Medway Local Plan (Regulation 18, 2023)

The Climate Response Team welcome the inclusion of climate change within the overall vision. The planning system has a significant role to play in designing places that cut carbon emissions and build resilient communities. In addition to this being an opportunity to refresh the vision and objectives of the Local Plan in line with the council’s ambitions, this is also an opportunity to establish the Local Plan as a fundamental driver for a range of solutions to the climate crisis.
We have the following specific feedback on this section:
• Paragraph 2 - The new Local Plan should be a key delivery tool in achieving net zero carbon emissions for Medway. This section should make it clear that the vision is for a net zero carbon and adaptation framework which needs to be ambitious. Consider rewording to say, “Medway will have achieved a significant reduction in carbon emissions (well on its pathway to net zero by 2050) aided by developments which have adopted high sustainable buildings standards (not just in construction but use and refurbishment too) and are achieving ambitious net zero carbon targets. Alongside this, adaptation is an essential component of all development and Medway is well prepared for its long term future adaptation needs”.
• There should be a commitment to use evidence to set local carbon reduction targets (for example through SCATTER or Tyndall tools) for the Local Plan so that its success, and that of its associated policies, can be can be measured.
• The vision around energy is lacking and yet emissions from domestic energy currently make up 38.99% of all Medway emissions compared with 29.4% from transport. Consider saying, “Medway is delivering against a strong local energy plan and communities are harnessing the results of their direct involvement in decision making on community owned, local energy infrastructure”.
• Paragraph 3 - Not sure that everyone will understand the term “green growth” – is there another way to explain what this means?
• Paragraph 3 - Where flooding is mentioned, risk of overheating, drought and soil erosion should also be included. These are noted elsewhere in the document but not captured here. Linked to this should be a greater explanation of the role that new and protected natural assets will play in carbon sequestration and adaptation and the co-benefits this brings of enhanced biodiversity, good air quality and improved public health.
• Paragraph 3 - Remove “with a clear path mapped out to reaching net zero” as this should be in place now (well before 2040) and significant achievements realised by 2040 (see first bullet point above).
• The vision jumps around a bit and may benefit from some restructuring. For example, the mention of Medway transitioning to a low carbon economy in paragraph 3 doesn’t tell us much, the details follow in paragraph 9.
• There is currently no mention of minimising the need for travel although this is possibly inferred in paragraph 6 where it says “people can meet most of their daily needs in their local area.” Reducing the need to travel is the first step in the transport hierarchy and will be key to achieving a reduction in emissions. It is mentioned in paragraph 9 in terms of commuting. Again, an example of where the vision jumps around a bit and could be stronger if slightly restructured.
• Paragraph 7 - “Older properties have been retrofitted to improve sustainability”. The word sustainability is vague. The challenge here is to retrofit them for energy efficiency and adaptative measures to make them less vulnerable to the impacts of climate change. Consider re-wording to say “Property owners have felt sufficiently supported to retrofit older properties to make them more energy efficient and less vulnerable to the impacts of climate change such as overheating.”
• We welcome the mention of a low circular economy but the vision could be more meaningful, for example: “A significant reduction in emissions from waste (including water) is achieved through provision of infrastructure and services which support people to reduce waste and reuse more. The circular economy is embedded into business models and applied to developments.”

The wording of this objective is vague and does not clearly define what the plan aims to achieve. Consider rewording this to say “Support the achievement of a net zero carbon Medway and tackle the negative impacts of climate change through adaptation” or “Working together for a net zero carbon and resilient future.”
• The first bullet point feels like a list of buzzwords. Please revisit some of the comments made previously around the vision in Section 3, for example:
o Establish the Local Plan as a framework to achieve significant reduction in carbon emissions. This should be the driving principle, not just environment as a theme; likewise
o elevate the significance of having clear adaptation plans to minimise the effect of the impacts of climate change (not just “seeking” measures) on people and places most at risk.
o the term “net zero carbon” should be used consistently through the document rather than intermittently with terms such as “zero carbon” or carbon neutral.
o adaptation measures are not limited to mitigating flood risk; it should also include overheating and droughts
o To deliver on Medway’s net zero carbon targets, “Drive reductions in the carbon impacts of new homes by setting minimum requirements for developers to ensure that whole life carbon costs are considered (embodied carbon of materials and processes).
o We welcome the consideration to protect vulnerable communities as these groups are most likely to feel the effects of climate change. This should be its own bullet point (perhaps under the objective around communities).
o Nature based solutions and transport are mentioned in the first bullet but should be removed from here and warrant having their own bullet point so as not to dilute the significance of them.
o Energy needs its own bullet point and there should be a commitment to determining the future energy requirements based on the development needs of Medway to support a clear and comprehensive Local Area Energy Plan, including large scale and localised renewable energy solutions. It is essential that consideration should be given to the most and least environmentally sensitive sites for deployment of solutions to avoid negative impacts.
o In the bullet about transport, it should reference the travel hierarchy to include minimising the need for travel in the first instance through spatial planning.
o In the bullet about green and blue infrastructure, more emphasis is required around addressing resilience through the creation and protection of natural assets. The current statement doesn’t quite make sense, “providing resilience for nature through better connectivity and conditions.” Also, bring in the co-benefits of enhanced biodiversity, good air quality and improved public health being realised.
o See previous comments about waste (Section 3).
o A final bullet should be to establish clear guidance and high standards for developers to adhere to which reflect the aspirations of net zero carbon and adaptation. Also, to prioritise climate change when determining development applications.

• “Drive reductions in the carbon impacts of housing in new developments…..” by setting minimum requirements to ensure that developments accord with the energy hierarchy and take a “fabric first” approach. Renewable energy is “designed in” to social and affordable housing to help level up access to cheaper energy. Energy security is prioritised to help reduce fuel poverty. Expand on the existing point “secure opportunities for retrofitting older properties” with “and ensure property owners feel sufficiently supported to retrofit older properties to make them more energy efficient and less vulnerable to the impacts of climate change such as overheating”.
• The following key points should also be included:
o To create places that promote social interaction since people who are isolated can be more vulnerable to the impacts of climate change.
o Empower communities to have direct involvement in decision making on community assets and infrastructure so that they feel galvanised to take action.
o Empower residents and businesses to make sustainable choices for example support with developing staff travel plans.
• Include reference to neighbourhood plans and the role of the Local Authority in providing support/guidance around climate change considerations to empower communities to make significant contributions to development and infrastructure in Medway.

Consider expanding on the sentence “Build on existing strengths and expertise, such as engineering, energy and creative industries, and raise the profile of key sectors, to attract and develop the skills and jobs of the future required to enable the vision for example, skills to enable low carbon resilient developments£.
We welcome the inclusion of green tourism as a consideration. Noting, however, that tourism itself is likely to be adversely affected by the impacts of climate change. For example, shifting of wildlife habitats.

Consider including “Ensure the restoration of iconic Medway buildings (including those with a heritage designation) and subsequent prevention of premature building demolition (and the associated carbon emissions of disposal) by protecting against the impacts of extreme weather. Reuse and repurpose existing buildings (such as vacant units on the High Street) before building new, where possible.”
Recognise the role that new builds have, in doing the upmost to avoid climate impact risks so that remedial action is not an afterthought or the responsibility of future generations. Resilience planning should be very long term, at least 100 years.
Instead of “seeking opportunities for greener construction,” this should state “drive reductions in the carbon impacts of housing in new developments…..” by setting minimum requirements…”

The testing criteria, for the 4 location categories, should also include a risk assessment of current and future climate change impacts such as flooding

It is important that we say here that achieving Medway’s net zero carbon target is already challenging without adding in the forecasted level of housing required to meet population growth. This highlights the significant role the Local Plan has as a vehicle for achieving Medway’s net zero ambitions.
The Council will also need to assess the potential need to relocate communities which may be vulnerable to the impacts of climate change. If climate mitigation targets are not met, the number of displaced communities will likely increase putting further pressure on housing needs.

New item for inclusion under Development Needs – it is essential that future energy requirements based on the development needs of Medway will be determined and how this will support a clear Local Area Energy Plan, including large scale and local energy schemes.
The testing criteria, for the 4 location categories, should also include a risk assessment of current and future climate change impacts such as flooding,

New item for inclusion under Opportunities - Studies are under way to assess potential district heating opportunities within the central urban and urban waterfronts which could support the increasing energy demands of future growth.

Would suggest explicitly saying that the Council will need to consider how flood risk areas are managed, in particular with regard to new build developments on the functional flood plain