Medway Local Plan (Regulation 18, 2023)

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Comment

Medway Local Plan (Regulation 18, 2023)

The plan's vision is to

Representation ID: 1720

Received: 31/10/2023

Respondent: Mr Martin Rose

Representation Summary:

Topic areas to my response:
Sporadic, uncoordinated development in recent years
Transport and land use policy
Recognising the value of our (scarce) land - and the strong position Medway Council is in with developers
Making more Efficient use of land
Biodiversity and agriculture

Full text:

Sporadic, uncoordinated development in recent years
In this example I will refer to Rainham but it could be applicable elsewhere in the Medway area. Parts of the Rainham North ward, around Otterham Quay Lane and Lower Rainham Road have seen significant amounts of new housing development over the past five years. Building new homes for people who need them is not necessarily a bad thing, but the new housing does not appear to have included accompanying social infrastructure, principally: primary school places, expansion of GP services, local shopping and bus services. Worst of all, there appears to be no new footpath provision.
A very good example of this is the Bloomfields estate on the northern end of Station Road, Rainham. Station Road had suffered from narrow footpaths for a very long time. When the field on the north east of the road was developed into Bloomfields there was a fantastic opportunity to devote more space to pedestrian movement, and yet somehow the old narrow, not fit-for-purpose footways were retained. It was unfathomable why the Council didn’t seek such a simple measure, which would have only taken a few inches off the front gardens of some new houses, everyone lost out as the road remains an unpleasant walking environment, further encouraging local trips by car.
Transport and land use policy –
Facilitating “15 Minute Neighbourhoods” (or equivalent)
New development should aim to fulfil the ambition of the 15 Minute Neighbourhood (15MN) – another name may be more appropriate, in view of the misinformation surrounding the concept online. Places like Twydall, Park Wood and Walderslade although remote from their town centres, exhibit some characteristics of 15MN – key social infrastructure is available for most people in these areas within a 15 min walk of their front door. However, the availability of decent roads, parking and low residential densities contributing to poor public transport provision means that sadly, many do still choose to drive.
Cycle infrastructure
The Council and developers should build more pedestrian and cycling infrastructure: off-road cycle lanes, cycle parking and safe road crossings in the new developments and into the existing road layouts to encourage sustainable travel behaviour, particularly as new residents offer a chance for new habits to be created.
Severance
The road network can be a hostile environment to pedestrians and cyclists, with examples near Bowater roundabout, or Dock Road and the Northern Link Road around the Universities. The severance these roads cause must surely reduce local quality of life and economically discourage creation of secondary facilities, e.g. catering and entertainment facilities to serve the student market in Chatham Maritime.


Poor public transport
The poor state of public transport is recognised in the consultation document and there are many issues which can be resolved outside of the Local Plan to improve the frequency and speed of bus services. However, services will only improve significantly with policies to increase density of development to increase demand and reduce competition for road space.

Recognising the value of our land
Medway has lots to offer, its potential as a place to live and invest is massively overlooked as a result partly of its urban grain and polycentric settlements. However the Council needs to be a much stronger force in encouraging and insisting upon greater levels of sustainability in new development.
s.106 / tariffs
Across the South East of England currently there is relatively little space to build new housing. Medway and other parts of North Kent are considered to have some capacity available, although less than before – as seen in local house prices rapidly climbing towards the regional average.
Medway Council should recognise the value the area has to the development sector – it seems that the Planning department doesn’t recognise its negotiating position, possibly due to weak support from politicians during the era of Conservative control. With new leadership, whilst recognising commercial viability, the Council should be increasing the level of s.106 and any other levies available from developers and pursuing them for every last penny of it.

An imaginative approach to design and urbanism
St Mary’s Island – although benefitting from scale and public subsidy, the success of St Mary’s Island as a good example of place-making, with an emphasis on pedestrians and cyclists, and decent design should not be overlooked. I hope the Council can use SMI as an example to learn from on the Hoo Peninsula if land is released there for development.

Effects on existing communities
Moreover, recognition is needed of the impact of development on existing communities of the construction of new development – to use another example from Rainham North, Lower Rainham Road has been subject to numerous closures over recent months, increasing congestion elsewhere in the town and adding to journey times for local people. Development offers existing communities nothing in exchange – the development of new social infrastructure (whilst designated a mitigation, may often be perceived as an improvement) may help soften the impact of new housing. There is no evidence of such schemes in Rainham North. In fact, the children’s play area on the housing estate on Station Road includes a large sign informing non-residents that they are not allowed to make use of it. Further evidence that without a robust planning authority comprising strong political leadership, technical expertise and well-formed policy, developers are allowed to ride roughshod over existing residents of an area.
Neighbouring districts
Quality of life in Medway is at risk from the urban fringe being developed by neighbouring local authorities e.g. Lidsing / Bredhurst (Maidstone BC) and Rainham North (Swale). These plans should be challenged at all costs, and Medway’s own planning should not facilitate these potentially disastrous plans – particularly Lidsing. Developing parts of the Capstone Valley would only fuel that dreadful idea of a new ‘village’ near the M2.

Efficient use of land:
Town centre viability
To arrest the decline of the high street, I propose seeking to make the designated zones for retail in Chatham and Gillingham smaller than they are at present. In doing so, the remaining space will fill more vibrant and welcoming to sceptical local residents who currently have the means to stay away and use other facilities. I have set out a rationale below.
I would suggest 40-50% of the space was released for other activities, e.g. Gillingham High Street west of Canterbury Street and Chatham High Street east of Batchelor Street (but also releasing the old Debenhams / Alders site). The space released could be converted to decent family housing with parks, play areas and schools. Size, massing and scale of Rochester Riverside, especially if the old Tesco and bingo hall were included in the scheme, along with a re-alignment of Brook Street.
Chatham and Gillingham’s high streets are too long for the purposes they currently serve and are in a spiral of decline. Vacancy levels and general degradation mask the usefulness of these local assets, and deter those with disposable income to spend money and time in those centres, instead preferring out of town outlets or online shopping.
Also, there seems to be a surplus of car park land in both town centres, can more be released for development?
There has been a massive reduction in demand for some high street shopping facilities with a transfer to online or out-of-town facilities. In terms of these trends, previous planning decisions by the Council to allow the growth of sites such as Horsted Retail Park and Dockside, and local online distribution centres have hastened the decline of the traditional high street. Further development decisions on out-of-town or online retail should recognise the harm their approval would have on traditional urban centres.
Medway suffers from the polycentric nature of the settlement. Compare the quality and massing of Reading or Brighton centres (both serving similar populations to Medway) – part of their success is due to the presence of a single dominant centre, where core comparison retail functions have been consolidated. With this in mind, thinking more radically, could Gillingham town centre be scaled back even more significantly, replaced by housing, with functions relocated to Chatham, along with some relocated functions from out-of-town activities?
On the other hand, I’d suggest Rainham, Strood and Hempstead Valley are useful assets, public transport, walking and cycling connections to these locations should be prioritised.

Better use of low density suburbs
Much of Medway’s outer areas are low density and difficult to serve with public transport. More consideration should be given to the scope to assemble land from private gardens (subject of course to availability of land and local approval) to develop more intensive housing in such areas. However, any intensification of suburban areas needs to be combined with improved public transport links.

Biodiversity and agriculture
Some of the land around Medway is extremely rich fertile farmland, if lost then it would be hugely regrettable for our food security and preservation of Kent’s remaining agricultural heritage. Agri-businesses looking to make high profits from selling farmland should be warned this is not possible, with a robust local plan and clear zoning.
Similarly the biodiversity of small sites should not be overlooked. Fields which appear scrubby and unproductive may include numerous florae and faunae not seen elsewhere. Careful investigation should be undertaken of this sites and developers forced to fulfil their obligations over biodiversity net gain.

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