Object

Representation ID: 4795

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan is considered incomplete and possibly insufficient to prove it is “positively prepared,” “justified,” and “effective” as required by the NPPF. Relying on an interim Habitat Regulations Assessment (HRA), pending air quality assessments at a crucial stage weakens confidence in the Plan’s evidence base. Lack of clear evidence showing how consultation feedback has influenced Plan changes, inadequate assessment of all potential sites and alternatives. Interim HRA before completing a full air quality assessment risks breaching the Conservation of Habitats and Species Regulations 2017; requires Appropriate Assessment before Plan submission. Lacks coordination between authorities to manage cross-boundary environmental impacts effectively.

Object

Representation ID: 4852

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Stakeholders and residents cannot meaningfully comment on environmental impacts without access to the final HRA evidence, particularly where air quality is a known constraint in Medway

SEA Regulations require the SA to assess “reasonable alternatives” in the same level of detail as the preferred option. Evidence shows that alternatives — such as reduced housing numbers, different spatial distributions, or prioritising brownfield — were not assessed on equal terms.