Medway Local Plan (Regulation 18, 2023)

Trenport Investments Limited (TIL) prepared these representations to Medway Council’s (‘the Council’) Regulation 18 Local Plan consultation in relation to Land to the East and West of Church Street, Cliffe, Rochester (‘the site’). TIL welcomes the first step by the Council in advancing a new Local Plan and for the opportunity to make comment on its contents.

The Regulation 18 Local Plan document sets out the framework for the area’s growth up to 2040 and where and how new development can take place. Section 1.4 notes that this consultation does not detail policies or identify those sites preferred by the Council for new development and that detail will come in the next stage of work on the Local Plan. It is also notes in Section 5.1 that the Local Plan will
include a Policies Map which will show land allocated for new housing development. Notwithstanding the above, Map 3 on Page 22 of the Regulation 18 Local Plan provides an overview of potential sites for rural development. The Site is not included within Map 3.

Section 5.12 sets out that the housing needs for the Council over the plan period is 28,339 and figure 2 splits the potential sources for the supply into three categories - pipeline, windfall and allocations. Section 5.13 notes that there is an existing pipeline of sites for over 7.500 homes, the Site is likely not included as a pipeline site as it does not yet have planning permission. Therefore, unless the Site has
been included as a windfall, the Site should be considered as an allocation.

Section 5.14 and 5.15 notes that the Council has produced a Land Availability Assessment (LAA) to review potential sources for allocation. The LAA identifies land with potential capacity for circa 38,200 homes of which many of these sites are subject to constraints including environmental considerations. Section 5.16 goes on to note that the LAA has identified four broad categories of locations where development could take place – Urban regeneration, suburban growth, rural development, green belt loss. In this context, the Site would be considered a rural development site. However, the Site is not included in Map 3 as a potential site for rural development and is therefore likely to have been excluded from the 14,736 homes in the rural development category of the 38,200 potential housing capacity set out in Table 1. As such, it is not clear if the Site is being considered as an allocation or any other category within the Regulation 18 Local Plan.

In addition, Section 5.39 of the document notes that most of the sites currently being promoted for housing led development are large scale with the potential to provide land for hundreds of homes. On this basis, the Site should be considered as it could provide up to 250 homes along with a number of benefits outlined above and is not the subject of any environmental constraints.

TIL seeks clarity on the status of the Site within the consultation document and emerging local plan. We would strongly recommend that the Site, which has been the subject of the scrutiny of a Public Inquiry where the Council withdrew their objections, is included on Map 3 in the next version of the Local Plan and any future iteration of the policies map in the Local Plan