Medway Local Plan (Regulation 18, 2024)

We are writing on behalf of our client, Richard Castle, in respect of the Medway Local Plan (Regulation 18, 2024) consultation and its supporting background documents.
Our client continues to promote the sites now referred to as AS14, AS15 and AS17 in the consultation document and located at Middle Stoke on the Isle of Grain as suitable for residential led schemes in future Medway Local Plan (MLP). These sites, which extend to approximately 2.72ha, 0.86 ha and 7.83 ha respectively are identified as suitable for “reasonable alternative development”, with each having a possible capacity of 90, 15 and 180 units respectively. Given the adjacent landownership being the same as these sites, there is potential for greater delivery should the Council so require.
This consultation response provides feedback on both the main Regulation 18 documents and its background documents, specifically the Sustainability Appraisal and the Viability Assessment.
This representation supports the inclusion of sites AS14, AS15 and AS17 for inclusion in the future Local Plan for Medway and provides detailed feedback on individual paragraph numbers and policies as follows:
• Paragraph 1.2.2:- We support the vision for the plan which seeks to identify sites that will enable people to live healthier and longer lives. We consider that sites AS14, AS15 and AS17, will provide a safe, connected and sustainable place to live and work.
• Paragraph 1.2.8:- We support the statement that ‘Housing-led growth can support wider investment in services and businesses and contribute to shaping the character of new and existing communities’.
Section 2.3 ‘Spatial Development Strategy’ :- The aspirations of the Spatial Development Strategy for Medway are supported, specifically, “Outside of the urban regeneration areas, the Council will support the expansion of identified suburban neighbourhoods and villages, where the principles of sustainable development can be met, and where unacceptable impacts on infrastructure and the environment can be avoided”.
Sites AS14, AS15 and AS17 form part of a grouping of sites located centrally on the Isle of Grain, which have been identified as suitable for residential development. The fact that the land parcels of the 3 sites are all under the family ownership means they can be delivered more easily, whilst allowing for a phased release. These sites, when developed together and having regard to their surrounding will prevent isolated development and create a neighbourhood area which would meet the aspirations of sustainable development.
Furthermore, section 2.3, sets out that “Development will respond positively to the environmental context and realise opportunities to boost biodiversity and resilience”. The current land has limited biodiversity value, but given the wider land ownership by our client, has the potential to enable the provision of biodiversity enhancements and the creation of a green infrastructure which will connect the sites to the wider countryside. On this basis, the development of the site for residential uses would enhance biodiversity in accordance with National policy aspirations and the draft proposals in the Local Plan.

Policy S2 ‘Conservation and Enhancement of the Natural Environment’:- The aspirations of this policy are supported. The development of sites AS14, AS15 and AS17 provides a wider opportunity to contribute and enhance the natural environment and its network in accordance with the policy wording.

Paragraph 4.6.2:- “Green infrastructure is intrinsic to good development and quality place making”. This statement is supported, sites AS14, AS15 and AS17 provide the potential opportunity to enable the sites’ to link with each other and the wider countryside.

Policy T1: Promoting High Quality Design. A policy to support design proposals is supported. However, a policy that has been drafted as a ‘catch-all’ to respond to every eventuality is considered to provide a risk of making some schemes unviable. It specifically does not respond well to different sized schemes, for example, as drafted the policy requires all schemes to provide public art, which would not normally be expected of smaller sites.
A further example is that the following criteria is considered to be unnecessary when all development is required to be ‘sustainable’ by preceding strategic policies. The criteria itself is also not quantifiable- “There is demonstration of provision and/or access to essential services and facilities sufficient to support existing and new growth”.
It is considered that the 21 criteria within the policy could easily be streamlined, and the policy would not be any less impactful. This is especially the case when there is a further Housing Design policy, set out at Policy DM5 (discussed further below).

Policy DM5: Housing Design:- In a similar response to Policy T1, the criteria in this policy should be reconsidered as some of the criteria would be better suited to a more overarching strategic policy. The last criterion of DM5, in particular, is considered to be unnecessary, lacking clarity, and would be better suited to a strategic policy:
“All new accommodation must, in addition to the general design policy above (T1): ●Design for flexible living, successful places are robust and support 'long-life and loose-fit' neighbourhoods that are flexible and adaptable to rapidly changing circumstances. The physical and social infrastructure provision required to create sustainable communities have been considered”.
This criterion, and the additional requirements for single aspect homes, seem more like a generic and vague aspiration than those based on a sound evidence base.

Policy T3: Affordable Housing: We object to the wording of this policy which set out the requirement for the level of affordable housing at 30 % for the Hoo Peninsula. It is important that the policy enables flexibility based on viability assessments when also having regard to environmental enhancement.

Policy T11 ‘Small Sites and SME Housebuilders’, we support the inclusion of a policy which supports the provision of development by small and medium sized businesses, as these sites can be built-out quickly and support local jobs.