Medway Local Plan (Regulation 18, 2023)

General Comments:
Given the extreme urgency and the vital importance to society as a whole of decarbonising the world economy and given the current government’s wavering on the vital measures required in order to achieve net zero by 2050. It falls to Local Government to make the right sustainable choices in their Local Plan in order to move the sustainable agenda forward.
As such the emerging Medway Local plan has a key role in the UK achieving its targets of net zero by 2050. The principles of sustainable development which are referred to as key goals for the emerging local plan are essential and fully supported.
Specifically, the following concepts are seen as effective and evidenced based strategies which will provide for sustainable development over the plan period.

1. Locating residential and commercial development adjacent to and within existing service centres with good public transport links. Providing community and commercial services within walking and cycling distance (typically 800 meters) is supported by the National Planning Policy Framework and is therefore complaint to national policy in addition to being a sound sustainable design principle.
2. Linked to the point above the reduction of car dependency is essential and fully supported. Increasing dependency on car use is unsustainable due to the carbon footprint traditional fuelled cars. Additionally newer electric cars are not without a significant indirect carbon footprint and are therefore not a panacea. The new local plan has the ability to design for and encourage the vital modal shift from individual car journeys to mass public transport. Medway is blessed with 7 railways stations which connect west-east and north-south. The existing transport hubs Strood, Rochester, Chatham, Gillingham, Rainham Halling and Cuxton give the Local Plan ample opportunity to locate development in sustainable locations within the confines of existing built-up areas.
3. The outlined focus on existing town/ settlement centres for development is supported as this will provide for sustainable communities which have critical mass and footfall to ensure commercial success and community vibrancy.
2. Context
2.2 We support with the aspiration expressed in this paragraph.
2.4 We agree that for the plan to be successful it needs to be ambitious with regard to the demands identified and the sustainable manner in which the issues outlined are resolved. The Council should take inspiration from the International Energy Agency’s report entitled “Net Zero Roadmap” published September 2023 which states that staggering growth in renewable energy infrastructure projects means that net zero targets and limiting global temperature increase to 1.5 degrees is feasible. The work undertaken for the Medway Local plan can build on these positive moves by designing a truly sustainable future for Medway.
2.5 We think that this statement could be reinforced the threat of climate change to human society in general and Medway specifically is vast and life threatening. Having the capability to undermine societal norms as we have come to accept them.
It is vital that the new Local Plan recognises that this is the critical moment in terms of preventing global climate instability. Medway Council cannot take all the responsibility for this on a global scale, but it must within its own area of geographical, political and social responsibility lead in sustainable initiatives. The Key test in any of the proposed allocations within the plan should be “does the development increase or decrease the ability of achieving true net zero development before 2050.”
2.6 The issue of reduction on car dependency is vital in terms of not only achieving sustainable development but also in terms of the quality-of-life and life expectancy experienced by the residents of Medway.
As is noted later in the consulation document the road network in Medway is at or beyond capacity. A situation which is unlikely to be resolved anytime soon. In the meantime, there is a real need to resolve the housing shortage which is having negative consequences in everyday life of many of the younger residents of Medway. As evidenced by the difficulty of finding affordable housing for purchase or rent due to high demand and inadequate supply.
We support the initiative and ambition to think differently about how people travel short, medium, and longer journeys. We agree that the reliance on single use car journeys is no longer a sustainable choice. The Local Plan presents an enormous opportunity to propose alternative solutions which will reduce road congestion, air pollution and carbon emissions.
2.7 Housing should not be looked at in isolation. We would propose that the concept of the 15-minute city where communities are designed so that all key services are within a maximum 15 minutes’ walk of any residential unit. This concept combined with the increase of work form home practices across many industries has the ability to reduce traffic generation, provide local footfall and activity for local businesses and provide the structure within which sustainable communities can build up over time.

3. Vision for Medway 2040
3.1 We support the vision statement.

We think that this statement could be reinforced. The threat of climate change to human society in general and Medway specifically is vast and life threatening. Having the capability to undermine societal norms as we have come to accept them.

It is vital that the new Local Plan recognises that this is the critical moment in terms of preventing global climate instability. Medway Council cannot take all the responsibility for this on a global scale, but it must within its own area of geographical, political and social responsibility lead in sustainable initiatives. The Key test in any of the proposed allocations within the plan should be “does the development increase or decrease the ability of achieving true net zero development before 2050.”

2.6 The issue of reduction on car dependency is vital in terms of not only achieving sustainable development but also in terms of the quality-of-life and life expectancy experienced by the residents of Medway.

we support this aspiration

we support this aspiration

We support this statement however we would suggest adding a sentence specifying that homes jobs and services are located in sustainable locations well served by public transport and green networks.

No matter what the argument is over the precise method of calculation is. It cannot be denied that ther is a very real housing crisis and the Medway local plan should as a matter of principle commit to solving this lack of housing supply within the plan period.

There are two ways of looking at this issue. The current capacity constraints on the road network north Kent are not unique to Medway. Neither are the very real needs for housing and other forms of development. If the issue of lack of capacity is viewed form the perspective of a continued high car usage across the network, then this issue becomes a catch 22 which prevents forward movement in the local plans of many North Kent Local Authorities.

However, viewed from the perspective of restricting climate change and moving positively forward to net zero by 2050. The capacity lack of capacity on the strategic road network is an opportunity to design communities and their transport requirements differently. In order to meet net zero targets the use of private vehicles is going to have to be reduced.

Given that developments located near to public transport hubs will tend to reduce private vehicle use and those located distant from public transport hubs and adjacent to existing strategic road networks will tend to increase private vehicle use. It is proposed that developments within the emerging Local Plan should be sustainably located in close proximity to existing and proposed new transport hubs.

As such the Local Plan should consider a hierarchy of sustainable development against which to measure sites promoted for development. Where sites adjacent to existing transport hubs and services are classed as highly sustainable and those located away from transport hubs and adjacent to large strategic road network are classed as unsustainable. With a sliding scale of sustainability between the two extreme points on the scale

As of this weekend reports in the National media are picking up that Governmental support for the Lower Thames Crossing is waning. This could have enormous implications on road capacity and the general environment that the Local Plan is developed within. The progress of the LTC should be monitored as the plan progresses.

It is our view that accepting to allocate an extra 2000 homes onto top of the 19,000 homes that remain to be found within Medway is an unacceptable and unsustainable position to accept, given the existing clearly defined constraints that exist within the boundaries of Medway itself. Any proposal to accept Gravesend Borough Councils overspill would be contrary to the ambition to reduce pressure on local services and will not be supported.

We refer to our comments regarding proximity to public transport hubs and the assessment of sustainability outlined in Para 5.7. Furthermore, we would suggest that once sustainable options for development have been identified the notion of a sustainable phasing should be considered for inclusion in the local plan by Medway Council. This could look something along the lines of

• Phase 1 – sites within 800m of existing transport hubs and local services
• Phase 2 – river frontage sites adjacent to newly developed water-based transport systems
• Phase 3 – rural sites located around newly provided rail hubs.

This would allow time for the funding for the proposed river transport system and the rail extension into the Hoo peninsular to be identified and secured along with the design and implementation of these new initiatives.