Medway Local Plan (Regulation 19, 2025)

Object

Representation ID: 4859

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Out-of-date/incorrect baseline. Para 10.6.4 says Medway has 8% gigabit coverage. Ofcom’s latest figures show ~84% gigabit coverage across England in 2024, while independent mapping shows ~92% in Medway—so the 8% claim is plainly wrong and undermines the evidence.

National targets misstated without delivery hooks. Para 10.6.3 cites Government ambitions (standalone 5G to all populated areas by 2030; at least 99% gigabit by 2030) but Policy 10 include no binding local mechanisms (SoCGs with operators, mast/site criteria, coverage triggers, or developer duties beyond Building Regs). This fails the effectiveness test.

Object

Representation ID: 4860

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Replacement isn’t required to be equivalent or better or available before loss.
Healthcare clause is duplicated and poorly drafted.

No delivery hooks. No SoCGs with NHS ICB/education/police, no triggers, no monitoring targets.

Object

Representation ID: 4861

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

A blanket confidentiality clause is unlawful in effect.

Object

Representation ID: 4862

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Medway’s Waste Management vision is aspirational but non-operational. It repeats the Waste Hierarchy without quantified arisings, capacity gaps, or a spatial strategy for new/expanded facilities. There are no measurable targets, site allocations, or safeguards for existing sites/wharves, and no clear decision criteria (enclosure, odour/noise/dust control, HGV routing, buffers). Construction and demolition waste is largely ignored (no pre-demolition audits, circular design, or reuse targets). Developer contributions lack thresholds/calculators, and monitoring/review triggers are absent. As drafted, it cannot guide decisions or secure investment—failing justification, effectiveness, and consistency tests.

Object

Representation ID: 4863

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Chapter 10 of the Regulation 19 Medway 2025 Local Plan is unsound due to its failure to demonstrate a justified and deliverable spatial strategy. The housing allocations lack robust evidence of infrastructure capacity, environmental constraints are insufficiently addressed, and the plan does not align with national policy on sustainable development. There is an over-reliance on strategic sites without clear phasing or delivery mechanisms. Additionally, the absence of a clear mitigation strategy for impacts on protected habitats undermines legal compliance. This contradicts national policy on health, air quality, and climate adaptation (NPPF 104–106, 112).

Does not meet the tests of soundness.

Object

Representation ID: 4864

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

T27 remains a narrative commitment without binding delivery mechanisms or quantifiable health outcome targets. There is no published Statement of Common Ground with NHS Kent & Medway ICB, although they are a statutory consultee with an explicit expectation of health infrastructure contributions. The policy lacks measurable metrics and a transparent equality or impact assessment.
Amend T27 to include protection, adaptive reuse, and business rate or planning relief for venues that demonstrably contribute to community health and circular economic activity, ensuring they remain viable over the Plan period.

Object

Representation ID: 4865

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

Over-reliance on new-build provision for education and training facilities (7.5.1–7.5.9) no clear commitment to retrofitting or re-use of existing heritage or under-used buildings.

Undermines NPPF 197–202, which require great weight to be given to conserving heritage assets and their significance, including through viable uses consistent with their conservation.

Missed opportunity to align education skills strategy with retrofit, conservation, and heritage crafts — especially given the local historic building stock and regeneration areas.

Lack of embedded delivery mechanisms for apprenticeships, SME growth, and specialist training in heritage restoration, retrofit, and sustainable construction.

Object

Representation ID: 4866

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The draft Medway Local Plan is fundamentally unsound because it fails to address the acute skills and literacy deficit that is already damaging the area’s economic competitiveness. Without targeted education infrastructure — including early years capacity, literacy catch-up provision, and adult skills hubs integrated with employer demand — Medway will remain unattractive to high-value businesses and will continue to lose investment to better-prepared regions.

Object

Representation ID: 4867

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? No

Sound? No

Duty to co-operate? No

The NPPF requires Local Plans to be positively prepared to meet economic and social needs, and skills are a core driver of both. Also, the Infrastructure Delivery Plan explicitly covers schools and community facilities.

Object

Representation ID: 4868

Received: 11/08/2025

Respondent: Mrs Gillian Mulloy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Risk to cohesion: Without protective measures, rapid turnover of uses (office to café to gym to private clinic) can undermine local identity, continuity of services, and long-term investment in community assets
Risk to SMEs and local shops:
Investors might exploit Class E freedoms for short-term gain, outbidding local independents for prime space, then flipping uses for higher rents, pushing out small traders.