Policy S1: Planning for Climate Change

All plans for new housing or industry need to include provision of recycling water and use of soler panels on roofs or other structures. To achieve net zero rainwater harvesting and solar generation are easy gains. For new property it would be ideal to offer incentives or discounts to local people, otherwise new build drive up house prices as we become an extension of London.

Use of solar panels on roofs to help with loading on the current electricity supply network should be stipulated on all new builds, together with charging points for electric vehicles. Individual houses should have one EV point and solar panels that connect to the property. For HMOs, flats , etc. there should be a provision for at least one EV point for every 2 dwellings (each room a dwelling in HMO) with connection to solar and /or battery storage. Where roofing gives poor solar efficiency, batteries could be utilised together with off-peak charging to provide additional peak capacity without stressing the existing supply infrastructure. This would contribute to net zero

There is a need to seriously consider people’s representations and they need to genuinely influence any decisions by Medway Council and not just pay lip service. All of my previous comments contribute to this section. Clearly any new development must consider its impact on roads, health infrastructure, transport, air quality, water services, refuse collection etc. Sustainability is the key and protection of and creation of new outdoor green spaces. Also new developments need to have a community hall or place where the local community can meet for social events especially outlying areas with poor transport connections

There is no mention of lighting and the damage it does wildlife, our health, and crime figures.
Working towards dark skies would be cheaper, with better lighting and reduce crime.

Support this as long as it ensures good design.

Cycle and walking routes ideally need to be away from traffic, not adjacent too. Footpaths need to be accessible to all footpath users and not blocked by inconsiderate parking. Routes should be litter free as this is a negative for the benefits of well being if walking and cycling.
Water resources/efficiency measures should not just be on new builds but encouraged across all homes, and measures to reduce hardstanding run off through capture or alternative permeable coverage encouraged.

Great Britain has a world impact of circa 0.5% re carbon etc. Russia, China, America, India are the climate changers. From roads, watches, phones to PC's oil will continue to be used. If not here it will be imported like the Gas from America to the Isle of Grain.

I wholeheartedly agree with these points. Renewable energy should be standard in new buildings which are considerably easier which are considerably easier to be built with rather than retrofitting old buildings.

no plan for rising sea levels
the introduction of mass housing on the peninsula will increase the risk of human activity on the ecosystems
increased traffic both private and commercial will impact an already dangerous Air Quality situation here on the peninsula that coupled with a very poor public transport which encourages private car use can only add to this situation

By allowing planning on the scale suggested this will increase pollution, concreting over the land which up to now has provided food, this year a crop of wheat and oilseed rape have been grown on this land. The extra traffic will be harmful to the air quality, the electricity is always going off and the overhead lines are constantly blowing down in the inclement weather we have on the island.

Southern Water supports all requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. We therefore strongly support the content on “multi-functional green infrastructure” within policy S1. However, we would also like to see this policy go further and make suggestions for additional policy wording below.
Southern Water also supports the policy intention to minimise the use of natural resources, and we would welcome a reference to policy DM6 and the water efficiency standard referred to therein (that we submit a separate representation on in our response to this consultation).
Requested changes:
Effective Spatial Planning and Placemaking:
• Existing surface water flow routes and drainage features within the site should be identified and preserved wherever these contribute to sustainable drainage eg ditches, seasonally dry watercourses, historic ponds.
Adaptation to climate change:
• Reducing water consumption using water re-use measures including rainwater harvesting, surface water harvesting and/or grey water recycling systems. Personal water consumption per day for new build should not exceed the Building Regulations recommended standard for water efficiency in water stressed regions.
Further explanation and justification:
We need planning policy to consider carefully the measures called for in response to the climate crisis, and ensure sustainable development is central to the local planning framework for planning applications coming forward.
Southern Water is strongly supportive of sustainable urban drainage solutions (SuDS) as these will be essential to establishing community resilience to the impacts of climate change into the future. Whilst we appreciate there may be a need for some flexibility, Southern Water considers SuDS essential for all development. This is in line with paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) that requires:
167(c) using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. As stated in Water UK’s 21st Century Drainage Programme;
“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.
In terms of community resilience to the impacts of climate change into the future, better rainwater management through SuDS is the preferred approach. Retrofitting sustainable drainage solutions can be challenging. By showing the way with new development we can reduce the implementation costs of these measures whilst securing truly sustainable development.

Quite simply, ALL new homes and developments should be forced to build solar panels onto the roofs as part of the agreed planning permission.

Totally agree with this action but it also must be cost effective

Railfuture London & South East regional branch endorses this.

No comment

There could be a stronger emphasis on encouraging economic growth through Medway taking a more active Industrial role in the development of manufacturing and technology required for climate change mitigations.

Happy with policy, however must ensure the Rural Areas, Natural Environment and Historic Environment are not affected detrimentally.

Your spacial strategy suggests that it will be redesigned with wildlife in mind yet we have seen no evidence of this. Small mammals cannot travel anywhere safely to breed, feed or migrate.

There is no consideration of ways to manage additional water resources. The last reservoir was built in 1991. Money will be needed for flood defences.

Unless all the roads on the Hoo peninsula are considerably improved there will not be any improved access to anything! Binney floods, the road is still broken up from the development of 9 houses (completed over a year ago). You will destroy peoples well-being. Food cannot be grown if you destroy farmland! By doubling the amount of cars in the village it goes against the government’s mission for less cars on the road. Despite pathetic efforts of developers with swift/swallow boxes (none have been used on the new houses in Binney) they just drive nesting birds away.

In response to Q1

CPRE Kent is keen to ensure that before setting local standards for development are considered that an appropriate spatial strategy is developed which is truly sustainable and places the environment at the heart of Medway's future as a means of addressing climate change.

Blindly developing a spatial strategy purely in response to (greenfield) sites being promoted by developers - as set out in our comments under 2.1 (the Council’s vision), 2.3 (Strategic Objectives), 2.3 Spatial Development Strategy and 3.2 (Preferred Spatial Growth Option) - does not make a good strategy.

In the interests of climate change, the Council’s strategy needs to be right from the outset, rather than policy seeking to retrofit poor strategy decisions. Such a strategy needs to be based on evidence-based planning which prioritise the environment and identifies the positive qualities and placemaking benefits of so called environmental 'constraints'.

Please see covering letter from The Planning Bureau dated 6th September which includes the following recommendation:

Recommendation:
The draft policy should not be amended and the council should not consider setting local standards.

In response to Q1:

CPRE Kent is keen to ensure that before setting local standards for development are considered that an appropriate spatial strategy is developed which is truly sustainable and places the environment at the heart of Medway's future as a means of addressing climate change.

Blindly developing a spatial strategy purely in response to (greenfield) sites being promoted by developers - as set out in our comments under 2.1 (the Council’s vision), 2.3 (Strategic Objectives), 2.3 Spatial Development Strategy and 3.2 (Preferred Spatial Growth Option) - does not make a good strategy.

In the interests of climate change, the Council’s strategy needs to be right from the outset, rather than policy seeking to retrofit poor strategy decisions. Such a strategy needs to be based on evidence-based planning which prioritise the environment and identifies the positive qualities and placemaking benefits of so called environmental 'constraints'.

I have never read so much rubbish as I have in this article. You clearly don't care about the environment if you're more than happy to allow developers to just concrete all over it, no construction work will never do any good for the environment

It's important that we protect our countryside from commercial development.

Q1: The Council should not go beyond national policy/regulations in addressing climate change. National policy and regulations are continually changing adapting to new and different concerns.

For example, the Future Homes Standard (FHS) is anticipated to launch in 2025. The technical consultation on the proposed specification of the FHS took place in Spring 2023; further consultation is to take place throughout 2024, followed by the adoption of the regulations in 2025. From 2025, compliance with the FHS will become mandatory and will ensure that new homes built from 2025 will produce 75-80% less carbon emissions than those constructed under current Building Regulations. The FHS seeks to decarbonise new homes by improving heating and hot water systems and reducing heat waste.

Notwithstanding the above, it is noted that the FHS has yet to be adopted. Significant concerns and risks were raised in the technical consultation relating to the impact of the increased costs of implementing the FHS on house prices and building costs. In turn, there is a chance that the full impact of achieving net zero could filter through into the viability and subsequent delivery of new schemes. It would, therefore, be prudent for the viability assessment to be re-run, including the scenario within which the FHS is implemented and considering any government funding to ensure that new development is able to achieve net carbon zero and remain viable.

Given the reasons set out above and the example of the FHS we consider that the Council should work policy S1 in a way that is flexible and adaptable enough to meet the ever-evolving requirements of national policy when it comes to meeting the challenges of climate change. The Council do not want to be over reliant on her policy in the future that is out of date with the current national policy at any particular one time.

Although Medway is just a small player in global climate change events, any steps to improve on the impact we have on the climate can only be beneficial.

The Council should not go beyond national policy/regulations in addressing climate change. National policy and regulations are continually changing adapting to new and different concerns.

For example, the Future Homes Standard (FHS) is anticipated to launch in 2025. The technical consultation on the proposed specification of the FHS took place in Spring 2023; further consultation is to take place throughout 2024, followed by the adoption of the regulations in 2025. From 2025, compliance with the FHS will become mandatory and will ensure that new homes built from 2025 will produce 75-80% less carbon emissions than those constructed under current Building Regulations. The FHS seeks to decarbonise new homes by improving heating and hot water systems and reducing heat waste.

Notwithstanding the above, it is noted that the FHS has yet to be adopted. Significant concerns and risks were raised in the technical consultation relating to the impact of the increased costs of implementing the FHS on house prices and building costs. In turn, there is a chance that the full impact of achieving net zero could filter through into the viability and subsequent delivery of new schemes. It would, therefore, be prudent for the viability assessment to be re-run, including the scenario within which the FHS is implemented and considering any government funding to ensure that new development is able to achieve net carbon zero and remain viable.

Given the reasons set out above and the example of the FHS we consider that the Council should work policy S1 in a way that is flexible and adaptable enough to meet the ever-evolving requirements of national policy when it comes to meeting the challenges of climate change. The Council do not want to be over reliant on her policy in the future that is out of date with the current national policy at any particular one time.

Building more houses will only dilute the percentages which is a fudge to make things LOOK better.
Install FREE solar panels and install insulation in older and existing houses, that would really bring things down for the existing stock. Add more only changes the denominator and thus a lower FUDGED figure.

I think it is vitally important to include food secuity here.

"Development must minimise the impact and mitigate the likely effects of climate change on existing and future communities and the environment and minimise the use of natural resources." seems to be an oxymoron. Development caused human climate change in the first place.
The main priority of all planning for the future must be the restoration of nature, then we can look at human development.