Medway Local Plan (Regulation 18, 2024)

It is CPRE Kent’s overall view that the strategic objectives are largely positive with a strong emphasis on the need to conserve and enhance the natural, built and historic environment, which aligns with CPRE Kent’s goal of protecting the countryside. However, it is important that these objectives translate into firm actions and policies that prioritise the environment over development.

For example, whilst the Plan talks about improving transport networks, it should also consider the impact of transportation infrastructure on rural areas. Building more roads will lead to increased car dependant development and urban sprawl in rural areas, which can negatively affect the countryside.

This is a particular concern that we have with respect to the Hoo Peninsula, as made clear within our responses to the various HIF related consultations we have previously participated in and our 2023 Regulation 18 comments.

While we support the aspiration for high-quality homes that genuinely meet the housing needs of Medway, it is our view that there should be a far greater emphasis within the strategic objectives of redeveloping brownfield sites over greenfield sites.
We welcome the placement of delivering the Council’s commitment to the Climate Emergency at the top of the proposed strategic objectives. However, we would like to see this expanded to include meeting the ecological emergency.

In this regard, it is CPRE Kent’s view that the countryside itself can provide many of the solutions to tackling climate breakdown and the ecological emergency, while supporting rural communities and economies to thrive. Development should meet local need, while contributing to efforts to mitigate and adapt to the climate emergency.

Sustainable development needs to be redefined to focus on living within environmental limits and the importance of addressing the climate emergency. At the national level, CPRE is campaigning for all new development to demonstrate a net negative carbon footprint, and for all plans and infrastructure programmes to demonstrate how they will achieve a reduction in total road transport, not just the need to travel, and that climate action is a key test of soundness in the examination of all development plans.

We therefore consider that the new local plan will need to give ‘positive discrimination’ towards the environment by giving clear priority to policies which seek to mitigate climate change.

For Medway, fundamental to this will be ensuring that the overall strategy for the local plan is firmly focused upon optimising the recycling of land that has already been used for buildings by adopting a truly ‘brownfield first’ strategy. This will need to be put at the forefront of developing the Plan, so that it is clearly reflected within each of the Plan’s objectives.

Alongside this, we would expect to see ring-fencing of all environmental measures within the local plan viability appraisal as being non-negotiable fixed costs. This should include the need for all new-build residential development to be designed to achieve zero carbon homes, with a requirement for detailed carbon assessments demonstrating how the design and layout of the development has sought to maximise reductions in carbon emissions, a water efficiency standard of less than 100 litres and ensuring significant improvements in the dwelling emission rate over the target carbon dioxide emission rates.

We would also expect to see proactive policies that increase the area of habitats that sequester and store carbon and those which support projects for retrofitting existing building stock. Again, this will need to be clearly reflected within the objectives of the Plan.
Overall, the proposed objectives show a commitment to environmental sustainability, but it's essential to ensure that these objectives are effectively translated into precisely worded policies and actions that prioritise the protection of the countryside and its unique ecosystems. Furthermore, robust monitoring and enforcement mechanisms should be put in place to ensure that development does not come at the cost of rural landscapes.

We are CPRE, the countryside charity. Formed in 1926, CPRE is a registered charity and one of the longest established and most respected environmental groups in England, with over 40,000 members and supporters living in our cities, towns, villages and the countryside. CPRE Kent is the largest of the CPRE county branches.

Our vision is of a beautiful and thriving countryside that enriches all our lives, and our mission is to promote, enhance and protect that countryside.

We believe that the planning system is a toolbox for achieving better – for people, nature and the economy – while supporting the delivery of more badly-needed homes to end the housing crisis.

In general, CPRE Kent supports a development strategy which meets the following criteria:
1. Brownfield first, especially in urban areas and not in rural areas where it would result in unsustainable patterns of development
2. Development should result in sustainable communities
3. Provision in rural areas where there is an identified local need and the scale of development is appropriate for the size of the settlement
4. The plan should promote development in locations:
a. that are well supported by, or that will support, sustainable transport and active travel.
b. that are well served by regular public transport services and social and community facilities, that are in safe walking and cycling distance or would support, or result in, a sustainable settlement.
5. Ensuring our unique English countryside landscapes are protected and valued for the benefit of current and future generations.

Overall, it is our position that local planning authorities should seek to ensure that the impact of development on the countryside, both directly and indirectly, is kept to a minimum and that development is sustainable in accordance with national planning policy.

Our detailed comments on the 2024 Regulation 18 consultation are as follows:

2.1 Vision for Medway in 2041
CPRE Kent considers that overall, the vision appears to be a comprehensive and ambitious vision with positive goals.
However, running to more than two pages of text it is very wordy and not easily digestible. Headings and bullet points would help in terms of presentation.

CPRE Kent welcomes the proposed development strategy in so far as it prioritises regeneration, makes the best use of previously developed land and directs investment to urban waterfront and centre opportunity areas.

However, we cannot support a strategy that places such significant reliance on greenfield sites (on the Hoo Peninsula).

As set out in our comments on the 2023 Regulation 18 consultation we are concerned that the Council’s strategy has been dictated by the sites submitted by developers (as part of the Land Availability Assessment).

It is CPRE Kent’s view that this is a flawed approach to plan making as, consciously or subconsciously, it places too much influence in the hands of developers who will naturally prioritise their financial interests over the genuine needs of communities.

In this respect, such an approach inevitably leads to a strategy heavily weighted towards greenfield sites. The reason for this is it is greenfield sites that are almost unilaterally promoted by developers, as it is these sites which give the greatest profit.
Such undue reliance upon developer submitted sites inevitably leads to a haphazard spatial strategy that lacks a cohesive, long-term vision. This in turn neglects important aspects such as sustainable infrastructure, environmental considerations, and the social wellbeing of residents.

A far more effective approach would be for the Council to take firm ownership of the direction of the spatial strategy and then proactively identify potential development sites to deliver that strategy.

As set out below, this could include targeted call for sites. The spatial strategy needs to be grounded in comprehensive, evidence-based planning that prioritises the environment (and identifies the positive qualities and placemaking benefits of ‘constraints’ to the environment) and the wellbeing of both current and future Medway residents, rather than short-term developer interests.

It is our strong view that such an approach would naturally lead to a true “brownfield-first” spatial strategy, spearheading the regeneration and improvement of the Council’s urban areas. Likewise, we see significant constraints with respect to the amazing environmental and ecological features that the district is blessed with, particularly on the Hoo Peninsula.

For the reasons set out in our earlier representations, it is clear to CPRE Kent that Medway’s new local plan should embrace a true “brownfield-first” spatial strategy. That is, before any greenfield land is released, far more needs to be done to demonstrate that brownfield opportunities have been maximised.

The Council know that those sites on its brownfield register are simply a list of sites already known to it, either as a consequence of a planning application or an existing local plan allocation. These add nothing in terms of identifying future additional supply.

It is also the case that very few brownfield sites will ever come forward as part of a call for sites exercise as these are usually in locations where the principle of development is already acceptable, meaning there is very little point in a landowner going through the unnecessary expense of promoting their site through the local plan process. Instead, the real profit is to be made from the promotion of greenfield sites, where the principle of development has not been agreed, hence why these naturally dominate any call for sites exercise as set out above.

A far more proactive approach needs to be undertaken. Key to this will be a full, detailed and up-to-date Urban Capacity review that robustly identifies where further development opportunities are within the urban areas.

Alongside this, we would want to see a brownfield land specific call for sites that is advertised as widely as possible. This should include local communities and the general public being actively encouraged to identify brownfield sites, with the Council working alongside to identify and overcome existing delivery constraints.

As an organisation we are happy to work proactively with the Council on this, utilising the CPRE Brownfield Land Register Toolkit which has been developed specifically for this purpose https://www.cpre.org.uk/resources/brownfield-land-register-toolkit/ . Likewise, we would welcome working with Medway Urban Greenspaces Forum to identify where there may be further opportunities for regeneration that’s welcomed by communities and developers alike.

With respect to delivery, it has always been our opinion the HIF Funding of £170 million being directed to releasing development on greenfield sites on the Hoo Peninsula was a massive, wasted opportunity. Instead, Medway Council should have been doing everything it could to get this funding re-directed so it could bring forward the various stalled brownfield sites within the Medway Urban Areas.

We are therefore extremely pleased to see that Medway received £3,968,371 from the first phase of the Department for Levelling Up, Housing and Communities Brownfield Land of £60 million to help release brownfield sites, including the Strood Waterfront and the Debenhams building in Chatham. With the second phase of monies also released and a total fund of £4.8 billion available, we would expect to see evidence of the Council having been fully engaged in securing the necessary funding to bring forward both the brownfield sites that have currently stalled and new sites identified.

We would also expect to see Medway’s leaders partnering with Homes England to bring forward identified brownfield sites and regenerating Medway’s high streets, where an increased residential offering will be anticipated. We would also expect to see evidence of the Council having fully engaged with all possible delivery partners before deciding that any sustainably located brownfield site is not deliverable.

CPRE Kent is calling on the new Plan to maximises the development potential (by density) of those sites located within the most sustainable areas. This needs to come hand in hand with good design, sufficient infrastructure and in particular sufficient active travel and public transport options that provide a realistic alternative to car dependency, along with sufficient well designed green spaces and inviting public realm environments. Higher density certainly does not have to come at the expense of good planning.

Overall, unless such proactive steps are undertaken, we are not going to accept the usual argument given to CPRE Kent that there are insufficient brownfield sites available for development, leaving no option but to allocate further greenfield land.

The higher the density, the more benefits accrue, and the more (greenfield) land is saved. High density building does not equate to high rise apartment blocks. CPRE London published a report in 2019 on this issue called ‘Double the density , halve the land needed’ which sets out both the benefits of higher density design along with providing examples of higher density developments being achieved by a variety of means. This includes a mixed-use residential development at Springhead Park, Ebbsfleet, Kent where 160dph is being achieved.

As set out above, we believe it is wrong to simply continue sacrificing yet more greenfield land in an attempt to accommodate what is an unsatisfiable external market demand. We would therefore firmly object to any further allocation upon the Hoo Peninsula beyond that accepted by the existing communities, as needed to maintain and support them.

This position is in recognition that the Hoo Peninsula is a largely rural area, containing significant environmental constraints including ancient woodlands, SSSI’s, SAC’s SPA’s and RAMSAR sites. It is also predominately Best and Most Versatile agricultural land and has significant areas of intrinsically dark skies, the loss of which should be strongly resisted. The ecology upon the Hoo Peninsula is extremely sensitive, containing one of the largest breeding sites in the UK for the nightingale population, highly protected water voles along with recently proven habitats of the rare purple emperor butterfly and dormouse. Medway also has at least six red listed rare birds sheltering in its boundaries including the Black Tailed Godwit, the Curlew and the Pochard and many more on the amber list. We note only last year, surveys on the Isle of Grain discovered the extremely rare Shrill Carder Bee only known to be found in seven areas across England and Wales and never before discovered in Kent.

It is also the fact that the Four Elms Hill and Peninsula Way through Chattenden suffers significant levels of air pollution, hence it being designated an Air Quality Management Area (AQMA). The proposed development associated with the £170 HIF funding bid largely sought to justify itself on the basis it was needed to help fund this new road infrastructure. With car ownership and usage rates on the Peninsula already much higher than the rest of Medway, our responses to the various HIF consultations strongly objected to the principle of the building yet more traffic inducing new roads that facilitate building, or “unlocking”, greenfield sites.

The benefits of new roads schemes are extremely over-stated and in reality, generate traffic above background trends by inducing traffic, which leads to permanent and significant environmental damage. Specifically, and as set out in our report ‘The end of the road? Challenging the road building consensus’, March 2017 https://www.cpre.org.uk/resources/transport/roads/item/4543-the-end-of-the-road-challenging-the-road-building-consensus, the building of new roads to accommodate further growth is just going to significantly exacerbate the Peninsula’s accepted existing problem with ingrained car dependency.

We remain unconvinced that the selection of the Hoo Peninsula for any substantial housing development beyond what is needed to support existing communities would survive the scrutiny of the Local Plan process. Focus must now be on mitigating the worst effects of the unplanned windfall development that has taken advantage of the HIF Funding debacle and are now coming forward without any plans for the necessary mitigation being put in place. As a minimum, Medway must be doing all it can to resist these developments as they continue to come forward. The first step to this will be making it as clear as possible, as early as possible, that Medway’s new local plan will not be looking to allocate any further significant development upon the Hoo Peninsula

For any allocations upon the Hoo Peninsula to be considered remotely acceptable by us, they would need to be demonstrably sustainable with very genuine levels of self-containment and deliverable sustainable transport options. This may include alternatives to the previously proposed rail station such as zero-emission dedicated bus routes that we are beginning to see elsewhere in Kent, such as Dover’s new Fasttrack service between Whitfield and Dover - https://www.dover.gov.uk/Planning/Regeneration/Fastrack/Dover-Fastrack.aspx.

In terms of the dispersed growth element of the blended strategy, CPRE Kent could support growth adjoining the existing urban areas to the south and east of Medway if it was demonstrated a true brownfield first approach had been undertaken, vital greenspaces were maintained and enhanced, and that sufficient infrastructure was to be provided. However, we are concerned that much of the area identified is Best and Most Versatile land. As set out within CPRE’s recent report “Building on our food security” in the past 12 years England has lost over 14,000 hectares of Grade 1 and 2 agricultural land to development, the equivalent to the productive loss of around 250,000 tonnes of vegetables. It also appears that this figure is increasing. Nationally there has been a 100-fold increase in 2022, from that built on in 2010. This loss cannot continue to be ignored. This issue will need to be given significantly more consideration with respect to the allocations which do make it to any submission version of the plan.

Specifically, we would want to see and understand what sequential measures have been undertaken to minimise loss of Best and Most Versatile land. We would also want to see how this significant constraint has been given the due regard necessary with both the setting of an appropriate housing figure for Medway and then the site selection process, informing which sites are taken forward to allocation. It is however our starting assumption that any loss of BMV could be avoided.

Where sites on the urban edge are to come forward, we would want to see that sufficient active travel and public transport options that provide a realistic alternative to car dependency are provided. We would also want to see that existing green spaces are sufficient protected and improved/expanded to accommodate an increasing population. Where new land is given over to development, it should be used as efficiently as possible, as appropriate for that site’s location.

In response to Q1

CPRE Kent is keen to ensure that before setting local standards for development are considered that an appropriate spatial strategy is developed which is truly sustainable and places the environment at the heart of Medway's future as a means of addressing climate change.

Blindly developing a spatial strategy purely in response to (greenfield) sites being promoted by developers - as set out in our comments under 2.1 (the Council’s vision), 2.3 (Strategic Objectives), 2.3 Spatial Development Strategy and 3.2 (Preferred Spatial Growth Option) - does not make a good strategy.

In the interests of climate change, the Council’s strategy needs to be right from the outset, rather than policy seeking to retrofit poor strategy decisions. Such a strategy needs to be based on evidence-based planning which prioritise the environment and identifies the positive qualities and placemaking benefits of so called environmental 'constraints'.

In response to Q1:

CPRE Kent is keen to ensure that before setting local standards for development are considered that an appropriate spatial strategy is developed which is truly sustainable and places the environment at the heart of Medway's future as a means of addressing climate change.

Blindly developing a spatial strategy purely in response to (greenfield) sites being promoted by developers - as set out in our comments under 2.1 (the Council’s vision), 2.3 (Strategic Objectives), 2.3 Spatial Development Strategy and 3.2 (Preferred Spatial Growth Option) - does not make a good strategy.

In the interests of climate change, the Council’s strategy needs to be right from the outset, rather than policy seeking to retrofit poor strategy decisions. Such a strategy needs to be based on evidence-based planning which prioritise the environment and identifies the positive qualities and placemaking benefits of so called environmental 'constraints'.

In response to Q2

CPRE Kent welcomes policies which prioritise the natural environment and its biodiversity. As such we support the Council going beyond 10% BNG.

As set out in paragraph 4.3.7 of the Plan, a KCC commissioned study (Viability Assessment of BNG in Kent, 2022) found that an uplift from 10% to 15 or 20% would not materially affect viability.

In response to Q2
Yes

In response to Q5
Yes

In response to Q7
Yes