Medway Local Plan (Regulation 18, 2023)

1. The following representations are made in response to Medway Council’s (the “Council”) Local Plan 2040 (LP2040) Regulation 18 Consultation – Setting the Direction for Medway 2040 (September 2023) on behalf of Catesby Estates, in respect of its land interests at Allhallows, Rochester, Medway.

2. These representations should be read alongside the following supporting document:

a. Catesby Estates – Allhallows Vision Document

3. The Council has not proposed specific questions as part of this consultation, therefore Marrons’ response follows the chapters within the LP2040 and makes comments where appropriate.

Chapter 1 – Introduction

4. The LP2040 states within the introduction that this consultation does not detail policies or identify those sites preferred for new development. Catesby Estates supports the approach the Council has taken in looking at the needs of Medway holistically, given the unique context of the area. In planning for development to 2040 it is important to consider proportionality and deliverability across the plan period. Consequently, as commented on in more detail later in these representations, Catesby Estates considers that the most suitable approach is one which delivers housing and prosperity via a range of options.

Chapter 2 – Context

5. The LP2040 notes that Medway is a complex place, with distinct towns and villages that have strong identities and heritage, but looks to the future with innovation and enterprise. Catesby Estates considers that any strategic plan for the region should therefore consider how the region can be developed to encourage and sustain Medway’s growth to 2040. It is therefore encouraging that the LP2040 also states that people will be at the centre of the Plan and it will consider the diverse communities who make up Medway. Catesby Estates also supports the notion in the LP2040 that “housing-led growth can support wider investment in services and businesses and contribute to shaping the character of new and existing communities” (paragraph 2.7).

6. Catesby Estates agrees with the Council’s assertion that the LP2040 can help Medway ‘capitalise on its strategic advantages for businesses, with transport links, proximity to London, the cluster of universities and colleges, and a diverse portfolio of employment plan’ (paragraph 2.8). There are clearly opportunities to attract more businesses to set up locally and re-balance the commuting patterns, something the LP2040 notes as being ‘central to Medway’s economic strategy’ (paragraph 2.8). This can be achieved by creating vibrant and well-connected communities with a range of uses and a choice of homes.

7. Notably, as the LP2040 comments, Government funding has been withdrawn from the Housing Infrastructure Fund (HIF) for strategic transport and environmental schemes. The HIF programme was central to the delivery of key infrastructure ahead of growth coming forwards and it is acknowledged that there are pressures on the existing infrastructure. Catesby Estates considers that development can help fund key infrastructure improvements, that benefit existing communities and help Medway implement its economic strategy. Notwithstanding, the delivery of infrastructure improvements must be sustainable in order to keep pace with growth and Catesby Estates suggests this is best achieved by a balanced approach across Medway, rather than in one focus area.

Chapter 3 – Vision for Medway in 2040

8. Catesby Estates supports the vision outlined within the LP2040, particularly where it references the unique characters that contribute to the areas identify, involving coastal, countryside and urban locations. It is important that all areas of Medway enjoy the planned growth available via the LP2040 and the associated benefits it can bring.

‘Supporting people to lead healthy lives and strengthening our communities’
11. Catesby Estates supports the need for high quality housing and for a choice of housing that meets the needs of the local communities. Notwithstanding, any associated policies must be evidenced robustly to ensure they are a true reflection of local need. Communities need to grow in order to maintain services. Development in Allhallows presents an opportunity to deliver homes and services which will contribute to strengthening the existing community, as well as providing homes in an area identified for significant employment growth.

12. Catesby Estates also supports the reduction in inequalities related to health and considers that well planned rural homes can offer good access to green and blue infrastructure, which the LP2040 is also focussed on, that will in turn also support the development and retention of local services.

‘Securing jobs and developing skills for a competitive economy’
13. Catesby Estates agrees that a pillar of the LP2040 will centre on boosting the local economy and attracting inward investment through a choice of quality employment land that meets the needs of businesses. It is also considered however that a choice of homes that meets the needs of current and future residents will support the desired increase in the local economy and assist in Medway becoming an attractive place to live and work. Development in Allhallows will allow a rural choice of homes within an existing settlement that is well positioned to sustain future growth, given it lies within close proximity to the Isle of Grain and Kingsnorth; two of the largest existing employment opportunity areas in Medway. The expansion of Allhallows will not only enable the services and facilities within that settlement to thrive and improve, but also provide increased choice to local people to remain in the area and encourage the live-work model that the LP2040 is striving to achieve.

‘Boost pride in Medway through quality and resilient development’
14. The LP2040 focusses on the need for the provision of good quality infrastructure, sustainable development and making the best use of brownfield land. Catesby Estates considers that Medway has big ambitions and in order to achieve these it is vital that growth is planned and implementable. In order to deliver the desired connectivity, choice of economic land, choice of new homes, promote inward investment and cater to the needs of the existing communities, a holistic approach is required that looks towards connecting and supporting the whole region.

Chapter 4 – Strategic objectives

‘Prepared for a sustainable and green future’
9. Catesby Estates supports the need to plan for a sustainable and green future, however, this must be done in a way which is viable so that development is not stifled and the associated benefits realised more quickly. In order to ensure transparency, it is vital that Government policies and agendas are built into the Plan, rather than bespoke strategies which may be harder to implement and/or govern.

10. Catesby Estates is also supportive of the Council’s aspirations for green growth, particularly in terms of securing ‘a robust green and blue infrastructure network’, and considers that this should be inclusive of delivering the new homes required, rather than seen as competing issues. By way of example, expanding Allhallows will allow the sensitive delivery of homes where they are needed, whilst investing in the protection and enhancement of valued environmental assets. This should be embraced and incorporated within well designed development, rather than seen as a constraint to development at locations where sustainable development is possible. ‘The Concept’ shown on page 6 of the accompanying Vision Document demonstrates how this might be possible with the Site.

Chapter 5 – Developing a Spatial Strategy

‘Development needs’
15. Catesby Estates agrees that a ‘Local Plan should be positively prepared for sustainable development. It should not be used to stop development that is needed for our growing and changing communities’ (paragraph 5.2). Alongside this Catesby Estates supports the Council’s growth ambitions and advocates an unconstrained and holistic view of development across Medway, in order to achieve this.

16. The LP2040 correctly identifies that the Government directs Local Planning Authorities to use its Standard Method when determining the scale of housing required over the plan period. As the LP2040 sets out the standard method identifies a minimum need of 28,500 homes over the plan period to 2040 (1,667 dpa). The LP2040 further states that this is higher than the rates of housing building seen in Medway for 30 years (paragraph 5.3). Catesby Estates is clear that Government policy should be followed when preparing a Local Plan to ensure it is positively prepared, compliant with national policy and thus able to be found sound. At the time of writing it remains that the Standard Method is the starting point for calculating the minimum housing need and it is this calculation that the Council should therefore use when preparing the Plan.

17. Moreover, as the Planning Practice Guidance (PPG) refers, unconstrained housing need could exceed the standard method minimum:

‘The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates…
…Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;…’ (our emphasis)
(Paragraph: 010 Reference ID: 2a-010-20201216)

18. Catesby Estates therefore considers it counter-productive, given the Council’s own vision and strategic objectives which seek to transform the economic performance and prosperity of Medway, to immediately limit housing needs based on past trends – clearly the future of Medway cannot be assessed on past trends given the ambition of the Council and LP2040 into the future: to exceed the past delivery and economic performance of Medway.

19. Whilst Catesby Estates recognises the concerns of the Council regarding existing infrastructure and future capacities, the preparation of a Local Plan is the correct tool with which to address these issues. It is vital therefore that the LP2040 plans for the correct level of development, in particular housing, so the correct level of supporting infrastructure can be planned alongside.

20. Notwithstanding the above comments, Catesby Estates also notes the request from Gravesham Borough Council to provide an additional 2,000 homes to help it meets its needs. This further increases the requirement within Medway and highlights the need to plan for housing that can be delivered at all stages of the plan period.

21. Paragraph 5.12 of the LP2040 states the housing needs for Medway over the plan period pf 2022-2040 to be 28,339. Paragraph 5.3 and 5.11 subsequently note the need to be 28,500. Furthermore, paragraph 5.3 also refers to the need as 1,667 homes a year, which when taken across the 18 year plan period (2022-2040), results in a total need of 30,006 homes. With three different figures in the LP2040, it is imperative the Council are clear on the housing needs of Medway and if it has applied any reductions to the standard method figure. Notably however, a buffer will need to be applied to the correct figure as the Council confirms at paragraph 5.12 and Gravesham’s unmet need will also need to be accounted for. Catesby Estates therefore considers that the plan period need for Medway will be closer to 34,000 homes (1,888 dpa).

22. At Figure 2 of the LP2040 the Council sets out how many sites are considered to be in the pipeline (with planning permission), those it expects to come forward as windfall sites and thus the remainder it will need to allocate within the LP2040 in order to meet its needs.

23. Regarding pipeline sites, Catesby Estates notes this figure to be 7,583, which is 27% of the need across the plan period (using the Council’s figure of 28,500). This is considered significant and the Council should assess these sites to ensure they are deliverable before relying on them in a new Plan. Any planning permissions which have lapsed should indicate that a Site is not coming forward in the short term.

24. Regarding windfall sites, Catesby Estates notes this figure to be 3,000, which is 10.5% of the need across the plan period (using the Council’s figure of 28,500). The National Planning Policy Framework 2023 (NPPF) is clear that where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply (Paragraph 71). Catesby Estates therefore requests that the Council provide robust evidence that demonstrates 3,000 homes are capable of being delivered via windfall sites across the plan period.

25. Regarding the number of homes needing to be allocated within the LP2040, it is noted that this is likely to rise following the correct calculation of need across the plan period. Nevertheless, Catesby Estates suggests the Council should consider allocating more sites within the LP2040 in order to require less unplanned development to meet its needs across the plan period.

26. Paragraph 5.15 of the LP2040 notes that the Land Availability Assessment (LAA) has revealed land with a potential capacity for circa 38,200. Catesby Estates suggests that sites contained within the LAA are therefore assessed robustly and objectively to enable the Council to plan and allocate sites for the majority of its housing need.

27. Table 1 of the LP2040 demonstrates the potential housing capacity for each of the category areas, according to the LAA. It shows that a potential capacity of 11,151 homes exists within urban areas, which is considered a high level of growth. Catesby Estates considers that caution should be applied when considering whether this this level of urban growth is feasible, and whether it will deliver the right choice of homes. Complexities exist with urban redevelopment that often impact the speed and viability of delivery. In addition, such development also delivers a greater proportion of smaller sized units and the Council need to consider this carefully against the aim of the LP2040 and needs of the existing a future population of Medway.

28. Table 1 of the LP2040 also confirms that circa 40% of the potential sites fall within the rural development areas of Medway. This reflects a need for the Council to consider its growth locations and corridors holistically and not miss opportunities to allocate sites that would contribute to the vision for Medway, and provide links to different areas. The expansion of existing settlements such as Allhallows can deliver family homes with policy compliant affordable housing. Any environmental impacts can be mitigated through careful layout and design that ensures future development respects and enhances its surrounding context.

29. Paragraph 5.36 of the LP2040 discusses sites with the potential for development in the rural areas and focusses heavily on those sites put forward on the Hoo Peninsula. The LP2040 does not discuss other rural areas where sites have been put forward such as Allhallows – at this stage the LP2040 should be considering all options and assessing them against the vision for Medway. Whilst it is noted that the Hoo Peninsula can accommodate some new development, it is a notable constraint that HIF funding has been removed, and the Council comments at paragraph 5.45 that the capacity of infrastructure to support major growth on the Hoo Peninsula is a strategic consideration.

30. Notwithstanding, Catesby Estates considers that Allhallows forms part of the wider area which the Council has spent much time developing proposals for and therefore complements the development prospects on the Hoo Peninsula when viewed holistically, particularly those related to industry. Indeed, Catesby Estates recognises that such urban growth may take a long time to come to fruition, as seen elsewhere in the country with strategic development locations. Consequently, Allhallows represents an opportunity for early delivery without the need for significant infrastructure, within a wider area which has long term growth potential, helping achieve the desired long term aim of increased prosperity in the region, alongside maintaining an annual supply of homes.

Land at Allhallows, Rochester, Medway

31. Catesby Estates is promoting Land at Allhallows, Rochester, Medway (“the Site”) for residential-led development through the LP2040. The Site is identified in the Council’s LAA as one of the sites put forward within the ‘rural areas’. The enclosed Site Location Plan details the extent of the Site and a Vision Document providing more detail regarding its context, opportunities and constraints, and development potential is also enclosed with these representations.

32. The Site directly adjoins Allhallows’ southern and eastern boundaries and has the opportunity to deliver new homes and facilities to support the growth and function of Allhallows as a self-sufficient and sustainable year-round community, alongside supporting nearby employment growth at Hoo St Werburgh, Grain and Kingsnorth. The Site has the capacity to accommodate circa 350 new homes, via a landscape-led development approach.

33. Figure 3 within the accompanying Vision Document details the Site’s immediate context, opportunities and constraints. It also demonstrates the significant caravan/holiday park accommodation that is located within Allhallows, which is considered an issue for its year-round vitality and social prosperity. Given the vision of the LP2040 is to boost economic activity and promote inward commuting patterns, existing settlements such as Allhallows have the opportunity to accommodate new sustainable growth that will benefit existing residents, helping to spread the vision across Medway. Moreover, Allhallows already has key infrastructure such as a primary school, community facilities and a GP surgery, therefore the proposed development will help complement the existing services and facilities, making Allhallows a more sustainable community.

34. Figure 7 within the accompanying Vision Document demonstrates the emerging context of Medway following the publication of the LP2040 consultation. Hoo St Werburgh and the Hoo Peninsula are key areas for Medway, alongside the areas of planned employment growth at Kingsnorth and Isle of Grain. Allhallows is situated on the northern coastline, approximately equidistant from Kingsnorth and Isle of Grain. The Site’s location therefore provides a choice of new homes within a commuting distance of two planned employment growth areas, helping link up existing communities with future economic prosperity.

35. These new homes and year-round population will assist in sustaining the existing services and facilities within Allhallows, as well as supporting enhancements in the range of local services and facilities and therefore the general future sustainability of the settlement. It should be noted that enhanced services and facilities are likely to boost the seasonal population of the holiday parks and lead in to an increase in tourism trade for Allhallows and the surrounding areas.

36. In addition, Investment in on-demand public transport links between Allhallows, the Isle of Grain, Kingsnorth and importantly Strood (for train links and secondary education facilities) will all be explored as part of the development proposals to further reinforce the sustainability and connectivity of Allhallows within the Hoo Peninsular.

37. The Site is considered to support the Councils four strategic objectives set out within the LP2040, as detailed on pages 12 and 13 of the accompanying Vision Document, but in particular support for development on the Hoo Peninsula and at Allhallows.

38. Marrons and our client Catesby Estates would be pleased to discuss the Site and its development potential further with the Council, as appropriate.