Medway Local Plan (Regulation 18, 2024)
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5.3 The view of CCE’s appointed ecologist, Ecology Solutions, is that the planning policy in the Reg 18 B Plan is pitched correctly – to ensure compliance with the 10% national legislative standard. For many sites (particularly intensely farmed arable), whilst it may be possible to aim for and indeed achieve more than 10%, this should be explored on a site-by-site basis, rather than written into Policy. A higher target in the Local Plan across Medway would be overly prescriptive and could result in deliverability or viability issues, noting that BNG assessment work is complex and varied .
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5.4 The approach put forward is pragmatic and aligns a number of key elements, including aspects that can deliver BNG, wider ecological benefit and other elements of schemes important for ecology (such as informal recreational areas) and other disciplines (drainage, landscape, design).
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7.5 CCE support the importance given in the Reg 18 B Plan to affordable housing, it being a ‘key priority’. CCE’s strategic landholdings provide the opportunity to make a significant contribution to affordable housing in Medway. There is a need to provide the right homes in the right places to meet Medway’s growing affordable housing needs. Policy T3 Affordable Housing proposes 30% affordable housing in ‘high value areas’ including the Hoo Peninsula and suburban greenfield sites. The policy states: ‘A viability assessment in line with national policy and guidance should be submitted to the Council to be independently verified if the affordable housing proposed does not meet that which is required.’ The policy should be amended to make it clear that, should the viability assessment demonstrate the requirement for affordable housing is not achievable, then a lower level could be acceptable. 7.6 On Tenure mix, Policy T3 refers to ‘49% affordable home ownership, including First Homes’. Medway will be aware that the Government’s proposed changes to the NPPF (2024), would remove the requirement for ‘First Homes’. Should this change be published within an updated NPPF towards the end of the year, the Regulation 19 Plan will need to be updated accordingly. 7.7 In addition, the Policy refers to the ‘Local Plan Viability Assessment’, which was undertaken in 2022. An updated Viability Assessment will need to be prepared and published with the Regulation 19 consultation later this year, and Policies reviewed in line with this document to check the 10% and 30% requirements remain achievable.
Support the importance of delivering Affordable Homes in Medway. CCE’s strategic landholdings provide the opportunity to make a significant contribution to affordable housing in Medway. There is a need to provide the right homes in the right places to meet Medway’s growing affordable housing needs. An updated Viability Assessment will need to be prepared and published with the Regulation 19 consultation later this year, and Policies reviewed in line with this document to check the 10% and 30% requirements remain achievable.
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7.6 On Tenure mix, Policy T3 refers to ‘49% affordable home ownership, including First Homes’. Medway will be aware that the Government’s proposed changes to the NPPF (2024), would remove the requirement for ‘First Homes’. Should this change be published within an updated NPPF towards the end of the year, the Regulation 19 Plan will need to be updated accordingly.
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9.4 The supporting text of S22 Hoo Peninsula confirms the Council is collating evidence as part of the preparation of the Local Plan, which includes identifying the infrastructure and service needs linked to growth in this location. This evidence base will be a key document; it must undertake a capacity and needs based assessment to inform the emerging proposals for infrastructure and retail at the Hoo Rural Town, including whether the provision of a supermarket at Hoo is likely to be needed. CCE would welcome engagement with the Council on this evidence base to understand further the requirements for infrastructure to support the new Community. In the same way, CCE would welcome discussions with Medway on need, timing and location of other infrastructure including schools (see CCE’s response to question 42). 9.5 Allocation of CCE’s land at both east and west of Ropers Lane, would not only provide the opportunity for the delivery of a mix of much needed, high-quality homes (including affordable homes), but the opportunity to provide a sustainable mixed-use development, including education, employment and the opportunity for retail provision. Current illustrative concept proposals for development of CCE’s land east and west of Ropers Lane are provided at Appendix 3 and in the Vision Document. However, this is not fixed and, should it be decided that land to the east of Ropers Lane would be usefully allocated alongside residential use to provide retail provision, or other infrastructure to encourage sustainable travel patterns for existing and new residents at the Peninsula, then this could be explored in consultation with Medway, CCE, and the wider Hoo Consortium. 9.6 In preparing its evidence base and developing the Regulation 19 Plan, Medway must consider the changing nature of the retail market. A data-led approach should be adopted to assess the amount of retail space which would be economically viable given the calculated anticipated retail spend of the new population.
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10.6 CCE consider it prudent to identify the infrastructure required to support development in Medway. Large scale strategic infrastructure, such as schools and road junctions, should be identified and funded by those allocations which benefit from their development. A mini IDP approach could be used to identify infrastructure, which is solely required for, and therefore funded by a single allocation.
10.6 CCE consider it prudent to identify the infrastructure required to support development in Medway. Large scale strategic infrastructure, such as schools and road junctions, should be identified and funded by those allocations which benefit from their development. A mini IDP approach could be used to identify infrastructure, which is solely required for, and therefore funded by a single allocation.
10.7 Sufficient development will need to be delivered to fund the construction of infrastructure. Careful consideration will need to be given as to when elements of infrastructure is required and then ranked in terms of priority, so it can be delivered in a stages across the development period of an allocation ensuring its viability.