Medway Local Plan (Regulation 18, 2023)

The Consultation states:
“The plan’s vision is to establish Medway as a leading regional city, connected to its surrounding coast and countryside; with a thriving economy, where residents enjoy a good quality of life and there is a clear strategy for addressing climate change and strengthening natural assets.”

A fundamental part of the overall Vision for Medway should be a positive and proactive approach to support new development.

It is acknowledged that the Vision for Medway has been established through the recognition that there are marked differences in health and wellbeing across communities in Medway. The Vision places people at the centre of the Plan, and places importance on Medway being a healthy place to live, including high quality, well designed housing. Essential to this is providing for the diverse communities by taking into account the needs of different sectors of the community.

Our client supports the Vision and wishes to reiterate the important contribution that the future development of the Site can make toward achieving this.

In relation to housing delivery, our client supports the vision for ‘providing for healthier and more sustainable choices of homes’. However, we believe the Vision should go further, and proactively encourage and support the delivery of housing based on meeting the existing and projected needs as a minimum. We also believe that the Vision should be clear in the priority being for housing to be located within the existing urban areas, with specific concentration on making effective use of land. The Vision should be clear in the importance of giving substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, in accordance with the aims of the NPPF .

The Vision identifies the importance of the urban waterfront and states that there should be continuous paths with attractive and healthy connections, and the development of the Site can assist in achieving this aim.

The Site intends to provide a mixed-use scheme which will allow for daily needs to be met within the development, in line with the aims of the Vision.

The overall Vision will also need to be reflected in both the strategic and detailed development management policies of the future Local Plan, as it progresses.

The Consultation states:
“The plan’s vision is to establish Medway as a leading regional city, connected to its surrounding coast and countryside; with a thriving economy, where residents enjoy a good quality of life and there is a clear strategy for addressing climate change and strengthening natural assets.”

A fundamental part of the overall Vision for Medway should be a positive and proactive approach to support new development.

It is acknowledged that the Vision for Medway has been established through the recognition that there are marked differences in health and wellbeing across communities in Medway. The Vision places people at the centre of the Plan, and places importance on Medway being a healthy place to live, including high quality, well designed housing. Essential to this is providing for the diverse communities by taking into account the needs of different sectors of the community.

Our client supports the Vision and wishes to reiterate the important contribution that the future development of the Site can make toward achieving this.

In relation to housing delivery, our client supports the vision for ‘providing for healthier and more sustainable choices of homes’. However, we believe the Vision should go further, and proactively encourage and support the delivery of housing based on meeting the existing and projected needs as a minimum. We also believe that the Vision should be clear in the priority being for housing to be located within the existing urban areas, with specific concentration on making effective use of land. The Vision should be clear in the importance of giving substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, in accordance with the aims of the NPPF .

The Vision identifies the importance of the urban waterfront and states that there should be continuous paths with attractive and healthy connections, and the development of the Site can assist in achieving this aim.

The Site intends to provide a mixed-use scheme which will allow for daily needs to be met within the development, in line with the aims of the Vision.

The overall Vision will also need to be reflected in both the strategic and detailed development management policies of the future Local Plan, as it progresses.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council

Our client supports the objective to provide for the housing needs of Medway’s communities. Although it is acknowledged that the level of detail established at this stage in the Local Plan preparation is limited and will be progressed in further detail as the Plan progresses. The sizes, types and tenures of the proposed housing at the Site will be informed by the housing need demonstrated within the Local Plan.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as detailed in our letter of representations submitted to the Council.

Our client supports the objective to secure a range of accessible services for local communities close to where they live. This objective provides for sustainable communities with sufficient access to services, in accordance with the NPPF.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

In relation to the regeneration of Medway, the plan process should include review of the key areas of regeneration and specifically consider how the wider transformation of the waterfront will be supported throughout the plan period. There should be flexibility within the policy approach to allow for mixed-use developments to ensure that there are sustainable communities within the areas of regeneration.

Whilst our client generally supports the overall Strategic Objectives it will be important to ensure that detailed policies under the subsequent chapters are formulated appropriately, in order to support their delivery.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

We acknowledge that there is current uncertainty regarding the Standard Method formula and we acknowledge that the Council has submitted these concerns about the standard method to Government. However, we request that as the Local Plan progresses that the LPA consider the outcome of this response once published and consult with the public and stakeholders such as our client, to ensure that the appropriate approach is undertaken in terms of determining the scale of housing needed over the plan period.

It will however be important that housing provision is set as a minimum target in the future Local Plan.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

Our client supports the general approach to growth, albeit considers that there is potential for additional growth in Urban Regeneration areas, including the potential for the Site to make a greater contribution towards housing provision than set out in the Land Availability Assessment 2023.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

These comments relate to points 5.18-5.21.

Our client specifically supports the inclusion of the Site within the overview of potential sites for ‘Urban Regeneration’ and request that this be taken forward as an allocation in the future Local Plan.

Our client supports the Council’s starting point of regeneration and making the best use of vacant or underutilised brownfield land in accordance with the NPPF. The proposed development of the Site would fully meet this objective.

The Land Availability Assessment (‘LAA’) Interim Report was published in September 2023. The Site was identified within the LAA as Site ID GN6: ‘Gillingham No. 3 and 4’. The LAA provides details of the existing site and proposed development. It recognises that the Site is categorised as ‘Brownfield – previously developed land’.

Since the previous Call for Sites exercise, our client has progressed the initial concept proposals to establish an approximate mix of uses on Site. Following further review of the development potential, in terms of uses and capacity of the site, our client considers that the Site has the potential to deliver the following:

- Approximately 500+ homes, subject to further detailed assessment;
- Potential for an assisted living / care home and / or purpose built student accommodation (‘PBSA’);
- Commercial uses including a foodstore and a range of flexible commercial units; and
- Potential for the reprovision of a clubhouse for the Sailing Club.

Our client believes that the Site has the potential to achieve a greater number of homes than detailed within the LAA (2023), but fully recognises this subject to further work including discussions with Officers in relation to matters including technical, design, environmental and amenity considerations.

The design concept includes the potential for a proportion of the proposed homes to be dedicated to assisted living / care home purposes or PBSA. Our client would welcome discussions with the Council as further work on the potential development of the Site, including the proposed uses and number of homes, evolves.

Our client continues to support the inclusion of the Site within the LAA and further consultation documents and requests that the Site be formally allocated for future development for the range of uses as set out above, within the future Local Plan.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

It is currently unclear what the boundaries of the ‘central urban areas’ are. As the Local Plan progresses, we request that these areas are identified and consulted on. However, we support the recognition that the underused and vacant sites have the potential for higher density development and our client fully intends to continue work collaboratively with the Council to establish an appropriate density for the Site.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.

Our client supports the principle of locating development in sustainable locations which are well-served or could be well-served by public transport. The Site is well-served by existing bus stops directly adjacent which provide good transport links for potential future residents.

References to ‘the Site’ mean Site Ref: GN6 (Gillingham No.3 and 4) identified in the Land Availability Assessment 2023 and as fully detailed in our letter of representations submitted to the Council.