Medway Local Plan (Regulation 18, 2024)

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Form ID: 1994

Respondent: Mrs Michaela James

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?

The Local Nature Recovery Strategy (Making Space for Nature) should set priorities for the county and local area and these should be used in setting local development permissible and non-permissible criteria. If Medway has less green area than country average this should justify not losing more. Green belts should be no go if this means loss of greenspace between communities. Farm land should not be lost unless it can be recreated/replaced with new farm land.

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

Yes, absolutely especially as we are in a densely populated with areas of ecological and heritage importance. the 10% appears to only look at the build and not all the disruption during in the local area through road closures, increased traffic, construction materials manufacture and delivery of, etc..

What evidence can you provide to support your view?

Not a development, but road changes such as the Stockbury roundabout have caused congestion and road issues far and wide in the area, adding to air pollution, wear and tear and increased road use on more rural routes such as Boxley. The change of the landscape in the area, impact on routes and homes. I don't believe the current 10% covers would cover this. The system is still quite new and subjective, so a generous overage would show commitment to best practise.

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.

This system is good basis to start on but should perhap not be the only or limited to approach. There should be limits and boundaries set that may change if any detrimental changes are seen. The system may also consider restrictions on developments that ensure protection or enhancement of protected sites.

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

Medway Council should have the ability to designate additional local value sites based on knowledge and/or application process from the community that meet a set criteria. This should provide a strong case against any governmental targets and rules that do not consider the whole system as intimately as the local council and community. Whilst the goverment may set some target criteria that should recogonise anomalies across different landscapes and communities.

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

Accessibility to green space for all. Habitat connection. Unique buildings of cultural, historical or community value. Places like Darland Banks do not appear shown as AONB, but the value of this Nature Reserve is irreplaceble as is the Capstone Park area. Woodland areas such as those bordering the Bredhurst area.

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

Yes, these support and hopefully can gain funding for future improvements. These should be a minimum standard and we should not be afraid to go above and beyond these objectives as the LNRS will identify with NE support for local priorities.

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?

Appreciate the complexities of the system, so tend to agree the focus is correct.

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

Yes, updates should be incoporated.

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

Exceptional circumstances may require review, but these should be open and with public consultation.

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