Medway Local Plan (Regulation 18, 2024)

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Comment

Medway Local Plan (Regulation 18, 2024)

Vision for Medway in 2041

Representation ID: 3457

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

The draft Local Plan states in its strategic objectives that growth will be directed to the most suitable locations. We submit the strategic objective itself is too vague to serve its purpose – it is unclear what it would or would not justify and is not a proper basis for alternative testing or assessment of soundness. Further, in relation to employment, critical economic infrastructure, and lack of proper alternative testing, the strategy would not put the growth in the most sustainable places. There are a number of inconsistencies with the NPPF, detailed further in the full representation provided to planning.policy@medway.gov.uk

Full text:

The draft Local Plan states in its strategic objectives that growth will be directed to the most suitable locations. We submit the strategic objective itself is too vague to serve its purpose – it is unclear what it would or would not justify and is not a proper basis for alternative testing or assessment of soundness. Further, in relation to employment, critical economic infrastructure, and lack of proper alternative testing, the strategy would not put the growth in the most sustainable places. There are a number of inconsistencies with the NPPF, detailed further in the full representation provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Prepared for a sustainable and green future

Representation ID: 3459

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

Chatham Docks utilities river-borne and sea-borne transport to receive raw materials and to send out finished products, a lower carbon alternative to road-based transport. If Chatham Docks is redeveloped as a residential led development, ArcelorMittal Kent Wire will be forced to relocate, likely outside the UK, leading to longer journeys for their steel products essential for UK construction projects, including those associated with sustainable energy development.

The carbon impact of this has not been properly considered by as part of the draft Local Plan process.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

Chatham Docks utilities river-borne and sea-borne transport to receive raw materials and to send out finished products, a lower carbon alternative to road-based transport. If Chatham Docks is redeveloped as a residential led development, ArcelorMittal Kent Wire will be forced to relocate, likely outside the UK, leading to longer journeys for their steel products essential for UK construction projects, including those associated with sustainable energy development.

The carbon impact of this has not been properly considered by as part of the draft Local Plan process.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Supporting people to lead healthy lives and strengthening our communities

Representation ID: 3460

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

Chatham Docks is a 400-year old commercial port and is a vibrant, working dock operating 24 hours a day, seven days a week. The docks employ over 800 people – many of whom local. There are also existing jobs in the supply chains. There are over 2000 jobs dependent on the docks.

Chatham Docks must be both supported and protected in the new Local Plan. The new Local Plan must strike a balance in identifying new sites for housing but not to the detriment of existing jobs and existing important employment generating uses.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

Chatham Docks is a 400-year old commercial port and is a vibrant, working dock operating 24 hours a day, seven days a week. The docks employ over 800 people – many of whom local. There are also existing jobs in the supply chains. There are over 2000 jobs dependent on the docks.

Chatham Docks must be both supported and protected in the new Local Plan. The new Local Plan must strike a balance in identifying new sites for housing but not to the detriment of existing jobs and existing important employment generating uses.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Securing jobs and developing skills for a competitive economy

Representation ID: 3461

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

ArcelorMittal strongly supports the Council’s Strategic Objectives to secure jobs and develop skills for a competitive economy – these objectives must be carried forward in continuing to protect Chatham Docks in the new Local Plan.
The current Local Plan protects existing employment uses and ‘port-related development.

If the Council is truly seeking to ‘boost the performance of the local economy by supporting local businesses to grow and innovate…’ and ‘build on existing strengths and expertise, such as engineering…and raise the profile of key sectors…’ then these protections must remain.’

A full representation is provided to planning.policy@medway.gov.uk

Full text:

ArcelorMittal strongly supports the Council’s Strategic Objectives to secure jobs and develop skills for a competitive economy – these objectives must be carried forward in continuing to protect Chatham Docks in the new Local Plan.
The current Local Plan protects existing employment uses and ‘port-related development.

If the Council is truly seeking to ‘boost the performance of the local economy by supporting local businesses to grow and innovate…’ and ‘build on existing strengths and expertise, such as engineering…and raise the profile of key sectors…’ then these protections must remain.’

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Boost pride in Medway through quality and resilient development

Representation ID: 3462

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

There is no proper assessment of the proposed loss of the ArcelorMittal Kent Wire facility versus the residential led proposal to ascertain whether what is proposed is a quality and resilient development. The lack of proper assessment prevents evidence-based judgments being made.

Given the significance of the port and its unique features as a non-tidal dock within Medway and the South-East, we consider there must continue to be a policy within the Local Plan which specifically supports the docks and its uses. We submit an alternative proposal for the Docks, the SPPARC Masterplan, alongside our full representations to planning.policy@medway.gov.uk

Full text:

There is no proper assessment of the proposed loss of the ArcelorMittal Kent Wire facility versus the residential led proposal to ascertain whether what is proposed is a quality and resilient development. The lack of proper assessment prevents evidence-based judgments being made.

Given the significance of the port and its unique features as a non-tidal dock within Medway and the South-East, we consider there must continue to be a policy within the Local Plan which specifically supports the docks and its uses. We submit an alternative proposal for the Docks, the SPPARC Masterplan, alongside our full representations to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Spatial Development Strategy

Representation ID: 3463

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

Neither the draft Local Plan nor supporting documents provide any reasoned conclusions for the redevelopment of Chatham Docks away from strategically significant steel manufacturing. There is no indication that the Council have considered the spatial and location uniqueness of the last non tidal dock in the South East, nor the consequences of redeveloping them as homes. It does not consider the impact on the UK construction industry, carbon impacts of losing water based transport, loss of 2000 skilled jobs and inadequately considers economic impact, employment land, and the unique features of the docks.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

Neither the draft Local Plan nor supporting documents provide any reasoned conclusions for the redevelopment of Chatham Docks away from strategically significant steel manufacturing. There is no indication that the Council have considered the spatial and location uniqueness of the last non tidal dock in the South East, nor the consequences of redeveloping them as homes. It does not consider the impact on the UK construction industry, carbon impacts of losing water based transport, loss of 2000 skilled jobs and inadequately considers economic impact, employment land, and the unique features of the docks.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

3.2.1

Representation ID: 3464

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

There is no assessment of the proposal for the residential led redevelopment of Chatham Docks. The Chatham Docks Employment Report considers the economic impact of a mixed-use redevelopment of Chatham Docks but in a superficial way without proper consideration of the loss of UK production of essential steel products. The issue is not adequately considered by the Sustainability Appraisal. Noting the very widely drawn strategic objective, the Council has so far failed to produce (or rely on) any evidence which properly appraises the proposed redevelopment.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

There is no assessment of the proposal for the residential led redevelopment of Chatham Docks. The Chatham Docks Employment Report considers the economic impact of a mixed-use redevelopment of Chatham Docks but in a superficial way without proper consideration of the loss of UK production of essential steel products. The issue is not adequately considered by the Sustainability Appraisal. Noting the very widely drawn strategic objective, the Council has so far failed to produce (or rely on) any evidence which properly appraises the proposed redevelopment.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Policy S1: Planning for Climate Change

Representation ID: 3465

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

Chatham Docks, by virtue of its location on a non-tidal dock, is able to use water-based transport. Were the site to be redeveloped for residential led development in accordance with the draft Local Plan, the new occupiers would not make use of that water-based transport. AMKW have sought to identify alternative sites but have concluded they would likely need to relocate outside the UK. This would have both carbon consequences, as materials would need to be transported longer distances, and likely with more reliance on road-based transport.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

Chatham Docks, by virtue of its location on a non-tidal dock, is able to use water-based transport. Were the site to be redeveloped for residential led development in accordance with the draft Local Plan, the new occupiers would not make use of that water-based transport. AMKW have sought to identify alternative sites but have concluded they would likely need to relocate outside the UK. This would have both carbon consequences, as materials would need to be transported longer distances, and likely with more reliance on road-based transport.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Policy S5: Securing Strong Green and Blue Infrastructure

Representation ID: 3466

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

Chatham Docks is vital to maintaining a ‘robust…blue infrastructure network…’

The river-borne and sea-borne traffic associated with Chatham Docks allows direct sustainable connections with the rest of the South-East and with European ports, rather than just lorry deliveries in and out. These options would be lost were Chatham Docks to be redeveloped for uses not requiring water-based transport, and with displaced industry instead relying more on road-based transport with consequent carbon impact.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

Chatham Docks is vital to maintaining a ‘robust…blue infrastructure network…’

The river-borne and sea-borne traffic associated with Chatham Docks allows direct sustainable connections with the rest of the South-East and with European ports, rather than just lorry deliveries in and out. These options would be lost were Chatham Docks to be redeveloped for uses not requiring water-based transport, and with displaced industry instead relying more on road-based transport with consequent carbon impact.

A full representation is provided to planning.policy@medway.gov.uk

Comment

Medway Local Plan (Regulation 18, 2024)

Policy S10: Economic Strategy

Representation ID: 3469

Received: 08/09/2024

Respondent: ArcelorMittal Kent Wire Limited

Agent: Lucy McDonnell

Representation Summary:

The Local Plan puts forward policies in relation to employment land needs, whilst acknowledging that it is based on an assessment from 2015, updated in 2020. We submit that a more up to date assessment is required to accurately consider the need for employment land. The information provided to date is an insufficient basis for the Council's apparent identified need to "regenerate" Basin 3. We do not consider that a need to "regenerate" the site has been identified, especially given that it is currently occupied by a viable key employer.

A full representation is provided to planning.policy@medway.gov.uk

Full text:

The Local Plan puts forward policies in relation to employment land needs, whilst acknowledging that it is based on an assessment from 2015, updated in 2020. We submit that a more up to date assessment is required to accurately consider the need for employment land. The information provided to date is an insufficient basis for the Council's apparent identified need to "regenerate" Basin 3. We do not consider that a need to "regenerate" the site has been identified, especially given that it is currently occupied by a viable key employer.

A full representation is provided to planning.policy@medway.gov.uk

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