Medway Local Plan (Regulation 18, 2024)

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Form ID: 2777

Respondent: Catesby Estates

Agent: Mr Craig Pettit

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?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.33 Catesby Estates does not consider this to be a sound approach. Local standards which differ from national standards and requirements can lead to bespoke approaches needing to be applied. This can impact viability and the ultimate delivery timescales of sites. It is considered that policies can encourage betterment, however, standards should be based on those at a national level. Should the Council wish to set local standards a viability assessment would need to be conducted, and the Council would need to confirm how it has introduced sufficient flexibility to account for changes in technology.

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

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.34 Catesby Estates does not consider this to be a sound approach. The statutory minimum biodiversity net gain of 10% has been derived following detailed evidence and is widely accepted nationally. Policies can encourage the betterment of the statutory minimum but it should remain as the baseline.

What evidence can you provide to support your view?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.35 In support of this, the Planning Practice Guidance states the following: “Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented."

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.

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.36 A tariff to support the delivery of the SAMMS programme should be sufficiently evidenced in order to justify:  The need for the tariff;  The type of development that the tariff applies to,  The location of the development; and  The amount of the tariff. 3.37 Should the evidence justify that such a tariff is required, it should be tested within the viability assessment to ensure the inclusion of the tariff does not impact the delivery of the development.

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

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.38 Paragraph 180 of the Framework sets out that planning policies should contribute to and enhance the natural and local environment. Part of this is to protect and enhance valued landscapes. There is therefore no requirement for the Council to specifically designate landscapes of local value. 3.39 The Council must also be mindful of the designations that are already in place, such as the statutory Kent Downs National Landscape designation, Special Protection Areas, Local Nature Reserves and Local Wildlife Sites, and consider whether the introduction of another designation would benefit or inhibit the planning process.

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

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.40 Should the Council decide to designate any areas, the following criteria set out within the Guidance for Assessing Landscape Designations (Natural England 2021), is considered relevant: a) Sufficient evidence should support the designation of any area specifying the landscape qualities of the area. b) Ensure the correct area is designated and not a blanket designation c) Provide clear guidance for how development can come forward within these areas to ensure that the vision and needs for Medway are deliverable

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

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.41 Catesby Estates supports the inclusion of Natural England’s Green Infrastructure Framework Standards within the LP2041. Notwithstanding, sufficient flexibility should be provided to ensure that where the framework is not applicable, or where the framework changes over time, allowance is provided within the Policy. 3.42 In relation to sites AS18 and AS22, the accompanying Vision Document demonstrates the intention incorporate a network of greenspaces that are connected to one another and to those outside of the sites. The associated open space will provide a variety of benefits to both existing and future residents.

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?

No answer given

Form ID: 2784

Respondent: Catesby Estates

Agent: Mr Craig Pettit

Do you think this policy provides effective guidance on the required housing mix in Medway?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.43 The supporting text to Policy T2 states that the housing mix is informed by the Local Housing Needs Assessment (2021) and that the Council will update this evidence before finalising the Plan to accurately reflect needs. This is considered the correct approach to ensure the policy is informed by the most up to date evidence and Catesby Estates awaits this information before commenting further. 3.44 In addition, given the Council’s preferred option for growth is a blended strategy, the policy should also allow for considerations pertaining to local market and demand, to ensure there is a correct understanding on what is appropriate in urban areas vs suburban/rural areas. This flexibility is important as urban needs will rarely align with suburban/rural needs.

Do you agree with having a 10% requirement for affordable housing on urban brownfield sites and 30% requirement for affordable housing on greenfield sites and higher value urban locations?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.45 Policy T3 requires different levels of affordable housing based on the value of the area within which a particular site sits. This is 30% provision in high value areas and 10% provision in low value areas, said to have been informed by the Local Plan Viability Assessment. 3.46 The Local Plan Viability Assessment (including CIL) – December 2021 concludes that the Residual Value on the greenfield typologies assessed is above the Benchmark Land Value. Paragraph 6.3.11 states: “In the areas where viability was challenged, such as urban brownfield sites, a 10% affordable housing rate could be supported. In the stronger market areas, such as the Hoo Peninsula and suburban locations, this rose to 30%. The difference was based on the different land values, house prices and build costs. The 2022 Viability Assessment has informed the content of this draft policy for consultation. The Council notes that there may have been changes in the development market since the preparation of this assessment, and variations in proposed development sites considered in the assessment. The Council will consider comments in relation to viability from this consultation, and address these in updating the evidence base and policy response for the Regulation 19 Pre-Submission Draft Plan.” 3.47 The cost implications of delivering strategic sites which accord with the Council’s vision, for example, providing increased areas of open space, biodiversity net gain and access to sustainable transport corridors, will also need to be considered. 3.48 The Council includes the opportunity to provide a viability assessment to justify a lower provision, which is considered a sound approach in order to provide a mechanism to consider this on a site by site basis. 3.49 It is also noted reference is made to a 2022 Viability Assessment, which is not included within the consultation evidence base.

What do you consider would represent an effective alternative approach? Do you agree with a varied approach for affordable housing requirements based on the different value areas across Medway?

No answer given

What do you consider would represent an effective split of tenures between social/affordable rent and intermediate/low-cost home ownership housing in delivering affordable housing?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.50 The split of tenures should be informed by up to date housing needs assessments or SHMA. Flexibility should also be incorporated into the policy to allow for the changing circumstances/demand across the Plan period and for differing individual site characteristics.

What do you consider would represent an effective split of tenures between social/affordable rent and intermediate/low-cost home ownership housing in delivering affordable housing?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.51 Catesby Estates considers that there may be occasions where onsite provision of affordable housing is not suitable or viable and so mechanism for securing off site affordable housing is considered acceptable. 3.52 In relation to the cascade principle, Catesby Estates supports the provision that local people in need of housing in their local area should have first refusal on new affordable housing and that where surplus affordable housing remains, this should then be allocated based on the Council’s housing needs register.

Do you have views on defining the limits to over-concentration of HMOs in a community? What criteria would be recommended?

No answer given

Do you have any sites you wish to promote for self-build allocation?

[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.53 Catesby Estates notes the inclusion of its land (site AS22) within Policy T9: Self-build and Custom Housebuilding, for the provision of 5% of the dwellings proposed. This is supported in principle, provided there is an identified need. 3.54 Policy T9 states that the landowner/developer is required to market the plots available for self/custom-build for a minimum period of 12 months. The policy then states that if any plot(s) remain unsold after being marketed for this 12 month period, they can either remain for sale as a self/custom build plot or be offered to the Local Authority to acquire for the provision of affordable housing (separate from any relevant affordable housing requirement for the Development as applicable), before reverting back to the land owner to build out on the plot or sell without restriction. To prevent the delay of housing delivery, the Local Authority will be given a time period of three months to acquire the vacant plot(s). 3.55 Whilst this mechanism is well considered, should plots not be required by self-builders or the Council, the policy effectively places a pause on these plots for 15 months, before they revert to the landowner/developer. The Council should consider whether this is feasible for the developer to return to these plots after this period has elapsed. It is considered a 12 month period for both self-build and Local Authority interest may be sufficient. 3.56 The policy is also designed to cater for self-build need, therefore the ability for the Council to secure these plots for affordable housing will need to considered in further detail. For example, how will this relate to the construction of the wider site?

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