Hoo Development Framework

1. Introduction 1.1 In January this year the Labour and Cooperative Group submitted comments on the Future Hoo Consultation – Second Round. We welcome the opportunity to submit further comments on the Hoo Development Framework and are using this opportunity to further refine our views on this fundamentally important development for Medway. 1.2 The community of Hoo St. Werburgh and the surrounding villages on the Hoo peninsula will be changed forever by these development proposals. As we made clear in our earlier submissions any development on this scale must be sustainable in terms of the existing community, the local economy and especially the local environment (the triple bottom line used as guide to sustainability). It is not possible to build 10,000 homes, and all the infrastructure that goes with them, without fundamentally changing the nature of the local community and if this is to happen these changes must be to the benefit of the current and future generations. 1.3 Our reading of the HDF document is based upon the understanding that the 10,000 plus homes will be built. We are, nevertheless, conscious that the current Government appears to be reviewing housing “need” calculations and the picture may change at any time. If this happens then we would expect there to be a new round of consultation based upon any new housing figures that are proposed. 2. Comments 2.1 Executive Summary – Vision 2.1.1 The framework will take 30 years to develop according to the current Council estimates and the HDF document has four guiding principles for this development. We welcome this approach but would like to see specific mention, in the Executive Summary, to the principles of sustainable development. In particular, the impact of this development in relation to our climate change emergency. 2.1.2 The increased population, which will be at least three times as large as the current 9,000, creates demand for new services which inevitably have a community, an economic and an environmental impact, all of which need to be addressed. The HDF document should recognise this from the outset. This position is further supported through our requirement to comply with the principles of the Social Value Act (2012) and it supplements, when providing infrastructure and services to the community. 2.1.3 There is some confusion over terminology in the HDF document when describing the future of Hoo St. Werburgh. In the executive Summary it is described as a “rural town” and a “small town”. In the section 3.2 it is referred to as a “Garden Community” and a “Garden Village”. Reference is even made to “Garden Cities”. 2.1.4 Bearing in mind scale of the development and its impact on the local community and the wider Medway community, we need to avoid any confusion on the part of the development companies as to our aspirations. Q. Can we have clarity as to what this means? Is Hoo St. Werburgh going to be a village, a town or a city? Is it a rural or a garden one? Is it large or small? 2.2 Context Analysis 2.2.1 Paragraph 2.2 of the HDF document describes the Medway Context of the development and refers to the historic towns of Strood, Rochester, Chatham, Gillingham and Rainham and the separation of Hoo St. Werburgh. Specific reference is made to the difficulty of accessing the Hoo peninsula without a car. 2.2.2 We are also asked to take into consideration the changes on the peninsula such as the decommissioning of the power stations and pressure to redevelop the former industrial sites. These points are important in relation to our comments below. 2.2.3 In paragraph 2.5 the HDF Document states that it is beyond the scope of the HDF to “deliver a comprehensive appraisal of the landscape sensitivity of the setting”. Nevertheless, the development of the SEMS was based upon such appraisals and there are detailed descriptions in this section of the report and in Part 3 (Vision and Guiding Principles) with references to the landscape led approach and the importance of strategic gaps and ecology buffers. 2.2.4 Based upon this analysis we would challenge the assessment made of the landscape sensitivity of the Chattenden and Deangate Ridges. In the HDF document this sensitivity is given as Medium/High and Medium respectively, while in fact they both should be High. The nearby Cockham Farm Ridge is assessed as Medium/High and the both the Chattenden and Deangate Ridges are significantly more important in landscape terms. Q. Can the landscape sensitivity assessment of the Chattenden and Deangate Ridges be changed to High? 2.2.5 Paragraph 2.9 discusses the vehicular movement on the peninsula. Car ownership and usage are much higher than the rest of Medway reflecting the poor connectivity and lack of adequate public transport. Cycling is mentioned, but again the topography and the roads discourage even the keenest cyclists. In addition, the bus network is described as “limited and unattractive”! 2.2.6 We would agree with this analysis. It is clear that there should be a sustainable transport approach to this problem. This is especially true regarding Four Elms Hill, the high quantity of HGVs accessing the Hoo peninsula, the inadequate road network, and the impact of the increased traffic the new developments will bring to Frindsbury and Strood. 2.2.7 Paragraph 2.11 describes the existing commercial and social facilities within Hoo St. Werburgh; the community infrastructure and employment opportunities. It is clear that there will be a significant increase in these as the local population rises. How these are managed and accommodated should be a key part of the emerging new Medway Local Plan. 2.2.8 Paragraphs 2.15 and 2.16 of the HDF Document summarise the constraints that we face with the HDF, and we would agree with these. Again, we would like to stress the importance of approaching these from a sustainable development point of view, taking into consideration the needs of the local community, the local economy and the local environment. 2.2.9 Paragraph 2.17 summarises the “opportunities” of the new housings estates. We would like to point out that these are not strictly opportunities but essential requirements for a very large-scale housing development. Specific reference is made to a “new relief road” taking traffic away from Four Elms Hill. Q. Could we have some clarity as to what this actually means? 2.3 Vision and Guiding Principles 2.3.1 The vision and guiding principles are detailed in Part 3 and in respect to the green and blue infrastructure have our full support. In fact, we have already expressed this through our support for the SEMS planning applications. The importance of landscape gaps and ecology buffers is well recognised. The need for the use of native, local species when landscaping with the new developments is also well recognised. 2.3.2 We have already referred to the confusion caused by naming the new developments as a “rural village” or a “garden village”, etc. We would reiterate our request for clarification as to what is meant by these terms, and which apply to the new developments. 2.3.3 There are two additional points we would like to bring in here. Firstly, the need to achieve significant biodiversity net gain in all new developments, over and above the standard 10%. 2.3.4 Secondly, the need to protect the landscape of the Hoo peninsula and in particular the strategic landscape gaps between the settlements and the main urban areas of Medway. 2.3.5 To this end we are proposing that that Hoo St. Werburgh and the surrounding peninsula and marshes to the North and East be designated as an Area of Outstanding Natural Beauty (AONB). 2.3.6 In 2020 a motion was put to the Council to start the process of designating the Hoo Peninsula and the marshes beyond as an Area of Outstanding Natural Beauty. We would strongly advocate this approach for a number reasons; • It provides protection at a national level for the landscape of this area, alongside the national and international protections the area enjoys for ecology and biodiversity. • It provides an opportunity to clearly define the landscape characters of the area so as to guide current and future development. • It provides a decision-making structure that has a focus upon the special nature and character of the area, especially for the local communities. • It provides a focus for the future challenges that the area will face in the light of climate change and especially sea level rise. • It will act as a focus for the development of new sustainable tourism opportunities in the area, not dissimilar to the north Norfolk coast. • It opens up new channels for funding opportunities for the area whilst not standing in the way of the Hoo peninsula playing its part in Medway meeting it housing requirement. These benefits form the basis for the aspirations of the landscape led approach described in the document. 2.3.7 Paragraph 3.4 of the HDF document refers to accessible and well-connected settlements and discusses the transport options for the new development. We have already seen how the road network is inadequate and we believe that a sustainable transport plan is the solution. 2.3.8 The original concept of a rail link into Strood has now been shelved. The new station at Sharnal Street and rail link into Gravesend will simply be a shuttle service. People will have to change trains to get to London and there is no indication as to when this will be delivered. The funding for this makes up a significant amount of the HIF and does not address the fundamental problems of connectivity between the communities on the peninsular and the urban areas of Medway. 2.3.9 It is our view that plans for the Sharnal Street station and shuttle to Gravesend be put on hold. Instead, this funding should be used toward the provision of an electric bus service. This would operate between the communities on the peninsular, from the new development to Strood, and even further into Medway. 2.3.10 We cannot rely upon private bus services to develop the level of infrastructure required for this. However, once in place we will have no difficulty in finding operators willing to be a part of this exciting project. The benefits of this would be huge; • Providing a carbon neutral, pollution free bus service between Hoo, the neighbouring settlements, and the urban areas of Medway. Creating better connectivity throughout our communities both existing and emerging, with much more flexibility as development moves forward. • Looking forward, the transport element of any s106 agreements would be targeted at this growing, flexible and sustainable transport network. • Providing links to the new employment centres within Medway. • Providing a school bus service for children to the new school in Strood. • Linking residents in Hoo with a much better rail service from Strood to London, Maidstone and the coast. • This will also open up the opportunity for Strood station to become a much more effective transport hub for Medway, as the Council owns the vacant land adjacent to the station. This would, in our view, be a much more effective and strategic way of using the HIF. In comparison the proposed rail shuttle is fixed, very expensive, and only goes to Gravesend. It would achieve the aim of providing a link to the national rail network whilst also giving a new and sustainable approach to transport within Medway. If the aspiration to develop the railway line from Sharnal Street to Gravesend is to be realised, this should be the responsibility of Network Rail and not Medway Council. 2.3.11 Principle 3 deals with sustainable communities and the idea that people should be able to live, work and socialise locally. In this respect we would welcome specific reference to the 20 minute neighbourhood as specified by the TCPA ( The 20-minute neighbourhood - Town and Country Planning Association (tcpa.org.uk) as a guide for developers. This approach is well researched and includes community cohesion and the sustainability concepts which we are striving for. It also allows us to preserve the best in existing local communities, allowing them to maintain their identity in the face of these huge new developments. 2.3.12 Principle 4 deals with Attractive and Tailored Built Form. The key issues within this principle should be dealt with by the emerging new Medway Local Plan and the details submitted with each planning application. Nevertheless, there are some basic concepts around sustainability and the climate crisis that should be applied. • All new builds should be carbon neutral, well insulated and low on energy for affordability • All materials used must sourced sustainably • All new houses should have EV charging + community charging spaces will be needed as well • All landscaping should use local native species and there needs to be a lot of trees to cope with the urban heating we are experiencing • Waste disposal should all be recyclable • Work from home capability is required in all new homes • Sustainable transport in all its forms It should be noted that even with existing technologies these are all achievable and certainly can be over the lifetime of the development. A good example of how we can achieve these ideals is seen in new Lower Thames Crossing, described as a pathfinder project, it will be carbon neutral (Environment - National Highways). 2.4 The Framework Plan 2.4.1 As stated above we believe that there needs to be a change within the Framework Plan that removes the fixed, inflexible and limited rail shuttle to Gravesend. This should be replaced with an electric bus service for the existing and new communities, that also runs down Four Elms Hill on a dedicated route to Strood station. 2.4.2 Strood station provides a much more effective rail link to London, Maidstone and the coast. There is sufficient land close to the station, in Council ownership, to allow for a new Transport Hub to be created. 2.4.3 This approach allows for a sustainable transport network to develop over time for the existing and new communities. It also opens up the opportunity to extend this into the main urban centres of Medway. 2.4.4 The Housing Infrastructure Fund was provided specifically for the new housing developments around Hoo St. Werburgh. The electric bus approach is flexible and will always have capacity for growth in a sustainable way to cope with all types of additional growth on the Hoo peninsula, including the redevelopment of the Kingsnorth site. 2.4.5 This will also include the anticipated growth in eco-tourism if the proposed AONB on the Hoo Peninsula and adjacent marshes were to go ahead. 2.5 The Neighbourhoods 2.5.1 We welcome the approach to the creation of distinctive neighbourhoods within the new developments. In this respect we would want the character and nature of the existing communities to be retained within the emerging neighbourhoods. 2.5.2 This approach needs to take in to account the TCPA “20 minute neighbourhood” concepts, as outlined above. In addition, the emerging, new Medway Local Plan, and its successor, must be the main guide for all new developments over the 30 year lifetime of this development. 2.5.3 Specific reference is needed to the development of the Chattenden and Deangate Ridges Neighbourhoods. This carries with it some controversial issues and will need further consideration and comment. One issue, as already referred to, is the protection of the landscape of these ridges. As stated we would want to see the assessment of theses to changes to HIGH. 3. Conclusion 3.1 Thank you for the opportunity to comment on the Hoo Development Framework. We would like to emphasise that the Medway Labour and Cooperative Group will have further comments to make as the process goes forward. 3.2 We look forward to the feedback on our comments. In particular, the proposals for sustainable transport within the new development, the proposed AONB and further consultation on the impact of the developments on the Chattenden and Deangate ridges and the surrounding Hoo peninsula. 3.3 Key Comments: • That the landscape assessment of the Chattenden and Deangate Ridges be changed to HIGH to fully recognise their value in landscape terms. • The infrastructure and employment opportunities associated with the new housing developments should be part of the emerging, new Medway Local Plan, and not be allowed to come forward as isolated, speculative applications. • The climate emergency that was declared by the Council in 2019 requires us to address all the issues affecting our local and global environment. For example, the need to use native species in all landscaping, the need to achieve significant biodiversity net gain and the reduction of air pollution. The Council has a Climate Change Members Advisory Group, which should be consulted as the developments go forward, and a Climate Change Action Plan which should act as a key advisory document for the Council and potential developers. • That the landscape of the Hoo peninsula and the North Kent Marshes to the north and east, including Hoo St. Werburgh, is designated as an Area of Outstanding Natural Beauty. • That plans for the Sharnal Street station and rail shuttle to Gravesend be put on hold. Instead, the funding for this should be used toward the provision of an electric bus service. This would operate between Hoo St. Werburgh, the communities on the peninsular and a new Transport Hub at Strood station. • That provision is made within this new sustainable transport network to serve the rest of Medway as funding becomes available.