation. It is however our starting assumption that any loss of BMV could be avoided.

Where sites on the urban edge are to come forward, we would want to see that sufficient active travel and public transport options that provide a realistic alternative to car dependency are provided. We would also want to see that existing green spaces are sufficient protected and improved/expanded to accommodate an increasing population. Where new land is given over to development, it should be used as efficiently as possible, as appropriate for that site’s location.

I support the urban-led approach to providing housing. Using brownfield land and focussing on already urban areas with the infrastructure already in place seems the sensible option. I understand that not all housing can be provided in these areas, but I question the locations of some of the housing sites in the preferred option. I object to Hoo being a focus for development, and I object to the housing sites suggested in Allhallows. Allhallows lies in close proximity to protected wildlife areas and there's simply not the infrastructure to support an increase in people.

We support the proposed site allocation for residential development of the former St John Fisher Comprehensive School.

DHA/17122/17124

This comment is made on behalf of Mr Zammit & Mr Jhalli in relation to land at Lower Bloors Lane, Lower Rainham (site ref. RN14) generating an ID.

The Applicant's full representation has been made within a separate document emailed to MC, and should be read in its entirety.

This growth option does not deliver the 28,000 homes required to fully meet the district's housing needs. The Council needs to allocate additional sites across the district to deliver the additional 4,267 dwellings across the plan period to fully meet their needs in accordance with para 23 of the NPPF.

We are concerned that this approach with the proposed site allocations will not deliver necessary quantum of housing as elaborated through our more detailed representations submitted as a separate document. In short, the allocations do not appear to have taking into account the full impacts of 10% BNG and no detailed housing trajectory has been provided to show how sites will deliver the necessary housing to meet the demands, a problem especially for strategic scale sites that lack the appropriate infrastructure at present.

We don't need an arrangement of diverse housing types, none of this plan will work