Medway Local Plan (Regulation 19, 2025)

Object

Representation ID: 4811

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan’s preparation does not clearly demonstrate adequate public consultation integration or adherence to legal duties under the Countryside and Rights of Way Act, Green Belt protection policies, and national planning regulations.
Relies on assumptions rather than demonstrable, verified evidence of actual housing and infrastructure needs. NPPF (2021, paras 104-106) development to locations with good access to services and sustainable transport to reduce reliance on private cars; Greenfield developments involve higher infrastructure costs than urban brownfield redevelopment and Medway’s Local Transport Plan highlights existing congestion issues that are worsened by new developments lacking integrated sustainable transport.

Object

Representation ID: 4812

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

There is insufficient evidence that the Plan’s spatial strategy is underpinned by meaningful community engagement, particularly in respect of impacts on local services, housing affordability, and social cohesion. This absence compromises the Plan’s justification and raises questions on whether it adequately reflects local needs and preferences, as required by the NPPF (para 16).

Given Medway’s designated environmental sites, the Plan’s support for greenfield development must be fully backed by comprehensive HRA and EIA. The lack of transparent, publicly accessible evidence of such assessments undermines confidence in the Plan’s compliance with environmental protection legislation, exposing it to potential legal challenge.

Object

Representation ID: 4825

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Pricing gap significantly narrows the potential buyer pool for new-build homes. This risk is compounded in Medway by the recorded 17% year-on-year increase in “homes ordered but not yet bought” in early 2024–25.
The Plan’s housing trajectory assumes rapid absorption of new-build supply, but market pricing data suggests this is vastly optimistic.

High pricing relative to existing stock increases the likelihood of longer time on market, unsold completions, and stalled build-out rates.

This creates a mismatch between the Plan’s projected housing completions and what is realistically deliverable, undermining the “effective” soundness test in NPPF para. 35

Object

Representation ID: 4827

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Socio‑Economic Risk & Community Cohesion: lessons from Ashford & Gillingham
Ashford’s high‑growth model caused:

Town centre hollowing and loss of independents

Transient HMO/1‑bed population

Social infrastructure a decade behind housing

Gillingham now mirrors this in HMO saturation and benefit‑dependency cycles. The plan as it stands will accelerate Medway decline.

The plan clearly lack safeguards to protect residents housing and employment opportunities. Of note in the plan are infrastructure opportunities and lax housing procedures and legislation that have benefited a number of MPs personally through ownership and change use schemes, and Political Parties through lobbying and donations.

Object

Representation ID: 4828

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Skills and Workforce Link. Policy T4 is silent on ensuring that specialist housing developments contribute to local workforce training in care, nursing, and support services — despite clear skills shortages in these sectors within Medway. This is a missed opportunity.
Not positively prepared – Omits clear links to objective, up-to-date needs data (JSNA, Kent & Medway Care Needs Assessment)

Not effective – Lacks measurable locational/accessibility standards and design enforcement mechanisms.

Not consistent with national policy – Risks approving poorly located or inadequately designed developments, contrary to NPPF paras. 92(b), 93, and 130.

Object

Representation ID: 4830

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Judicial Review risk: Decisions made under this policy could be challenged as irrational or inconsistent due to its vague wording and open-ended exceptions.

Object

Representation ID: 4831

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Not positively prepared – Lacks clear mechanisms to prevent clustering or protect family housing stock in practice.

Not effective – No measurable criteria for over concentration, amenity quality, or parking demand.

Not consistent with national policy – Risks undermining NPPF para. 69, which emphasises planning for a mix of housing to meet community needs.

A loosely defined HMO policy, combined with a lack of effective concentration controls, creates a policy environment that may be leveraged by large-scale HMO investors, including elected officials, at the expense of balanced housing provision. This raises risks of policy capture and erode trust.

Object

Representation ID: 4832

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy proposes intensification of the Cuxton public site without providing sufficient long term:

Environmental capacity assessment (impact on landscape, flood risk, access);

Assessment of site suitability for higher density occupation under environmental health and amenity standards;

Consultation with affected communities, both resident and adjacent.

Criteria for New Sites – Lack of Specificity

Policy T10 currently lacks the legal and evidential foundation required to be considered sound. The updated GTAA is essential — not optional — to justify its policy direction and site decisions

Object

Representation ID: 4834

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan’s employment and economic allocations are not effective or realistically deliverable. Historic evidence demonstrates that Medway Council’s strategic employment projects have repeatedly failed to deliver their stated economic objectives. This undermines the Plan’s projections for job creation and its assumed contribution to sustainable economic growth.

2. Evidence of Failed or Undelivered Economic Sites
2.1 Innovation Park Medway
Promised Outcome: Flagship high‑tech business park at Rochester Airport, expected to deliver c.3,000 jobs.

Investment: Approximately £33 million in public funds.

Object

Representation ID: 4836

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The plan profoundly lacks safeguards and reasonable foresight. The Medway plan as it stands and proposed through procedure and technicalities facilitates:

Over-concentration of the above low-quality uses in certain centres, displacing diverse retail, leisure, and cultural provision.

Loss of independently owned SMEs that keep accurate accounts, are dependent on local or tourist income, and often provide essential services such as repair shops, key cutting, and tailoring.

Closure of long-standing independent and national retailers in Medway’s high streets, including anchor stores such as Wilko, F Hinds Jewellers, J C Rook & Sons, and Chatham’s Tesco superstore.