Medway Local Plan (Regulation 18, 2023)

Paragraph 119 of the NPPF sets out that ‘planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living
conditions’.
It is set out in the current consultation that “The role of the Local Plan is to plan positively for the development and infrastructure that the area needs, whilst conserving and enhancing the natural, built and historic environment”.
In order to deliver the Local Plan, it is proposing that the plan is set around strategic objectives. “The objectives will feed into the wording of policies and how sites and different locations are assessed for potential development.
The objectives are presented around broad themes for the environment, communities, economy, and investment in
infrastructure and design that is fit for the future”. This representation supports the use of objectives to deliver the strategic aims of the plan, but wishes to raise the following comments regarding the individual objectives

This representation supports the provision of quality and resilient development in Medway and we support the Council’s recognition that growth does not mean losing character of an area.

The second bullet point sets out that sustainable development should be directed to the “most suitable locations that can enhance Medway’s economic, social and environmental characteristics”. This stance is supported, as it acknowledges that development of both brownfield and greenfield sites can come forward to meet the housing requirement. The most suitable locations that can enhance Medway's economic, social and environmental characteristics should be utilised to deliver the housing requirement of the area.
An allocation for development at Bloor’s Farm would provide an opportunity to deliver this objective, in a development which meets the aspirations of sustainable development, directing development to the most suitable location.

The NPPF (paragraph 20), sets out that strategic policies should ‘set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for [amongst others]:
a) housing (including affordable housing), employment, retail, leisure and other
commercial development’;

Furthermore, the National Planning Policy Framework (‘NPPF’) requires that in order to boost housing supply, local planning authorities (‘LPAs’) should identify a supply of specific deliverable sites sufficient to provide 5-years’ worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of housing.

The consultation report highlights at paragraph 5.4 that “It has to be recognised 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 and the requirements for those desperately needing a good quality home”. It goes on to acknowledge that many existing residents are living in over-crowded and / or sub- standard housing conditions.

It is important that the protection of the intrinsic character and qualities of a site or an area are considered, but these qualities can be protected when new housing development is delivered, through good design and by improving the sustainable networks and access to places and services. Rather than seen as negative, new housing development should be seen as an opportunity to improve the area for the current and future residents delivering the types and quantity of homes that are desperately needed.
On this basis, respectfully, reference to ‘housing delivery’ should be made in the vision.

The NPPF sets out in paragraph 22 that it is important that ‘where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’.

It is submitted that the development of Bloors Farm as a primarily housing-led scheme could be an option to deliver not only the existing elements of the vision for Medway, but could also deliver important housing numbers in the Medway area early on the plan period. The site is both available and the development of the site is achievable.

We are writing on behalf of our client, AC Goatham and Son of Flanders Farm, Ratcliffe Highway, Hoo St Werburgh, Kent, ME3 8QE in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.

AC Goatham & Son remains committed to the promotion of Bloors Farm as a site for predominantly housing-led residential development in the future Local Plan. This representation is made in this context and demonstrates a clear justification for designating the site as a sustainable urban extension to meaningfully contribute to the Council's substantial housing requirements within the district.

This site was formerly promoted for housing development through the representations made by Begur Ltd to the Regulation 18 consultation in April 2017 and secondly through Rapley LLP who continued to support the site through the Regulation 18 consultation held in June 2018. Now being promoted through Bloomfields Chartered Town Planners, the site still provides an opportunity for positive growth in the Medway area to 2040.

AC Goatham & Son has significant land ownership interests across the Medway area and also has interests in a number of sites which they have long term leases on. Within Medway the business farms over 500 acres of land for top fruit (apples and pears). In the last 10 years the business has invested over £20 million in built infrastructure in Medway to support its farming business.

The production of the Medway Local Plan has involved a number of key stages. With three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final regulation 18 consultation before the publishing of the Regulation 19 draft plan.

The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development. However, this representation builds on previous submissions by both Begur Ltd and Rapley LLP. AC Goatham & Son, continues to promote the site known as Bloors Farm, as a primarily residential housing-led scheme, in the context of the current open consultation.

Context

This representation seeks to continue the promotion of the site known as Bloors Farm. Lower Rainham Road, Rainham, which has previously been promoted for housing development through the 2008 Call for Sites exercise undertaken by Medway Council, the Local Planning Authority (LPA) and subsequently assessed through the 2019 Strategic Land Availability Assessment (SLAA).

Bloors Farm is circa 27.32 hectare and was submitted under the name “Land between Pump Lane & Bloors Lane, Rainham”. It was given the reference number in the SLAA of ‘Site 750’. A plan of the site being promoted is attached at Appendix 1 for information.

Bloors Farm was last assessed by the Council through the Medway Strategic Land Availability Assessment (SLAA) in December 2019, and along with a separate site in the ownership of our client, Pump Farm, both were identified as being available and achievable. However, they were subsequently deemed unsuitable without identified constraints being overcome. They were therefore not included to be carried forward for the next stage of assessment as part of the site selection for the Draft Local Plan.

The overall conclusion in the SLAA considered the site unsuitable for development unless identified constraints could be addressed. The constraints that were identified as unresolvable were because the site was ‘agricultural land’ and was identified as being the best and most versatile agricultural land. It is supported that during this Regulation 18 consultation the Bloors Farm site is now included within the area which is identified as a potential area of suburban expansion.

This representation confirms that the site continues to be promoted primarily for a housing-led development scheme. The strategic location and size of the site provides the opportunity for the delivery of a minor mixed-use scheme, which could be developed in isolation or more strategically with neighbouring sites, namely Pump Farm.

This representation responds to the current Regulation 18, by setting out how these constraints to development could be overcome. In addition to responding to each of the headings in the consultation plan, and identifying how the Bloors Farm site can deliver the vision and objectives through sustainable development.
 The vision for Medway in 2040
 The strategic objective; and
 Developing a Spatial Strategy

Overcoming Constraints:
The SLAA site assessment of Bloors Farm concluded that the only identified constraint for Bloors Farm was that the site is agricultural land. A further interpretation of the Local Policies map also identified that the site is in an area of Locally Valued Landscape.

It is set out below that both of these constraints can be overcome. In addition, The LPA is now reconsidering the suitability of Bloors Farm, as it is included in the general suburban land approach advocated in the general suburban extension model advocated in Map 2 of the consultation ‘Map 2 – overview of potential sites for Suburban Expansion’. An approach that is actively supported through these comments.

AC Goatham & Son confirms that this site will become surplus to requirement as orchards during the Local Plan period, which extends to 2040. It is expected over the coming years that some of the periphery orchards, Bloors Farm being one, will no longer form the main basis of their business model as the intention is to draw in operations closest to their headquarters and consolidate outlying interests. This meets the aspirations of NPPF paragraph 83, which advocates that ‘planning policies and decisions should recognise and address the specific locational requirements of different sectors’. The use of Bloors Farm with its intensive fruit farming operation has attracted significant residential complaints in recent years. Furthermore, the impending requirements for investment in replanting in the coming years will make the ongoing use of the site as an orchard unviable. The need for these sites to remain as agricultural land has been confirmed as having diminished significantly as to effectively extinguish what was formerly identified need.

The landowners is therefore releasing Bloors Farm, along with the neighbouring farm, Pump Farm, during the Local Plan process from their business portfolio of operational orchards. However, for the purposes of confirming land availability Pump and Bloors Farm are available now.

In respect of the Area of Locally Valued Landscape, it is our view that there will be no unacceptable impact on the landscape value. The Council’s Medway Landscape Character Assessment (2011) (‘MLCA’) identifies this area as an urban fringe with
urban/industrial influences. However, the landscape “condition” and “sensitivity” are identified as “moderate”.

It is now identified in the current consultation that the site could form part of a suburban expansion model, a model which is supported. It is therefore considered that the development of the site with a comprehensive and sensitive masterplan approach to incorporate appropriate landscaping will address any early landscape concerns. These could be undertaken a both strategic level through the Local Plan and on the site itself via careful masterplanning. In accordance with paragraph 125 of the NPPF 125, ‘area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places’.

As set out in previous Local Plan consultations it is understood that the full range of development needs cannot solely be met in the identified regeneration areas on brownfield land. On this basis, the approach set out in paragraph 5.16, which identifies four broad locations for development is supported; urban regeneration, suburban growth, rural development and green belt loss. By ensuring that there is a wide-spread of potential locations, any potential increase in defined housing supply numbers will be able to be absorbed.

Support- The national position advocated in the NPPF, where the development of Green Belt sites should be a last resort and only considered once other sites have been considered first. This would align with the “exceptional circumstances” test set out in national policy.

Larger scale development (for residential and employment purposes) should, in the main, be prioritised in areas not within the Green Belt or within AONBs, although due regard must be had to where this is development that supports the preservation of such a landscape through land management – again, immediately at the site or in the wider domain.

This objective is supported.
This representation promotes the use of the suburban expansion option, amongst others, as a way that could deliver a sustainable and green future for Medway. The use of suburban, and rural extensions will bring forward opportunities to support sustainable communities and a future sustainable transport network. It will also enable the wider and strategic aim of supporting a green and blue framework for better connectivity for wildlife and improve the quality of lives for residents within.

Paragraph 5.34 Development come forward in these edge of settlement locations, there will be an acknowledged shortfall for existing services, such as schools and health services to cater for the increased population. The site at Bloors Farm provides a clear opportunity to deliver a large development which would be able to meet some service requirements for future residents as part of a mixed-use scheme.
If the site is utilised in conjunction with other suburban extension sites, for example Pump Farm, it could deliver a strategic development which has the potential to deliver a larger strategic outcome for service delivery.

Paragraph 5.32 identifies that “Much of the land around the north and east of Rainham is the best and most versatile farmland”. As set out in previous submissions, in order to deliver the appropriate development required in this area, “less weight will obviously need to be placed upon the value of agricultural land in the context of other matters and wider benefits delivered from possible development on site". It will be important to assess sites not within nationally designated areas, such as the AONB at the first
opportunity.

We also support paragraph 5.31 which acknowledges that large sites on the periphery of the towns would provide opportunities to enhance sustainable travel, local services and work spaces near to people’s homes. With the opportunity to provide a development
that would meet the principles of the ‘15 minute neighbourhood’.

As the promoters of the Bloors Farm development site, there is a clear and defined opportunity to deliver a housing development that will improve sustainable travel, including pedestrian connections, and reducing the over reliance on the car.