Medway Local Plan (Regulation 18, 2023)

Edge of settlement sites, including Bloors Farm, could be delivered quickly and early-on in the plan period because it is not subject to the constraints often seen on brownfield sites. On this basis, we support the intentions of paragraph 5.30.

Map 2 is supported- The suburban expansion areas provide an important and clear approach to the spatial location of where 9,680 could be delivered on the edge of the existing built-up area of Medway.

The Bloors Farm site allocation would fall in the suburban expansion site spatial location to the north of Rainham. This site is not subject to national constraints and is not in the Green Belt. We consider that development on this edge of this settlement site
would provide a positive and important contribution to the delivery of housing numbers in this part of Medway.

It is noted in paragraph 5.15 that the LAA have identified land with the potential capacity
for c 38,200 homes. These sites will be taken forward to the next stage of detailed site
assessment. It is important that these sites are not discounted early-on before any final
housing numbers are decided.

We wish to raise an objection to this approach advocated by paragraph 5.13 because the acknowledged uncertainty in the number of housing numbers required to be delivered, means that a more cautious approach, by allocating more sites should be taken.

The Council should be looking at allocating more sites, to meet a potential increased capacity, in the Local Plan to ensure that there is an appropriate buffer should there be an additional requirement for housing in the Medway area, rather than relying heavily on
delivering the target number of 28,500 homes.

Paragraph 66 of the NPPF clearly sets out that 66. Strategic policy-making authorities should establish a ‘housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within
neighbouring areas) can be met over the plan period’.

On this basis, the client advocates that the Council looks for a larger number of sites to ensure that there are enough sites to meet the housing requirement and include the buffer.

The level of housing need required for the Medway area identifies a requirement for 1,667 homes a year in Medway, which provides a total figure of around 28,500 homes to be delivered before the end of 2040. This figure could further be increased, as it is
identified in paragraph 5.11 that Medway are currently considering a request from Gravesham Borough Council to increase capacity by 2000 homes to help meet the housing need of their district.

In March 2023 Gravesham Borough Council produced its Five Year Housing Land Supply Statement, covering the period 2022-2027. This document sets out that Gravesham only has 2.9 years of deliverable housing supply. In accordance with the Gravesham Local Development Scheme (January 2023) the new Local Plan for Gravesham is not expected until December 2024, and thus, the Borough’s Housing Land Supply (HLS) is not likely to improve in the near future. The high likelihood of Medway having to absorb some of this housing need should not be ignored in the early stages of Local Plan creation for Medway.

It is understood that Medway Council are still establishing final numbers, due to the Council raising concerns with the Government derived figures, and the basis and calculations on which final numbers are determined. However, it is made clear in paragraph 5.13 that the Council will look to find potential site allocations enough to provide for 19,000 dwelling units, the additional 7500 sites being provided through extant supply.

Our client supports the objective of contributing to building a strong, responsive and competitive economy. Specifically, supporting the bullet point that boost the performance of the local economy by supporting local businesses to grow and innovate; and attracting
inward investment and re-locations, through the provision of a portfolio of good quality employment land that meets the needs of businesses; and to secure and extend higher value employment opportunities; and reduce out-commuting.

However, we consider that there are some objectives that need to be tightened to ensure that the overall vision for Medway is not being limited.

In a response to the Development Options consultation, provided in April 2017. It was set out that Medway’s economy is lagging behind the county and national averages, with productivity running at two thirds of the national level, whilst productivity in terms of GVA is the lowest in the South-East region (despite being the largest city in Kent and one of the largest in the South East). We therefore, wish to re-affirm our previous comments:
“We therefore believe it is imperative that the Council reflects, in its Local Plan, the intention to be supportive of those businesses that are able to maintain and contribute to the growth of GVA. Especially where, in the case of AC Goatham and Son and its
growing partners, current annual GVA of the business is £13.75 million. Our client
therefore supports the vision that the Local Plan priorities should (as set out at paragraph
2.12) “boost economic performance through supporting local businesses and attracting
inward investment”.
Furthermore, the Kent and Medway Growth Deal 2014 recognises that to unlock economic potential “backing business expansion through better access to finance and support” should be taken forward in the Local Plan. It is currently not included in the
wording of the strategic economic objective and this is considered an omission.
This representation promotes Bloors Farm which is a large site that has the potential to deliver a mixed-use scheme. On this basis, jobs could be created through the provision of development of this site. This statement considers that there is an omission in the
overarching objective which supports a competitive economy as at fails to mention the construction industry as an important an influential model for delivering growth and supporting a competitive economy in the local area.

Further to this, the provision of a large residential scheme will enable the provision of jobs through the construction of dwellings and associated infrastructure.

The ‘Plan for Growth’ published by HM Treasury in March 2011 recognises that a successful construction industry is vital for sustainable growth in the UK and sets out that this includes the construction and maintenance of homes.
It notes that providing new homes in the right places is vital for future economic competitiveness.

Section 8 of the NPPF provides guidance on ‘Promoting Healthy and Safe Communities’. The proposed objective in the Medway Local Plan actively meets this objective and is therefore supported. But, respectfully it is considered that there is an omission in how
the objective is drafted.

The intentions of the third bullet point, proposes to strengthen the role of Medway's urban, neighbourhood and village centres…” This position is supported, but it is considered that ‘urban and rural extensions’ should also be included in this objective,
especially, as the inclusion of urban and rural extensions are included within the proposed spatial strategy for delivering growth.

Previous representations have been submitted on behalf of our client that promote the use of suburban expansion to deliver growth, especially on the edge of Rainham. It is considered that the provision of these extensions will help to develop and strengthen
transport networks and safe and sustainable travel as advocated elsewhere through the plan.

Bloors Farm continues to be available and achievable and would provide an alternative option for edge of settlement development.

The second bullet point, which references promoting healthy eating and physical exercise, is supported. Whilst it is set out that planning can help contribute to healthier food environments by managing the availability of fast-food outlets, acknowledgment
should be given to supporting the industries/businesses that are responsible for the delivery of healthy produce, especially, as is the case with AC Goatham and Son, where they are growing fruit and managing the landscape

The Medway Land Availability Assessment (LAA) was published on the 16th October 2023.

As set out in paragraph 3.1.6 of the Land Availability Assessment (LAA) “Medway Council would welcome information to confirm the availability of the 109 sites, otherwise such sites may not be phased for delivery in the first five years of the plan period”.

We are working on behalf of AC Goatham & Son, the owners of the site known as Bloors Farm. This site has been given the reference number RN9 in the LAA.

During the Stage 1: Identification of Sites and Initial Survey, the assessment into site RN9 concludes that it should proceed to Stage 2. It is however, included in the summary map of sites with unknown availability (Appendix F).

This representation seeks to continue the promotion of the site known as Bloors Farm and it is confirmed that it could be delivered in the first 5 years of the Local Plan period. However, for the purposes of confirming land availability Pump and Bloors Farm are available now.

Bloors Farm is circa 27.32 hectare and was submitted under the name "Land between Pump Lane & Bloors Lane, Rainham". This representation confirms that the site continues to be promoted primarily for a housing-led development scheme. The strategic location and size of the site provides the opportunity for the delivery of a major mixed-use scheme, which could be developed in isolation or more strategically with neighbouring sites, namely Pump Farm.

The LPA is now reconsidering the suitability of Bloors Farm, as it is included in the general suburban land approach advocated in the general suburban extension model advocated in Map 2 of the consultation 'Map 2 - overview of potential sites for Suburban Expansion'. An approach that is actively supported through these comments.

AC Goatham & Son confirms that this site will become surplus to requirement as orchards during the Local Plan period, which extends to 2040. It is expected over the coming years that some of the periphery orchards, Bloors Farm being one, will no longer form the main basis of their business model as the intention is to draw in operations closest to their headquarters and consolidate outlying interests. This meets the aspirations of NPPF paragraph 83, which advocates that 'planning policies and decisions should recognise and address the specific locational requirements of different sectors'.

The use of Bloors Farm with its intensive fruit farming operation has attracted significant residential complaints in recent years. Furthermore, the impending requirements for investment in replanting in the coming years will make the ongoing use of the site as an orchard unviable. The need for these sites to remain as agricultural land has been confirmed as having diminished significantly as to effectively extinguish what was formerly identified need.

The landowners are therefore releasing Bloors Farm, along with the neighbouring farm, Pump Farm, during the Local Plan process from their business portfolio of operational orchards.

1.1. We are writing on behalf of our client, AC Goatham and Son, in respect of the Medway Council’s Local Plan – Regulation 18 Consultation Report-Setting the Direction for Medway 2040.

1.2. This representation promotes a site extending to approximately 13.8 hectares on the northern side of the Peninsula Way, Hoo St Werburgh, Rochester, ME3 6QE, west of the Deansgate leisure centre and east of Homeleigh Nursery.

1.3. Historically, the site has been given the reference SO2 as part of the 2018 Local Plan Development Plan Considerations in which it was identified by the Council as “A site with opportunity for development subject to availability”. The site is and will remain available.

1.4. In 2019, the site was further considered as part of the Medway Strategic Land Availability Assessment (SLAA) 2019 when part of the site (the southern part which was then the only part promoted) was identified as “Suitable, Available and Achievable”.

1.5. In 2020 Medway Council released the Planning for Growth on the Hoo Peninsula document. This, together with land to the north of the site, identified the site’s potential as part of an opportunity area of incidental growth around “Indicative Neighbourhood centres”. The extent of this was shown on the “Opportunities” map.

1.6. The site formed part of a pre-application submission (PRE/20/2978) presented to Medway Council in early 2021 and that then proposed that the southern part of the site form a business hub. The Council’s pre-application response, dated 21st April 2021 confirmed that an employment/business could be included within the wider strategic growth plans for the Hoo Peninsula and that “this area of Goatham’s land would be an ideal location for such a development given its proximity to the transport network and vehicular connectivity”.

1.7. The site, which is owned by AC Goatham and Son provides an opportunity to provide a development site in the Hoo Peninsula rural development area. This site could contribute to the Council's substantial housing requirements within the district, especially when joined with the neighbouring sites and identified as part of the plan.

1.8. It is considered that the site provides an opportunity for additional housing and or mixed development, and hence, positive growth in the Medway area to 2040.

1.9. This representation responds to the current Regulation 18, by setting out how the site meets the aspirations and broad spatial strategy being promoted in the Local Plan, specifically in the rural area. In addition to responding to each of the headings in the consultation document, and identifying how the site can deliver the vision and objectives through sustainable development.

2. Context
2.1. The production of the Medway Local Plan has involved several key stages. Three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final Regulation 18 consultation before the publishing of the Regulation 19 draft plan.

2.2. The current consultation period considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

2.3. It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development, but does relay key areas where development could come forward.

2.4. This representation seeks to promote a 13.8 hectare site on the northern side of the Peninsula Way / Ratcliffe Highway, Hoo St Werburgh, Rochester, ME3 6QE, the extent of which can be seen at Figure 1 below and on the attached Site Location Plan.

2.5. This site has previously been promoted for development through the 2008 Call for Sites and more recently the 2023 Call for Sites exercise undertaken by Medway Council, the Local Planning Authority (LPA).

2.6. The recently published interim Land Availability Assessment for Medway (September 2023) does include an assessment of the site, with site reference HHH19. This document recognizes the site does not comprise “Habitats Sites”, Irreplaceable habitat” and is not an “Area at risk of flooding”. It is on this basis that the site is recognized as capable of delivering 5 or more dwellings, or economic development of over 0.25 ha and which is recommended to proceed to Stage 2.

2.7. The strategic location and size of the site provides the opportunity for the delivery of a residential scheme with potential economic development which could be developed in isolation or more strategically with the neighbouring sites.

3. Site description and history
3.1. The site is well located next to existing and proposed development in a sustainable location. The proximity of a proposed pedestrian crossing to the south further supports good connections to existing and proposed bus links, pedestrian and cycle paths, which will all link well with Hoo St Werburgh.

3.2. Allocation of the submission site would form part of the “Deangate Ridge” allocation set out within the Ho Development Framework (HDF) document, recognised as forming part of a “Vibrant and Sustainable” neighbourhood. This allocation therefore supports a logical extension of the framework area.

3.3. Historic ecological assessments that have been undertaken across the site which indicate there is no likely impact as a result of the proposal. Further investigation would be carried out as development proposals for the site progress. In accordance with emerging statutory requirements, development would also provide opportunities to achieve 10% Biodiversity Net Gain in order to provide a clear and tangible ecological enhancement over the existing baseline condition of the site. In this case, given the blue and green infrastructure opportunities identified by the Council in the immediate locality through the HDF document, it is perceived that development on this site could well exceed this.

3.4. Allocation of the site for residential development would be consistent with the objectives of the NPPF which seek to support sustainable development in accordance with the environmental, economic and social objectives. Development would make a significant contribution to each of these as set out at Paragraph 8 of the NPPF.

3.5. There are no known constraints that would prevent development of the site, and further detailed assessments would be provided to accompany any future planning application to address any perceived site-specific issues.

4. Deliverability
4.1. Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.

4.2. The Glossary of the NPPF defines deliverable and developable as following:
“Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
“Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.

Availability
4.3. AC Goatham, who own the site, have confirmed that the site is available. On this basis, and subject to its inclusion in the Local Plan, the site can become available in the first 5 years of the Local Plan period.
Suitability for Residential Development

4.4. The site is located on the main Ratcliffe Highway route, which directly accesses the Peninsula Way between the settlements of Hoo and Chattenden. It is served by good public transport services and a wide range of services/facilities. There are no perceived constraints that could not be overcome to facilitate residential development.

4.5. The site would be suitable for housing development, as a highly sustainable and logical extension to the settlement of Hoo and immediately adjacent to the Deansgate leisure centre. If the site were to come forward for a mixed residential / economic development, it could also sit comfortably with the adjoining existing and proposed site uses.

4.6. The site would form a positive approach to housing delivery in Medway. At an average 30 dwelling per hectares, often advocated in rural areas, the site could have an indicative capacity of up to 415 units; and depending on any possible allocation for economic and or retail purposes.

Achievability
4.7. Subject to the grant of necessary planning permission, the site is realistically capable of delivering development in the early phases of the Plan period. Development viability will be assessed by taking into account the affordable housing requirements, other obligations and market conditions at the time when development proposals are promoted through the planning application process. At this stage, there is no indication to suggest that there will be any viability issues for housing development on this site.

The NPPF (paragraph 20), sets out that strategic policies should ‘set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for [amongst others]:
a) housing (including affordable housing), employment, retail, leisure and other commercial development’;

Furthermore, the National Planning Policy Framework (‘NPPF’) requires that in order to boost housing supply, local planning authorities (‘LPAs’) should identify a supply of specific deliverable sites sufficient to provide 5-years’ worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of housing.

The consultation report highlights in paragraph 5.4 that “It has to be recognised that there is a housing crisis, particularly regarding affordability and there is an absolute need to provide the right homes in the right places to meet Medway’s growing needs and the requirements for those desperately needing a good quality home”. It goes on to acknowledge that many existing residents are living in over-crowded and / or sub-standard housing conditions.

It is important that the protection of the intrinsic character and qualities of a site or an area are considered, but these qualities can be protected when new housing development is delivered, through good design and by improving the sustainable networks and access to places and services. Rather than seen as negative, new housing development should be seen as an opportunity to improve the area for the current and future residents delivering the types and quantity of homes that are desperately needed. On this basis, respectfully, reference to ‘housing delivery’ should be made in the vision.

It is submitted that the development of the site, either delivered in solo or in conjunction with the adjoining proposed development sites could form a housing-led scheme which could be an option to deliver not only the existing elements of the vision for Medway, but could also deliver important housing numbers in the Medway area early-on the plan period. The site is both available and the development of the site is achievable.