Medway Local Plan (Regulation 18, 2024)

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Form ID: 3385

Respondent: Ms Joceline Cook

The Council could consider setting local standards for development that go beyond national policy/regulations in addressing climate change. What evidence would justify this approach, and what standards would be appropriate?

1) Section 5.4 Policy DM6-Sustainable Design and Construction is mostly about water/energy efficiency and use of recycled materials. No mention is made of how any development is going to incorporate wildlife, e.g.bird boxes, insect hotels, ponds. For example some developers now build in swallow/swift/house-martin in-built nest boxes in new homes. Section 4.4.5 mentions a Bird Wise scheme which might provide partners that you can work with to obtain more answers to the questions above. The evidence that I think would justify this approach is that the scale of the development will really negatively impact climate change because the plan is to destroy prime bird habitat (and habitat for other wildlife) within 6km of the marshes on the Hoo Peninsula. The standards will be additional mitigation or infrastructure creation appropriate to whichever form of wildlife or habitat will be destroyed. And the developers should be legally obliged to build the required items onsite with no get-out and not cheaply either. 2) The Council could set the standard that local jobs and infrastructure are created first. The evidence for this approach is to be had from lessons learned from the recent housing estate developments at Hoo which haven't worked. It has resulted in awful not particularly environmentally sustainable urban sprawl with many people commuting to work off the peninsula wholly or partly by car resulting in negative impacts on the environment e.g. traffic congestion at Four Elms hill and poorer air quality. If you managed to create some local jobs, you'd then be in a position to adopt the appropriate infrastructure for the industry sector. 3) The Council could go for greater numbers of Self Builds and/or Custom Builds. I would prefer not to have the uninspiring housing estates currently being built everywhere. The Council could demand for the best sites (whatever that means) that the most beautiful innovative highest quality homes are built to the most environmentally sustainable standards possible.

Do you consider that the Council should seek to go beyond the statutory minimum of a 10% increase in BNG?

Yes

What evidence can you provide to support your view?

I think the Council is obliged to do everything it can because of the colossal impact on climate change and the natural environment that the scale of this proposed development will have. I think in the case of this development, the proposals are going to change the Hoo Peninsula in particular from a rural area into an urban area which is an exceptional circumstance.

Do you agree that the tariff based strategic approach applied to development within 6 km of the designated areas, supporting the delivery of the Bird Wise SAMMS programme represents an effective means of addressing the potential impact of recreational disturbance on the designated SPA and Ramsar habitats of the Thames, Medway and Swale Estuaries and Marshes.

Yes and no, as too much wildlife, farmland and other habitat will be destroyed for any mitigation or financial recompense so it's not really effective in that sense. No amount of money will reduce the environmental impacts that occur because of this habitat being destroyed. The only use for it is if it deters the development of this land.

Do you consider that Medway Council should identify landscapes of local value as an additional designation in the new Local Plan?

Yes

What should be the criteria for designation? Are there areas that you would identify as justifying a local valued landscape designation – where and why?

One of the criteria should be aesthetic, e.g.: Views across the Hoo Peninsula - I can only speak about those around Allhallows, others may exist. Some of the best views across to the Thames and Medway will be destroyed. There is one particular part where you can see both rivers from one point (the Coastguard cottage at Homewards Road junction with Ratcliffe Highway), and another from Binney Road where you can see the gas tanks at Grain and the River Medway and the fog rising in the morning across the fields. Both of these locations are proposed sites on the plan. In the document in 4.5.7, you say 'The European Landscape Convention recognises that every landscape forms the setting of the lives of local people and the quality of those landscapes can affect everyone's lives'. The views, the space and the sense of remoteness is probably why many people choose to live there more so than the homes themselves. The analysis 'D.5.7 - Views experienced by local residents' in the Lepus Consultancy document classified it only as a minor negative impact but it is most certainly major for me and my mental health and will fuel the decision of whether I continue to live in Medway or not. I believe that the Medway LDP greatly underestimates this factor. The views on the Hoo Peninsula are as important to preserve as much as in the Kent Downs AONB because they are of equal value - they are as fabulous. I'm sure there are other particular features of landscapes that should be included as well, possibly similar criteria as for an AONB, but I'm not an expert.

Do you agree that the Council should promote Natural England’s Green Infrastructure Framework standards in the Medway Local Plan policy?

Yes. I think the scale of this development will be so catastrophic for the natural environment, the Council needs to do everything it can. I read some of the Appendices written by Lepus Consulting and was horrified at the amount of woodland that would need to be felled and open mosaic habitat etc that is going to be lost on multiple proposed sites. The most important thing is to lobby for changes to the planning system so that developers do not renege on their commitments to providing mitigation measures. I'm not an expert in this field and have no knowledge of the detail of Natural England's Green Infrastructure Framework but have heard stories locally where it was promised that they would build cycle parks or play parks but never did and there appears to be very little accountability on the part of developers.

Has the draft Medway Green and Blue Infrastructure Framework identified the correct key issues and assets, and provide effective guidance for strengthening Medway’s green infrastructure?

No answer given

Do you consider the Green Belt boundary should be revised in line with the recommendations in the 2018 Green Belt Assessment?

No answer given

Do you consider that exceptional circumstances exist to justify review of the Green Belt boundary?

Exceptional circumstances do exist, such is the scale of development and the number of houses required. I agree with the aim of keeping the distinction between Medway and London as separate entities with distinct identities. However, I went to the planning meeting at Hundred of Hoo school and learned from Planning Officers that 50% of the new house-holders that have moved into Medway were from outside Medway, mostly London so we are becoming an extension of London and coalescing across the green belt. Also in the light of Labour's policy to re-classify some parts of the Green Belt as Grey belt, perhaps it might be an idea to review the boundary. It might come out worse in that we lose Green Belt as part of the review, i.e. the belt boundary narrows which would be a negative impact but it may also identify sites within the green belt that are grey belt or brownfield sites and more suitable for building on than the green fields of the Hoo Peninsula.

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