3.2.1

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.

The RSPB’s preferred spatial growth option would be option SGO 1, as it avoids harmful development close to sensitive wildlife sites on the Hoo Peninsula, in particular Northward Hill SSSI and RSPB nature reserve and Chattenden Woods and Lodge Hill SSSI. However, we would broadly support the Council’s preferred option, option SGO 3, if the potential allocations close to Chattenden Woods and Lodge Hill SSSI and Northward Hill SSSI were removed, due to the likely negative impacts they will have on the designated sites. This includes allocations HHH3, HHH4, HHH6 (at least part of), SR14 and HHH26.

Should the Council select either option SGO 2 or the currently preferred option SGO 3, we consider that a strategic mitigation approach will be absolutely essential in order to protect the Chattenden Woods and Lodge Hill SSSI. A key feature of such a mitigation strategy should be a 400m buffer to prevent net new residential development in the closest proximity to the SSSI. As we have previously advised the Council, developers are unlikely to be able to mitigate urban impacts (in particular cat predation) within this distance of the SSSI. Therefore, housing development in this zone is highly likely to lead to adverse effects on the nightingale population, which will require compensatory habitat to be provided. In line with the ‘mitigation hierarchy’ set out in the NPPF, developments that cannot mitigate their impacts on the SSSI features will need to show there are no less damaging alternatives before they can proceed to the last resort of compensation. Given that the Urban Growth option, SGO1, demonstrates that alternative locations for new housing are available in Medway, we consider that such housing would not comply with the NPPF. Therefore, without a clear policy approach in place for the Chattenden Woods and Lodge Hill SSSI, the draft Medway Local Plan also strongly risks being found unsound due to a failure to comply with the NPPF.

DHA/16402

This comment is made on behalf of Veetee Rice Ltd in relation to land at various sites in Medway City Estate (Site refs: SR30, SR31 & SR37) to generate an ID.

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

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24]
3.6 As stated above the LP2041 sets out three broad options for growth:
i. SGO1 – Urban Focus
ii. SGO2 – Dispersed Growth
iii. SGO3 – Blended Strategy
3.7 The consultation reflects that a ‘urban focus’ approach alone is unlikely to meet growth needs in full with only a limited supply of previously developed land available to accommodate this. At paragraph 3.1.6 of the LP2041 the Council confirms that rural and suburban areas offer potential for development and there has been a strong promotion of the sites in these areas. The Council also confirms that it needs to consider “…large and strategic scale development allocations in the Local Plan to address the communities needs for homes jobs and services”.
3.8 There are however sensitivities across the Medway, including important habitats and landscapes, and the Green Belt, which need consideration. Nevertheless, the Council acknowledges that in order to meet the full scale of needs over the Plan period, complex issues will need to be considered and addressed as part of the development secured, including any mitigation necessary (paragraph 3.1.7 of the LP2041).
3.9 The Council identify the blended approach (SGO3) as its preferred strategy for meeting growth needs. Marrons considers this is the right approach, supported by a strong mix of urban, suburban and rural development to deliver the diverse needs of the community. The Council has already commented on the needs of communities being met through larger scale developments and Catesby Estates reiterates comments made in previous representations that such development can help fund key infrastructure improvements, that benefit existing communities and help Medway implement its economic strategy.
3.10 Notwithstanding, the delivery of infrastructure improvements must be sustainable in order to keep pace with growth and Catesby Estates suggests this is best achieved by a balanced approach across Medway, in line with the Council’s preferred spatial option.

DHA/32341

This comment is made on behalf of Mr Kevin Rice in relation to Waterside Court in Medway City Estate (Site ref: SR40) to generate an ID.

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

Our client supports SGO 3 (Blended Strategy) as it approaches regeneration with a ‘brownfield first’ focus looking specifically within urban centres and waterfront locations such as the Grays of Chatham site.

We specifically support the identification of indicative site allocation FP11 – the Grays of Chatham site, which has long since been identified for development and is subject to a current live planning application.

However, 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.

It is essential that the Council ensures that such sites are making the maximum contribution towards meeting housing needs, taking into account the constraints of the site.

DHA/34326

This comment is made on behalf of The Heritage Design and Development Team Ltd in relation to Waterside Court in Bakers Meadow (Site ref: SR27) to generate an ID.

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

This growth option doesn't 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.

agree

Please refer to submitted representation [DHA/32434] and appendices for full details of our client's submission.

Our client supports SGO 3 (Blended Strategy) as it approaches regeneration with a ‘brownfield first’ focus looking specifically within urban centres and waterfront locations such as the Morgan Timber site (CHR20).

We specifically support the identification of indicative site allocation CHR20 – the Morgan Timber site, which has long since been identified for development and is subject to a current live planning application.

However, 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.

It is essential that the Council ensures that such sites are making the maximum contribution towards meeting housing needs, taking into account the constraints of the site.

Agree with the council’s preferred option

Growth is NOT unsustainable.
If you build these houses, what next when the population grows yet again! More???
The root cause is that there are TOO MANY PEOPLE and England cannot continue to constantly provide and provide more housing.
2 children per couple is sustainable. More is NOT.
It is NOT A RIGHT TO BUY WHERE YOU GREW UP.
Everyone I have known and grew up with moved to cheaper areas and then when they established themselves via career progression and saving, they have been able to move back, IF they then desired.

Only URBAN and Brownfiled sites should be used.
The developers will push for green as it's easier and more profitable for them to build there.
There is a HUGE site at Kingsnorth that could be used to accomodate any Pennisular requirements.
New houses should not be FORCED on exsting villages.
Hoo has been destroyed by development, DO NOT let it happen to other villages on the Pennisular.
Developers do not build for people, they build for profit.
How many more work vans are we expected to put up with blocking our pavements?
USE each bedroom requires 1 parking space equation.

Has there been an assessment on how many empty buildings there are and reclaiming these.

The numbers of housing planned to reflect local need and population growth, it seems that Medway is taking more than its fair share of the national housing targets given its current population density. This should be challenged.

Of the 3 options offered, SGO 3 would be the better way forward.

My proposal is for Option 1 ( SGO1 ), as this is the minimal disruption and preferred choice for our area.
I would also like to have read more on medical and care facilities planned in parallel to the proposed options.
I do feel there should be a plan to develop and build a new hospital facility to cater for all the development and more taking this new facility into the next century for our Medway area, with areas like Chattenden barracks being considered.

The three spatial growth options are misleading, descriptions in
consultation leaflet dont match diagrams. Option1 described as an urbanfocus, but proposes housing on ruralland on hoo peninsula. Option 2/3, like Option1, focuses
housing growth on ruralland in hoo peninsula
. None are sustainable options for the parishes. All three options would cause severe economic harm to the hoo peninsula and would create severe environmental damage.
Option3 allocates housing sites to accommodate over 40% of Medway’s
requirement in rural part of hoo peninsula where infrastructure is poor, contrary to NPPF policies on growth,
site selection, natural environment, food production, infrastructure

This is not sustainable , one road in and out, public transport is not up to standard stops at 7pm, no rail link, no health facilities in rural areas, although ALLHALOWS has a surgery it is not maned, so its 5 miles to hoo. whybuild in isolated areas where the only way you can get from A to B is by car. Supermarkets are 10 miles away. it will cause social unrest as there is nothing to do. Teenagers are unable to leave the village unless the parents take them. Grade A farming land shoi]uld be left as is.

After much consideration option 3 for planning proposal is favourable. As transportation for Medway areas , would creating and using a River Medway bus service connecting the Medway areas be an option to consider . Infrastructure in Medway must be considered due to possibly future flood risks. Medway needs to have replaced outdated water/drainage sewerage systems before the future of housing is built. Alongside recreational facilities and services needed to accommodate a rising population level in Medway towns/areas. More importantly its the environment green spaces /nature reserves for all to benefit living in Medway Towns.

3.2.1 Any proposed land use should avoid low density housing, with preference given to high quality medium density with adequate public transport links to medways core

When considering this option the Council must take into consideration the lack of ability in Allhallows to have electric charging points because of the lack of enough power supplied to homes. Also the fact that the slightest rain means raw sewage runs down Binney Road for weeks, because the pipework cannot cope

With the aim of protecting the biodiversity and wildlife on the Hoo Peninsular SGO 1 and 3 would be our preferred options, we would also wish to see the Chatham docks protected as a large local employment area, and that local green energy generation that is design to enable farmland to still be utilised and protect / enhance local wildlife and water ways, to be incorporated into the plan.

First how can you justify building 690 houses on Binney road on farmers fields you said not long ago the uk should be providing there own fruit and vegetables how can we do this is you are taking so so much of fields to build on
Second we don’t have the infrastructure to provide for these houses let alone for the families already living in Allhallows still to this day trying to get there kids in the school
Third the historical views and environment will be ruined by what you want to you as the cancel wanted to build a airfield a little while ago but couldn’t as the herons come back year on year to nest and other wildlife we have badgers hairs and nouts returning to the fields that you propose to build on
Forth you say good quality farm land but you want to take it to build houses on to you say to help Medway and surrounding areas how would this be helping Medway buy taking our very own farmers land

This is a sensible choice.

In my opinion, this is the wrong approach. There are a large number of large brownfield sites within Medway that must be preferentially utilised for housing first. A large number of these are in urban and suburban locations and therefore will be better served by existing infrastructure,

Expanding housing in small rural locations will place unsustainable pressure on services including water, drainage and roads as well as public transport, doctors and schools.

Medway Council does not have the funds to adequately provide the required services.

It is not acceptable to utilise greenfield sites while there are brownfield sites available.

Given all of the previous infrastructure & economic investment/development has been purely urban based, I would support the SGO1 as the preferred option given the cost of the infrastructure to support the proposed housing expansion in rural areas would be too prohibitive and therefore not be implemented resulting in us being left with thousands of proposed new homes and cars utilising the same over-used, sometimes single-lane roads making them even more unsafe for both car users and pedestrians to use.

Note the current developments at Hoo, St Marys Hoo and Cliffe/Cliffe Woods as prime examples to support the above assertion.

I welcome the 'brownfield first' focus, but would like to see greater protection to Green Belt sites.

As a medway resident, building on Capstone Valley is abhorent and should not even be a consideration. I understand we need housing, but the Capstone Valley is an area that should be left untouched. The area is vital for residents for mental health, physical health and for out wildlife. Building on here will destroy our area.

Abbey Developments supports the Council's preferred strategy SGO3 and the identified sites for suburban expansion on the east side of Rainham.
Preferred sites RSE9 and RSE10 are adjacent to land in Meresborough Road Rainham that Abbey Developments is promoting for residential development but which are all currently subject to policies in the existing Local Plan resisting development, BNE25 and BNE34. The proposed outward expansion of Rainham implies that the policy restrictions on this area, including Abbey Developments' site, which was subject of a recent planning appeal, should also be suitable for future residential development. we are seeking clarification of this.

There is no assessment of the proposal for the residential led redevelopment of Chatham Docks. The Chatham Docks Employment Report considers the economic impact of a mixed-use redevelopment of Chatham Docks but in a superficial way without proper consideration of the loss of UK production of essential steel products. The issue is not adequately considered by the Sustainability Appraisal. Noting the very widely drawn strategic objective, the Council has so far failed to produce (or rely on) any evidence which properly appraises the proposed redevelopment.

A full representation is provided to planning.policy@medway.gov.uk