Medway Local Plan (Regulation 18, 2023)

The NPPF states that the Government attaches great importance to the Green Belt and its fundamental aim is to prevent urban sprawl by keeping land permanently open. Whilst the Green Belt is not an environmental designation, it is a strategic planning tool which was introduced to manage the growth of urban areas. It is therefore wholly appropriate to revisit Green Belt boundaries when development requirements justify this.
Richborough do not consider it necessary for an authority such as Medway, with only 5% of its land as Green Belt, to propose the removal of Breen Belt parcels for residential development as exceptional circumstances are unlikely to be demonstrated. While Medway is also constrained by ecological designations, the Green Belt in Medway plays an important role in maintaining the strategic gap between local settlements, including Strood and Higham, Cuxton and Meopham and Snodland and Rochester.
The possible cross authority development sites and emerging allocations on the boundary of Medway are coming forward in the context of Gravesham, Maidstone and Tonbridge and Malling being heavily constrained by Green Belt. The Green Belt sites in Medway, as referenced in the Consultation Document, also include significant swathes of the Kent Downs AONB. These designations are afforded national policy protection, and the loss of these sites are to be avoided wherever possible. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty which have the highest status of protection in relation to these issues…”
There is sufficient land outside the Green Belt in Medway, brownfield and greenfield land, to meet housing needs. Richborough do not consider the possibility of providing a cross authority development an exceptional circumstance to justify Green Belt loss when suitable sites, such as Site SR17, are available. Paragraph 141 of the NPPF confirms before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.

As previously referenced, the development of Site SR17 could include the provision of a new 30-minute circular bus route, thus linking the site to Wainscott, Chatham and Strood. Further improvements to cycle links, including connecting into the national cycle network are also being considered and could potentially be included within the Local Cycling and Walking Infrastructure Plan. National Cycle Network (NCN) Route 1 passes along the northeastern frontage of the site on Higham Road and Bunters Hill Road, providing a cycle connection to Higham Railway Station to the northwest of the site, which takes less than 15 minutes. There are fewer highway constraints associated with Site SR17 than a transformative scale of development at Hoo and the site can be delivered without external funding.
Site SR17 can also link more easily to the existing services and amenities to the south of the site at Wainscott and Strood. There is therefore less reliance on developer contributions or funding streams to deliver new amenities and services required to make development deliverable than is required at Hoo. Developer contributions from Site SR17 can contribute to the improvement of existing services and amenities.

The opportunities identified in respect of Rural Development appear to relate primarily to land on the periphery of the peninsula or around the settlement of Hoo. The assertion in respect of the ability of Hoo to deliver planned growth without the HIF funding programme will need to be fully evidenced and justified as the Local Plan preparation progresses.
Richborough contend that Hoo can accommodate a level of residential growth but any transformational change of this area of the Borough will be severely hampered by highway and accessibility constraints as well as the need to provide additional services and amenities. The existing highway capacity issues will need to be comprehensively addressed, including those at the Four Elms Roundabout, as part of any Local Plan that seeks to allocate a strategic level of growth at Hoo.
There is a high dependence on private vehicles for most residents on the Hoo Peninsula given its relative poor access to public transport and the capacity constraints of junctions on the existing nearby road network. Future evidence base documents will need to clearly demonstrate how these constraints are to be overcome.
There are a handful of Rural Development sites that are less constrained by existing highway issues given their location closer to Wainscott and Strood. The Site promoted by Richborough is included in this tranche of sites and is also located close to the existing services and amenities of Wainscott, south of the A289. While the categorisation of sites in the Consultation Document does not comprise a spatial strategy for the distribution of growth, Richborough would question how the categorisation has been made. It can be argued, based on the Opportunities presented in the Consultation Document, that the SR17 Site is more closely aligned to the matters of relevance to the Suburban Development sites, rather than the highway focussed Rural Development site matters.
Richborough welcome further consultation with Medway Council and the Local Highway Authority on the access strategy for Site SR17, although a technical assessment of the local highway network has shown that the development of the Site for 800 dwellings can be safely accommodated within the highway network with the primary point of access being from Lower Rochester Road. The Emerging Concept Plan provided within the submitted Vision Document indicates a proposed new roundabout on this stretch of road. The Vision Document also refers to improvements to the Four Elms Roundabout, including an integrated left turn lane to ease congestion at this key pinch point. This work was originally due to be funded by HIF but is now proposed to be funded and provided by promoters of SR17, which is a major benefit of the proposals.
Richborough are aware of wider highway improvement schemes under consideration (some of which were reliant on the former HIF funding programme) and considers junction improvements proposed as part of proposed development at Site SR17 will help realise the aim of reducing congestion levels at Four Elms Roundabout and increasing capacity towards the Hoo peninsula.

There is reference to the large extent of Best and Most Versatile land for agriculture. Given the level of housing need across the Borough, including the potential to plan for 2,000 homes from Gravesham’s need, Richborough is of the view that there will be a need to allow some loss of BMV land to meet the housing needs in full.

Richborough are promoting a Rural Development Site for a mixed use residential-led development of around 800-900 dwellings, a local centre and new primary school. The Site is Land off Lower Rochester Road and has been given the Site Reference SR17 in the Land Availability Assessment (LAA). The Site is shown on Map 3 – overview of potential sites for Rural Development. However, it should be noted that the Stage 1 Land Availability Assessment proforma for Site SR17 classifies it in the ‘Suburban’ Group.
Richborough submitted the site to Medway Council as part of the Call for Sites consultation in 2023, and included a Vision Document with the submission which presented a technical assessment of the site, a review of constraints and opportunities and also an Emerging Concept Plan.
The Site comprises approximately 48.3ha of land to the north of Wainscott and predominantly comprises agricultural land. Blacklands Farm lies in the south eastern corner with a residential dwelling and six farm buildings. There are Polytunnel structures situated in the eastern extent of the Site. Agricultural buildings and hardstanding associated with Sole Street Farm lie within the south western corner of the Site.
The Site is bound to the:
• North west entirely by Dillywood Lane
• North east and east by Higham Road/ Bunters Hill Road and rear gardens of properties along Higham Road
• South by the A289 Hasted Road, residential properties and a tree belt
• West by the B2000 Lower Rochester Road, residential properties (Springfield Cottages) and agricultural land
Beyond the A289 Hasted Road to the south is the settlement of Wainscott, whilst to the north, east and west is agricultural land with scattered residential dwellings and farms. The Site lies close to the boundary with Gravesham Borough Council. The boundary with Gravesham also forms the Green Belt boundary to the north, with a small section of Green Belt within the Medway Council authority area, to the west of the Site.
There are existing amenities and services nearby which can be reached on foot, bike or public transport, although the scale of the proposed development ensures the Site is relatively self-sufficient with provision made for a local centre and school.
The Site is also located close to existing public transport links to Wainscott, Chatham and Strood, although there is an opportunity to introduce a bus service through the development; this will most likely take the form of a circular service connecting the Site with Wainscott, Strood Railway Station and Strood Town Centre, with a 30-minute frequency considered to be viable.
There are two railway stations close to the site, Higham and Strood, both stations have regular services to London St Pancras, Luton Airport, Gravesend, Ebbsfleet Maidstone and Chatham. The Site is clearly sustainably located.
The Consultation Document highlights that much of the Hoo peninsula is the subject of statutory designations and highlights its national importance in respect of ecology. The Site promoted by Richborough is not affected by any statutory ecological designations such as SSSI’s, SPA’s or Ramsar sites.

The image provided at Map 2, titled “overview of potential sites for Suburban Expansion” shows that the identified sites are located in the south east and southern parts of the Borough. Paragraph 5.35 identifies that:
“Land in this area lies close to Medway's boundary with neighbouring authorities, particularly Swale and Maidstone. Development in these locations would potentially have a cross-border impact. Development to the east of Rainham would erode the strategic gap between Rainham and Newington and add further to the congestion and pollution issues on the A2. Development to the south around the Capstone Valley would potentially adjoin the development of the proposed 'Lidsing Garden Community' in Maidstone. The landowner is promoting a cross-border masterplan. There are a number of potential impacts, including transport, infrastructure and the natural environment.”
In respect of the transport impacts, Richborough consider that there are likely to be substantial issues with the proposal to locate significant expansion in the southern parts of the Borough, including the ‘Lidsing Garden Community'. Development south of the authority boundary will not count towards meeting the housing requirement for Medway, but the resulting traffic will significantly impact M2 Junction 4 and the M2 corridor around the south of the Borough. This will potentially limit the opportunities available for sites identified within Medway to deliver effective mitigation.

Richborough notes that there are concerns over the availability of amenities and services in existing towns and neighbourhoods in the southern and eastern suburban areas. It should be ensured that any emerging residential allocation can appropriately and viably mitigate for additional pressures on existing services, such as schools and doctors. The cost of providing new schools and doctors services is likely to require financial contributions from a significant number of residential developments; Richborough is of the view that the ability of the unconstrained land in the suburban area to generate sufficient funds for these required amenities should be assessed.

As previously referenced, the suburban areas to the south and east of the District are fairly heavily constrained by the Kent Downs AONB, as well as the ecological designations associated with the Medway Estuary (Special Protection Area, Ramsar Site and Site of Special Scientific Interest) and the Capstone and Riverside Country Parks. The ability to deliver significant levels of residential development sustainably alongside these important designations will need to be evidenced. Richborough is of the view that the second stage of the LAA will need to evidence how the residential development of each site can viably protect against the erosion of these features. Richborough is also of the view that Medway Council should look to develop a site selection methodology which prioritises sites which minimise impact on these key ecological designations.

Richborough supports the point that suburban residential development can provide opportunities to enhance sustainable travel options as well as provide for local services. Such development can viably sustain and justify financial contributions which significantly enhance walking and cycling connections to major services and/or public transport options. This could include improvements to be identified in the Local Cycling and Walking Infrastructure Plan.

Whilst Richborough agrees that residential development in urban areas presents opportunities for regeneration, the quantitative and qualitative needs for housing in Medway cannot be met only in these areas.
The PPG provides guidance (paragraph: 018 Reference ID: 3-018-20190722) on assessing the suitability of sites and highlights the following factors for consideration:
• appropriateness and likely market attractiveness for the type of development proposed;
• contribution to regeneration priority areas;
• environmental/amenity impacts experienced by would be occupiers and neighbouring areas.
Urban core developments are typically high density apartment-led schemes, which deliver smaller homes with limited private amenity space.
Table 6.1 of the Local Housing Needs Assessment (LHNA) (October 2021) provides the overall annual dwelling type and tenure mix recommendations and shows that 15-20% of new housing is recommended to be 1 bedroom flats and 20-25% 2 or more bedroom flats. While this shows that there is an identified need for smaller flatted development in Medway, the majority of the need remains for larger houses. These typologies clearly do not accord with town centre locations.
Paragraph 5.11 of the LHNA confirms that the expected housing choice for 65.3% of older households is to downsize. The stakeholder engagement summary provided at paragraph E9 suggests this is a desire to downsize to bungalows or small units in “community-based” developments. These identified needs do not necessarily align with significant urban area growth and would more likely be met through suburban development.
In respect of affordable housing need, Table C9 of the LHNA provides a comparison of existing affordable housing stock against annual need by bedroom numbers and it is clear that there is a particular shortfall of 4 or more bedroom affordable dwellings. Given the high density nature of residential developments in urban locations, due to land availability and viability pressures, it is unlikely that this shortfall in qualitative affordable housing need is going to be met in urban areas. Richborough is also concerned about the potential for such schemes to deliver any affordable housing at all given the possible viability issues. Further work is needed to be able to demonstrate that the affordable housing need can viably be met at both a Borough-wide level, but particularly on sites in the urban area. If affordable housing cannot viably be delivered in these areas, additional residential allocations will be required in more viable suburban or rural areas to ensure the Borough’s qualitative housing needs are met.
With regard to the delivery estimations for land in the urban area, such as Chatham Waterfront for example, there are inherent risks associated with relying on new residential markets to emerge in town centres in order to meet a Borough’s housing requirement. This approach places significant burden on these locations given the context of them not being established residential locations with appropriate services and amenities and being reliant on developers providing or contributing to new residential markets from a standing start. It would therefore be prudent for the emerging Local Plan to progress with conservative estimations on delivery in these unproven locations so that if delivery falls short this does not undermine the delivery of the Borough-wide housing requirement. It is for these reasons that Richborough has suggested applying a non-implementation discount to sites in the urban area. For instance, the Submission Version Local Plan for Dover District Council has included a 5% non-implementation discount on sites in certain areas within the housing trajectory.
The urban areas have acknowledged availability and viability challenges and an out of date Local Plan that has relied too much on residential development in this location has failed to address the market attractiveness of the claimed supply. Richborough are therefore promoting a mixed spatial strategy for residential development, with growth being appropriately spread across the Borough to urban, suburban and rural locations.