Medway Local Plan (Regulation 19, 2025)

Object

Representation ID: 4842

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Greenfield Employment Land Undermines “Brownfield First” Policy

"Greenfield employment land is likely to be more commercially attractive to potential occupiers..."

Let’s get this straight:

Medway Council says it prioritises brownfield development to protect the environment.

Then admits developers prefer greenfield employment sites.

Then... allocates greenfield employment land anyway. Not only is this demonstrably unsound, it is lunacy.

Object

Representation ID: 4847

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The lack of accessible, impact-focused, plain-English content that clearly explained risks as well as benefits falls short of the principles of meaningful engagement in the NPPF and the Council’s Statement of Community Involvement.

Object

Representation ID: 4850

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The claimed alignment with wider strategies (One Medway Council Plan, Health & Wellbeing Strategy, Climate Change Action Plan) is superficial; no clear policy mechanisms demonstrate how Local Plan allocations will deliver those strategies’ objectives. In some cases — e.g., large-scale development on best and most versatile farmland — proposed allocations actively conflict with stated climate, health, and environmental goals.

Accordingly, 1.3.2 overstates the Plan’s evidential robustness and strategic coherence, rendering this claim unsound.

While Council lists input from statutory bodies, residents, stakeholders, the Regulation 18 consultations reached fewer than 0.15% of the population and disproportionately reflected developer and landowner interests.

Object

Representation ID: 4851

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The NPPF requires that the standard method be the starting point for determining housing need, not the end point. Local Plans must then consider whether there are exceptional circumstances that justify a higher or lower figure, such as environmental constraints, infrastructure capacity, market absorption rates, and deliverability. Medway’s plan does not demonstrate that this exercise has been carried out.

2. Outdated or incomplete evidence base
The Strategic Housing Market Assessment underpinning this figure is not transparently published alongside updated demographic forecasts, post-2021 Census data, or realistic infrastructure capacity modelling. Without this, the figure’s legality and robustness are in question.

Object

Representation ID: 4852

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Stakeholders and residents cannot meaningfully comment on environmental impacts without access to the final HRA evidence, particularly where air quality is a known constraint in Medway

SEA Regulations require the SA to assess “reasonable alternatives” in the same level of detail as the preferred option. Evidence shows that alternatives — such as reduced housing numbers, different spatial distributions, or prioritising brownfield — were not assessed on equal terms.

Object

Representation ID: 4853

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The Plan lacks demonstrable agreement from neighboring authorities on strategic matters like housing numbers and impacts, undermining its legal foundation.

If the Inspector finds Duty to Cooperate requirements are unmet, the Plan must be withdrawn or be formally found non-compliant — it cannot proceed under soundness

Object

Representation ID: 4855

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy Overreach Without Deliverability
Policy T27 is commendable in intent but fails to be effective. It sets ambitious objectives for health infrastructure, green space, access to care, and active travel. However, there is no linked Infrastructure Delivery Plan (IDP) or funding mechanism to guarantee delivery. The commitment is rhetorical unless backed by enforceable mechanisms like developer contributions, phasing triggers, and formal agreements with health bodies

Object

Representation ID: 4856

Received: 10/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Introduce VAT relief (zero or 5%) for repair, maintenance, retrofit and heritage works, including lime, timber and stone conservation, to correct the current bias favouring new-build.

Extend/expand the zero-rate for energy-saving materials beyond 31 March 2027, and allow parity for whole-house fabric-first retrofits, especially in deprived areas.

Broaden refund mechanisms (akin to DIY new-build refunds) to qualifying community retrofit and heritage-skills schemes.

Object

Representation ID: 4857

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Guidance,” not policy teeth. For Regulation 19 the Council lists a Health Impact Assessment Toolkit and a Hot Food Takeaway Guidance Note (2025), but these are guidance documents—not binding policy caps within the retail chapter—so they don’t by themselves implement T27’s “control” pledge.

Object

Representation ID: 4858

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

A phasing & triggers schedule for each strategic site (what/when/by whom/cost/funding source).

Confirmed provider positions/SoCG (NHS ICB, education, utilities, highways) aligning capacity and timescales.

A clear contributions methodology (thresholds, calculators, heads of terms) that won’t undermine viability.

Without these, the “phased approach” is not credible and Policy 10.5.13 renders the plan unjustified and ineffective