Hoo Development Framework

Homes England support the key principles identified within this document and have the following comments on the Key Principles section of the document: Page 52 – On Figure 3.5: • The green corridor/landscape buffer should be amended to avoid brownfield / previously developed land in the context of Homes England land interests, particularly Lodge Hill Camp (and on page 68). Homes England have previously promoted this land for potential employment redevelopment on this brownfield/ previously developed site. Homes England also consider it prudent that brownfield / previously developed land is shown (where known) on the proposed plans throughout the document. • Page 52: Bullet 4 should read “ Provide ecological buffers, as part of a wider package of strategic measures to address potential impacts from development on the Chattenden Woods and Lodge Hill SSSI.” This is important to enable flexibility of accommodating a variety of buffers to development around the SSSI. Page 53 – Figure 3.6: • The primary green route at the far eastern section of the Lodge Hill Training Area should not cut through the SSSI but exit and follow Dux Court Road. Access by the public will need to be managed carefully around the proposed ‘Primary Green route’ given the proximity of the SSSI, it is unclear whether this is proposed to be open to the public and it may not be appropriate for public use. • In relation to the land under environmental management to the west of Chattenden Barracks - this designation would need to be compatible with other requirements of this land (i.e. the potential need for SUDS ponds etc). Homes England also note that the SSSI is all under environmental management but that the annotation does not reflect the brownfield nature of parcels of land within the SSSI and that there can be an element of reuse of brownfield land / existing buildings. The ‘environmental management’ annotation on its own therefore is considered misleading. • The designation “Existing Settlement” should extend to all brownfield/ previously development land, including at Lodge Hill Camp. Page 54 – Figure 3.7 We note that on the Chattenden Woods and Lodge Hill SSSI designation it is shown as “Green Infrastructure”, Homes England suggest this should be removed as it is effectively previously developed land that has a SSSI ‘designation’. This should be amended throughout the document (also page 55). Page 59 – Figure 3.12 - The relief road only appears along a small stretch whilst the remainder is road improvement not relief road, is this correct? Page 60: • It is important that bus provision is included with good connectivity to education, including the proposed secondary school, services and facilities. • HE are keen to be involved in further discussions around bus provision, how it would be delivered and funded including the (indicative) bus link route along Kitchener Road. • More information on potential bus stop locations on new roads and expected level of frequency of bus services would be beneficial to understand. Page 61: As a high-level plan appears fine. More detail will need to be developed on crossing points and links across existing and new developed areas. The potential bridleway between the proposed horse gates at Lodge Hill Lane and Dux Court Road would need to align with a SSSI-wide access management strategy, with interpretation and awareness through signage. Pages 64 and 65: The exact provision at each ‘hub’ for new services should be proportionate, appropriate and deliverable having regard to the scale of development being proposed and correlate with what can be delivered on site. It is important that proposed hubs are ‘deliverable’. Page 68: Homes England seek flexibility to deliver appropriate densities relative to the site in context with its surroundings. We suggest a point is added that Medway Council would be receptive to higher densities by transport hubs/ local centres and key bus routes. This would give more flexibility / justification to boost the supply of housing (as per National Planning Policy Framework, para 60) and to contribute to Medway’s overall housing needs.

Somewhat agree

Homes England are supportive of the proposed allocation of residential uses at Chattenden Barracks and are supportive of these proposals to deliver housing on the Hoo Peninsula. A few specific comments are noted on the content of the proposals on the development framework and other pages: Page 73 (comments also relate to page 9) – Figure 4.2: • Homes England maintain that Lodge Hill Camp should be identified for employment / mixed-use development either within the Development Framework or as ‘other development sites’. This part of the site is brownfield/ previously developed land with existing buildings. Lodge Hill Camp and has previously been promoted in the SHLAA as an employment development site. Equally there are other land parcels across the Lodge Hill asset that could be repurposed / redeveloped to NPPF objectives relating to the productive use of brownfield land. • In relation to the land under environmental management to the west of Chattenden Barracks - this designation would need to be compatible with other requirements of this land (i.e. the potential need for SUDS ponds etc). • It would be helpful to have evidence in the document to demonstrate how many pitches are required as a result of the overall population growth? We note locations for ‘potential outdoor football pitches’ but defining need based on anticipated overall homes / population growth would help to evidence actual provision required. Homes England do not consider that formalised provision of recreation on the former Military Recreation Ground would not be appropriate due to the proximity of land to the SSSI. • Homes England seek flexibility to deliver appropriate densities relative to the site in context with its surroundings. • It is also important to show a footpath link / connection between Chattenden Barracks, the Community Centre and Lodge Hill Recreation Ground. Page 75 – Homes England are in high level discussions about SEMS provision on its landholdings. The impact on the SSSI will need to be considered in relation to public accessibility.

Homes England supports the overall aspirations to create new neighbourhoods, which will be an outcome of developing new housing on the Hoo Peninsula, a few specific comments are noted in relation to the section on Chattenden given it relates to the land owned by Homes England: Page 78 – Acknowledgement that the descriptions in following pages do not constitute policy requirements is important and welcomed. Homes England suggest that acknowledgement is also given that these aspirations will also need to be subject to detailed Masterplanning informed by detailed technical / environmental work. Homes England support in principle the ‘small-scale retail’ proposed at Chattenden noted in Figure 5.2. Page 80 – Note typo in second paragraph an “emphasis” not “emphasise”. • Para 3 - The comment that the magazine stores will be retained should not be categoric as all features are subject to ongoing consideration of all heritage assets and matters that is being considered by Homes England across the Lodge Hill estate. • Para 5 - Homes England note the ‘important links with Cliffe Woods for walking and cycling’ to be maintained and new pedestrian routes through Chattenden to Hoo St Werburgh will be created. Homes England consider that this should also be informed by a joined up Natural England and Medway Council perspective. Page 81 - Homes England are generally supporting of proposed densities and suggest these are shown as ‘indicative’ subject to more detailed masterplanning. In addition, HE note a specific area of ‘land under environmental management.’ This designation would need to be compatible with other requirements of this land (i.e. the potential need for SUDS ponds associated with proposed development of road etc.). It is also important to show a footpath link / connection between Chattenden Barracks and Lodge Hill Recreation ground. Page 82 - Figure 5.10: We note the comment that “Further detailed work is required to ensure the proposals meet the Local Plan’s open space requirements.” Clarification on term ‘neighbourhood parks’ is required as important not to confuse with NEAP provision. Page 83 - Figure 5.12: Homes England object to the provision of a public square on the site given Homes England are primarily considering a ground floor retail unit. A public square is not considered deliverable on Chattenden Barracks and it is critical for any proposed public infrastructure to have clear funding streams to ensure delivery and to be factored into an overall viability appraisal. Any future provision of non-residential uses should be proportionate and deliverable given the scale of the specific development proposals. Page 84 Homes England’s emerging proposals for Chattenden suggested indicative ground floor retail that would appear to relate to the “Commercial and Retail” icon to which the scale of development is likely to support. Homes England are concerned that any additional provision would not be deliverable on the basis of the scale of development being proposed at Chattenden Barracks and so cannot accommodate more that an indicative ground floor retail unit, and there is no evidence to justify any additional provision. Page 85 • Homes England are generally supportive of the proposed densities identified and weighted towards higher density around Lodge Hill Lane but are keen for flexibility as per other comments. • Key frontage facing open space will need to be considered in relation to site specific Masterplanning. Regards will need to be given to technical and environmental matters when considering whether key frontages will be feasible in the locations identified as they will be subject to various factors including, road layout, feasibility of frontages facing woodland. Ramsbottom Wood represents a key landscape asset and as such the design and layout of proposed surrounding residential development should respect and respond to it appropriately. Whilst in principle new development positively and sensitively fronting onto and overlooking the woods should be a key design objective and properties backing onto the woods in principle avoided, the specific design details of route hierarchy and typology, new landscape treatment, building massing and orientation, overlooking and natural surveillance of open space and streets, and plot boundary treatments will be determined through detailed design that addresses detailed consideration of factors including trees to be retained, interfaces with existing properties at Chattenden Lane, views and legibility through the site and the size/ typology of proposed homes. • Homes England suggest the active frontage on Lodge Hill Lane is removed as given the small scale of provision ground floor retail this may be restrictive in subsequent design development, other technical matters such as drainage may also impact design in this location and a bespoke approach to frontages and potential corner treatment / landmark will need to be considered. Keeping the active frontage as a ‘potential’ requirement for consideration through more detailed design is fine, subject to the above considerations. The landmark building could also be a residential building, for example without an ‘active frontage’ in retail / commercial terms, but with a suitable design response in massing and architectural design. • Note no item 3 for Low Density in Figure 5.15.

Homes England have a number of other comments on the document and provide these below: • On Page 6 it could be helpful to have more explanation as to how Medway Council / Gillespies have arrived at this document and it may be helpful for the commentary to explain the journey the Council have been on by outlining the previous stages that have led to this iteration of the Framework including: a) the stages Medway Council / Gillespies have been through (i.e. what consultation/workshops has taken place to inform the document): including individual engagement with stakeholders (developers), local residents (parish Councils) etc. b) Medway Local Plan considerations / options for growth in Hoo and how this will now inform the emerging local plan. c) whether the consultation on Blue and Green infrastructure (B&GI) has informed the document given the reference to B&GI on p54. • On Page 6 query whether ‘Chapter 1’ listed as ‘Executive Summary’ should be ‘Introduction’ given contents page? • Page 8 – Homes England note the 2055 end date and seek confirmation that this relates to the anticipated completion date of the proposed Hoo Development not the end of the new Development Plan period? Homes England suggest that the growth potential is reworded to enable the area to “grow by approximately 10,000 new homes over the next 30 years” to allow flexibility for additional future growth? • Page 16 - Figure 2.9 shows the Special Protected Area (SPA) / Ramsar designation rather than SSSI which needs to be corrected. The SSSI designation is in the key but not correctly shown on the plan. • Page 18 - Landscape sensitivity areas are quite general and do not necessarily reflect site specific characteristics. Homes England query whether Chattenden Barracks should be classified as within Hoo Farmland given its previously developed nature? • Page 19 Chattenden Ridge: o Water bodies are mentioned in the LCA and are subsequently described in the Development Framework as a strong landscape feature. However, no water bodies are shown on the later water plan (on page 23)? It would be helpful to have clarification on this point. o The second bullet point is not required if integration of designations is included in the final bullet point. • Page 23: o It would be helpful to have a description of what the Framework Area includes and excludes, for example does it just include new proposed uses etc. It appears to not include any of the HIF Road, Rail or SEMS areas. We note that the proposed residential at High Halstow is included and is not adjacent the other residential area, so other areas not adjacent to the main Framework Area could also be included, such as land to the far North of Chattenden (i.e. Lodge Hill Camp / Training Area) in its brownfield land capacity. o Homes England seek the identification of Lodge Hill Camp for development. This part of the site contains existing buildings. We request that it is identified as an “other development sites” or ideally incorporated into the development framework area. o In that the Lodge Hill Recreation Ground constitutes part of the Chattenden Barracks masterplan, this land parcel should be reflected as such in the framework plans. • Page 28: On commentary – Homes England understands that the Church (Bishop Gundulph) is closed permanently. Homes England agree that development at Chattenden needs to acknowledge and respect the role of the existing centre. • Page 40: Figure 2.65: The Hoo Stop Line could be seen as an opportunity rather than a constraint. • Page 43 – the ‘potential relief road’ only appears along a small stretch whilst the remainder is potential new road, is this approach correct? • Page 44 – Homes England consider that the proposed cycle link from Chattenden Lane to Great Chattenden Wood and the proposed new bridleway to the north of the Lodge Hill site should be informed by a joined up Natural England and Medway Council perspective. This potential cycle route and bridleway, would need to align with a SSSI-wide access management strategy (linked or informed by the SEMS network), with interpretation and awareness through signage. We would envisage that any proposed infrastructure such as this would be supported by a dedicated Access Management ‘Masterplan’ that identifies appropriate measures/ approaches for minimising recreational pressure on the SSSI. It would be helpful if proposed cycle and pedestrian routes in this direction are clarified in the context of this sensitive designation to ensure that the Chattenden Woods and Lodge Hill SSSI is not detrimentally affected, and we would welcome further engagement with you on this policy. o Query what potential new blue infrastructure annotation will comprise on figure 2.79. • Page 45 - Figure 2.82: Additional detail on the walkable neighbourhoods welcomed, the scale of the neighbourhood centres will be subject to scale of housing development and ability to deliver.