The Medway plan... some good, some bad?

CPRE Kent has applauded Medway Council’s intention to protect the north of the Hoo peninsula – that wonderful swathe of Cliffe and Cooling Marshes, one of the last remaining areas of tranquillity in the county.
Taking part in the consultation on the Medway Development Strategy, we were keen to applaud this and similar countryside protection policies but did object to some potential scenarios presented in the strategy.
We recognised the constraints facing the council in the development of its new Local Plan, particularly in relation to housing development, but maintain that the government’s proposed methodology for calculating local housing need is flawed.
The methodology is based on market demand rather than need, providing no understanding of how Local Plans can reflect a move from these abstract targets to a realistic, deliverable and sustainable housing requirement.
In Kent, particularly, the methodology is leading to disproportionately high targets that will be impossible to deliver sustainably.
We welcomed the council’s renewed commitment to delivering regeneration of brownfield sites but retain significant concern at the inclusion of Lodge Hill as a strategic option for housing.
We acknowledged the presence of a residual brownfield footprint at this site but stressed that the National Planning Policy Framework is clear previously developed land should be re-used “provided it is not of high environmental value”.
Chattenden Woods and Lodge Hill’s designation as a Site of Special Scientific Interest precludes it from being realistically considered as still brownfield.
The future of the site has received intense media coverage, not least because, with 85 pairs, it hosts the largest population of nightingales in the country.
The development masterplan indicates significant building incursion on the SSSI, while earlier work in support of a withdrawn application made it clear it would not be possible to adequately mitigate harm to the nightingale population.
We suggested that proposed development at Hoo St Werburgh should be broadly supported by the local community and must deliver genuinely affordable housing for local needs, while we also highlighted the fact that the whole region is classified by the Environment Agency as “severely water stressed”.
The future of Medway is clearly far from straightforward.

Friday, June 29, 2018

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document