Medway Local Plan (Regulation 18, 2023)

Overall, CCE support the vision and strategic objectives set out in the consultation document. In particular ‘to provide for high quality energy efficient homes that meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs’ alongside ‘the provision of a portfolio of good quality employment land’. The objectives also, importantly, recognise development should be of high quality, resilient and supported by the timely provision of infrastructure to facilitate a sustainable and green future. CCE support the intention to deliver sustainable development, meeting the needs of Medway’s communities whilst respecting the natural and historic environment and directing growth to the most suitable locations.

The Council may need to consider extending the plan period beyond 2040, noting the intention is to adopt the Plan at the earliest in 2025 and the NPPF (2023), paragraph 22, states that strategic policies should look ahead over a minimum 15-year period from adoption.

Overall, CCE support the vision and strategic objectives set out in the consultation document. In particular ‘to provide for high quality energy efficient homes that meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs’ alongside ‘the provision of a portfolio of good quality employment land’. The objectives also, importantly, recognise development should be of high quality, resilient and supported by the timely provision of infrastructure to facilitate a sustainable and green future. CCE support the intention to deliver sustainable development, meeting the needs of Medway’s communities whilst respecting the natural and historic environment and directing growth to the most suitable locations.

Overall, CCE support the vision and strategic objectives set out in the consultation document. In particular ‘to provide for high quality energy efficient homes that meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs’ alongside ‘the provision of a portfolio of good quality employment land’. The objectives also, importantly, recognise development should be of high quality, resilient and supported by the timely provision of infrastructure to facilitate a sustainable and green future. CCE support the intention to deliver sustainable development, meeting the needs of Medway’s communities whilst respecting the natural and historic environment and directing growth to the most suitable locations.

Overall, CCE support the vision and strategic objectives set out in the consultation document. In particular ‘to provide for high quality energy efficient homes that meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs’ alongside ‘the provision of a portfolio of good quality employment land’. The objectives also, importantly, recognise development should be of high quality, resilient and supported by the timely provision of infrastructure to facilitate a sustainable and green future. CCE support the intention to deliver sustainable development, meeting the needs of Medway’s communities whilst respecting the natural and historic environment and directing growth to the most suitable locations.

Overall, CCE support the vision and strategic objectives set out in the consultation document. In particular ‘to provide for high quality energy efficient homes that meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs’ alongside ‘the provision of a portfolio of good quality employment land’. The objectives also, importantly, recognise development should be of high quality, resilient and supported by the timely provision of infrastructure to facilitate a sustainable and green future. CCE support the intention to deliver sustainable development, meeting the needs of Medway’s communities whilst respecting the natural and historic environment and directing growth to the most suitable locations.

The consultation document refers to the Government’s standard methodology for housing need formula which identifies a need for 1,667 homes a year in Medway, or around 28,500 homes over the plan period to 2040. The National Planning Policy Framework (NPPF) requires the use of the standard method for calculating housing needs and Planning Practise Guidance (PPG) requires use of the Office of National Statistics (ONS) Household Growth Projection data from 2014. The government made it clear in its recent consultation on proposed changes to the NPPF that it will not be amending the standard methodology to utilise 2018 data. Medway should therefore continue to base its housing need calculations using the established methodology, until such time as any updated or amended methodology is published by the government.

CCE support the recognition in the consultation document that there is a housing crisis, particularly regarding affordability and there is an absolute need to provide the right homes in the right places to meet Medway’s growing needs. CCE support paragraph 5.11 and 5.12 of the document which align with the NPPF and recognise the need to (a) consider if there is capacity to provide homes to help meet Gravesham’s unmet needs and (b) adding a buffer to supply, equating to a need to plan for 29,000 homes over the plan period.

Planning to meet full housing needs will also provide growth benefits for existing communities in Medway. This is acknowledged within NPPF paragraph 79 which states that to support sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Developing a Spatial Strategy – Rural Development Sites
Hoo Peninsula – Hoo Rural Town

CCE recognise that, in meeting the identified housing requirement, the Council should look to bring forward urban sites and previously developed land. However, it is also noted that such sites are often costly to bring forward and can take time to become available to deliver the required housing. Urban sites are also often more suited to flatted developments delivering smaller units which only caters to a small element of housing need locally. These considerations, coupled with Medway’s significant housing need will require the identification and release of less constrained greenfield sites.

To achieve its vision, CCE consider that the Local Plan needs to be ambitious, yet fully deliverable. It needs to ensure that the housing and employment needs of the Borough can be delivered with clear guidance as to the most appropriate and sustainable sites to accommodate the required housing and employment. In doing so, the Council will need to take a pragmatic approach to a range of development options. In this regard, CCE fully supports the proposals in the draft Hoo Development Framework (2022) for significant growth at Hoo St Werburgh and subsequently, the Council identifying this land as a potential broad location for development in the consultation document (Map 3).

The Hoo Rural Town offers the opportunity to provide a sustainable new community in its own right, with high quality supporting infrastructure. The expansion of Hoo St Werburgh and the surrounding villages offers new opportunities and many potential benefits to the area and Medway as a whole. There is potential for the area to grow by c. 10,000 homes over the next thirty years. New development would be planned to improve travel choice and reduce the need to drive with an attractive and comprehensive cycling and pedestrian network. People will be able to use an expanded range of local services and facilities close to home. There will be new schools and health facilities, shops, businesses, leisure and community services. It would provide growth that meets people’s needs for homes, jobs and services, whilst respecting the natural and historic environment.

The support for these proposals is clearly set out in the submission by Stantec prepared for the Consortium, including CCE. As noted above, these representations will not repeat or seek to reiterate the commentary prepared by Stantec on behalf of the Consortium in relation to the land at Hoo St Werburgh.

CCE own land east (call for sites submission ID 299, SHLAA ref. HHH31) and west (call for sites submission ID 300, SHLAA ref HHH22) of Ropers Lane which could accommodate around 3,500 new homes alongside supporting social infrastructure. The site presents an opportunity for a sustainable extension to the east of the existing settlement of Hoo St Werburgh and should be considered as part of the wider Hoo St Werburgh Rural Town, which provides the opportunity to deliver a highly sustainable community securing significant housing growth supported by infrastructure; employment opportunities; services and facilities as well as environmental enhancements. It also provides new links and connections to the proposed and existing employment areas at Kingsnorth.

This representation therefore confirms that land within CCE’s ownership at the Hoo Peninsula should be identified to assist in meeting the housing requirements and development needs of the Borough.

In this context, and as set out in the February 2023 call for sites submissions, CCE have commissioned the following initial surveys: Ecological Assessment, prepared by Ecology Solutions (January 2023); Agricultural Land Classification report, prepared by Strutt and Parker, January 2023; Heritage Assessment (above and below ground), prepared by Terrance O Rourke, (January 2023); Landscape and Visual Appraisal, prepared by Terrance O Rourke (March 2023); and, Utilities consultation note, prepared by Pell Frischmann (September 2020). Pell Frischmann are also appointed to provide technical advice to CCE on Highways and Flooding. The surveys confirm that there would be no overriding constraints to the development of land within CCE’s ownership at the Hoo Peninsula. Further technical assessment as required would be instructed by CCE as part of any future planning application, to inform future development proposals.

Other Rural landholdings

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

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

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

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

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

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

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

Phasing

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

Employment Site – Land at Kingsnorth
In addition to the housing requirements, CCE also own land adjacent to the Kingsnorth employment area (call for sites submission ID 298, SHLAA ref. HHH35) and consider that this land could be made available to provide further employment opportunities, as and when required.

CCE and their consultant team have undertaken initial assessments and a land capacity study to identify the potential of the land within CCE ownership around Kingsnorth to deliver employment growth. Initial feasibility work demonstrates that land to the west of the existing Kingsnorth employment area and south of the railway line would be suitable for expansion in the short term.

The site is suitable and available for employment use which could accommodate between 157,000sqm & 176,000sqm of floorspace, split between B2, B8 and E uses. The site could also support the wider proposals of the Hoo St Werburgh Rural Town, which would deliver a highly sustainable new community, enabling people to live in close proximity to jobs, thus reducing need to travel far by car and encouraging use of sustainable means of travel (as set out in the draft Hoo Development Framework Masterplan, November 2022). A planning application is already progressing on part of the site for employment development (reference MC/23/0104).Therefore, CCE support the land at Kingsnorth having been identified as a potential employment site allocation in Map 5 of the consultation document as well as the support throughout the consultation document which recognises Kingsnorth on the Hoo Peninsula to be a unique opportunity for employment land provision, with a key role to play in Medway’s economic development strategy.