Letter to Kelly Tolhurst

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20 June 2020

Dear Kelly Tolhurst  

Encouraged by your recent letter in response to our colleague Councillor Linda Atkinson, I have been asked to write to you on behalf of the High Halstow Parish Council and its Neighbourhood Forum, to seek your assistance in relation to Medway Council’s approach to development on the Hoo Peninsula and, in particular, their refusal to disclose to us or to discuss with us the details of the proposals for transport infrastructure on the Peninsula.  We write to you as our local MP, but with the  pride of knowing that you are also Minister for Transport in the Government.  

The High Halstow Neighbourhood Forum is currently preparing a Neighbourhood Plan for the Parish of High Halstow under the provisions of the Localism Act 2011.  This is likely to include identifying substantial areas of land for new housing.  As you may be aware, the most recent draft of the emerging  Medway Local Plan seeks to allocate land for about 12,000 new homes on greenfield land on the Hoo Peninsula, with about 800 new homes proposed for High Halstow, more than doubling the population within the plan period and in addition to substantial development already permitted. 

The Peninsula has only one serious road access; the A228 Peninsula Way.  Serious congestion occurs, particularly at Four Elms junction and roundabout in both the morning and evening peak hours and the Four Elms area suffers from serious air quality problems as a result.  When the A228 is closed, as happens regularly, by a serious accident or other obstruction, the Peninsula is effectively blocked off from the outside world. High Halstow itself is served by narrow rural roads with passing places and no facilities for pedestrians or cyclists.  High Halstow is poorly served by public transport. Development in the villages of High Halstow and Hoo in recent years has been opportunist, taking the form of individual applications with no overall masterplan or framework for development.  The result is piecemeal planning with poor quality development.  In a recent answer, planning and regeneration officers were unable to identify a single example of good design on the Peninsula, despite the rash of permissions in recent years.  A large part of the problem is the absence of an up to date Local Plan, and no masterplan or design guide.  The Regulation 19 draft Local Plan is continuously delayed and is entirely contingent on a Housing Infrastructure Fund grant of £170 million principally to provide new or improved roads and other transport links including a rail link to Gravesend and the Medway towns with onward connections to London.  However, the prediction is that the new rail link will provide a modal shift from use of the car to rail of only 8%.  The Parish Council are well aware of the need for new housing in Medway and for improvement to transport infrastructure. We are also aware that this must be balanced with need to protect and enhance the exceptional biodiversity, heritage  and landscape resources that the Peninsula contains. 

We recognise that it is a central plank of Government Policy to include people and communities in decisions about their future, rather than to exclude them as the planning process has tended to do in the past.  The Localism Act was passed by Parliament with that express objective in mind and it is reflected in the National Planning Policy Framework. 

With this background in mind, the Parish Council and Neighbourhood Forum had hoped to be able to participate fully in the preparation and planning of proposals for development and transport infrastructure on the Hoo Peninsula, together with and alongside  its neighbouring Parish of Hoo St Werburgh, which bears to brunt of the Medway housing proposals in a proposed new “Rural Town”. 

To inform our participation in the process, we both had sought information from Medway Council, and, to  a lesser extent, Homes England, about the specific proposals and the environmental impacts of those proposals in the HIF bid that would most affect our communities. 

Instead of providing information to assist our involvement, we have been dismayed to be met with a wall of what we can only describe as direct obstruction and hostility from Medway Council, together with the publication of a document called “Planning for Growth on the Hoo Peninsula” which is most remarkable for its failure to provide any information of substance about what the Council is proposing. 

In particular Medway Council have directly refused to answer our questions about the details of the HIF funded infrastructure and their environmental impacts, claiming, as an exemption, that to do so would affect their ability to make decisions.  It is their clear and stated intention to ensure that the details of the transport infrastructure proposals and their environmental effects are not disclosed to us until after the HIF agreement with Homes England is signed, presumably to ensure that we are not put in a position to be able to question any of the proposals subsequently.  Not only is such behaviour  contrary to the objectives behind Localism and the legislation that Parliament and the Government has put in place to secure local community involvement in the planning process, but it is also directly frustrating the Parish Council and the Neighbourhood Forum in preparing our Neighbourhood Plan. We have been astonished to find the leader of the Council, Councillor Jarrett, describing the very limited responses we have had from the Council as “clear and continued engagement with the local community”.  He has had no engagement with the Parish Council and the officers’ engagement has been limited, slow and largely unhelpful, being mainly directed to ensuring that we are not informed about details of the HIF proposals and their impacts.  

Of course, the statutory procedures that will accompany the Local Plan will allow for the statutory public consultation and participation in that exercise, in due course, but all the indications are that Medway Council does not intend to open up the content of the HIF programme to public discussion at any point prior to its final agreement with Homes England.  The content of the HIF programme will therefore dictate and severely limit the options available at the Regulation 19 stage of the Local Plan. The HIF programme for Hoo has been drawn up to provide the transport infrastructure that would support a Regulation 19 plan which has yet to be published and whose environmental impacts have not yet been assessed.  Yet it will inevitably pre-determine and severely limit the scope of any modifications that the Inspector will be able to make in order to ensure the Plan is “sound”.  The proposals for the Peninsula are to be largely fixed by the HIF agreement and we, and the Inspector, will be faced with a stark choice between going along with the HIF proposals (whatever they turn out to be) or having no Local Plan at all.  The results of years of failure to deliver a Local Plan have already disfigured the Hoo Peninsula with inappropriate and poor quality development unsupported by essential adequate infrastructure in terms of education, medical facilities and the availability of local and accessible jobs, services and facilities. 

We have suggested that this would best be achieved by the provision of a detailed masterplan incorporated into the statutory process as an Area Action Plan for the Hoo Peninsula, so that we can see exactly what is proposed and how it will affect our local communities.  That suggestion has been met only with silence from Medway Council.  

As things stand, the behaviour of Medway Council, who continue to treat the inhabitants of the Peninsula as some kind of backward indigenous colony incapable of participating seriously in the planning of our own future, and the Peninsula as a derelict wasteland, crying out for new development,  is raising fear and disillusionment in the democratic process. 

We therefore respectfully request that you intervene to assist us by ensuring that the HIF agreement between Medway Council and Homes England is not signed until the Parish Council and the local communities most affected by the proposals are consulted fully on the details of the HIF Infrastructure programme and its environmental effects have been assessed and published. 

Yours sincerely

George Crozer
High Halstow Parish Council

PS. The Neighbourhood Forums hold regular combined virtual meetings. I have been asked to invite you to join us, even if only for a few minutes, to discuss these issues. 

Development at High Halstow

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Bessies Lane High Halstow
Bessie’s Lane

Development of High Halstow

Coming Forward.

Developers are stepping up efforts to bring forward development in High Halstow ahead of the Local plan and our Neighbourhood plan.

Esquire Estates has now presented proposals to The Neighbourhood Plan Committee for 30 new homes at Sharnal Street. Although we like the design we have serious concerns about sustainability and reliance on the emerging Local Plan and HIF.

Redrow is beginning to engage with Medway Council ahead of an application for around 760 homes on the land East of the village between Christmas Lane and Britannia Road.

Medway Council have been given a target from Government to build 38,000 new homes by 2039.  Medway Council are planning to build around 12,500 of these new homes on the Hoo Peninsula in Hoo and High Halstow. 

However, It is not a done deal!

The new homes cannot be built unless they are sustainable, and that means: Sustainable road access, sustainable public transport and sustainable ecology.  Medway Council plan to do this with the help of the Housing Infrastructure Fund HIF. The fund (£170M) will have to bring forward that sustainability by 2024 before new home can be built. 

We do not believe the proposals are sustainable.

  • We do not believe they have done it correctly!
  • We do not believe that any assessment has been carried out to assess the effect of 12,500 homes on our Peninsula’s internationally protected ecology.
  • We do not believe the proposals take an account of the Paris Accord on Climate Change.
  • We do believe that Medway Plans for the Hoo Peninsula are ignoring The National Planning Policy Framework.

How has Development benefited the Peninsula.

In the meantime, because Medway have failed to produce a Local Plan there is no longer any specified allocation of building land. This leaves us vulnerable to developers.

During the past two decades we are at a loss to name any net gain in amenity or sustainability that new development has provided. In fact, all we have gained is the loss of our much loved and used Deangate Ridge golf course.

Commitment.

The Parish Councils of High Halstow and Hoo are united in their attempt to curtail the development of the Hoo Peninsula and ensure that whatever development is brought forward is the very best it can be and provides real sustainability.

We have been delighted with the response you have already made to our call to action and are encouraged by the response to that call from our MP Kelly Tolhurst.

Keeping up the pressure.

We must keep up the pressure though and ask you to write again to Kelly Tolhurst, to Medway Council and/or to our Ward Councillors. For more information and ideas for your letters please see other pages for our letter of objection to the Sharnal Street proposals and letter to our MP Kelly Tolhurst.  Further material and question are in the article in last month’s High Halstow Times.

Please comment to proposed developments by:

  • Writing to Dave Harris, Head of Planning at Medway Council or email Dave.Harris@Medway.gov.uk  
  • Writing to Kelly Tolhurst, MP for Medway or email Kelly.Tolhurst.mp@parliament.uk; and/or 
  • To make comments or objections on planning application go to www.HighHalstow-pc.gov.uk click on the Planning Tracker tab

New Provider at St Werburgh Medical Practice

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A new temporary provider has been put in place at St Werburgh Medical Practice in Hoo, following the CQC’s recent urgent enforcement action meaning the registered provider cannot currently see patients.

Medway Practices Alliance (MPA), the GP federation that brings together practices and GPs from across Medway to develop quality healthcare, now has staff based at St Werburgh Medical Practice, Bells Lane, running the surgery.

MPA is also working with neighbouring practices The Elms Medical Centre, Tilley Close, and Highparks Medical Practice, Park Side, Cliffe Woods, both of which will be supporting MPA with providing patient care if the need arises.

Wilf Williams, Accountable Officer at NHS Kent and Medway Clinical Commissioning Group (CCG), which plans and buys health services, said: “The most important thing to note is that patients do not need to take any action. We are very grateful to MPA, The Elms Medical Centre and Highparks Medical Practice for stepping in at short notice to ensure services are maintained and any disruption to patient care is kept to a minimum. We had to put a temporary solution in place for a couple of days following the CQC action but in under three working days, we have a new provider ready to see patients.”

CQC inspectors visited St Werburgh Medical Practice on Friday 19 June 2020. As a result of this inspection, the CQC took urgent enforcement action at 5pm on Wednesday 24 June to protect patients using services there, and also in their branch surgeries of Stoke Village Hall and the Yellow Suite at Balmoral Gardens Healthy Living Centre.

The registered provider has been in place at St Werburgh Medical Practice and its branch surgeries since 1 September 2018, providing care for some 11,000 patients. The other practices at Balmoral Gardens Healthy Living Centre are unaffected by the CQC’s decision and operating as usual, including Green Suite.

Wilf Williams said: “Now that MPA is based at St Werburgh, patients will be able to book appointments and get their prescriptions as usual, including those who use apps such as Patient Access. Due to Covid-19, many appointments are currently being conducted virtually but if patients need to see a healthcare professional, that can be arranged by calling the main surgery. As the situation develops we may need to call on other nearby surgeries for support but patients will be seen at their own surgery wherever possible.”

Clinics at the branch surgeries will also be available soon but in the meantime, patients can call St Werburgh Medical Practice to arrange an appointment.

Wilf Williams continued: “We are trying to keep patients up-to-date with what has been a fast-changing situation so I would advise those registered at St Werburgh to keep an eye on the CCG’s website and social media channels. As the CQC took urgent action over concerns about the safe delivery of services, unfortunately it was impossible to inform patients prior to their decision.”

For the latest information on St Werburgh Medical Practice, please visit www.kentandmedwayccg.nhs.uk.

Why the Hoo Peninsula?

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Why  is the Hoo Peninsula not  treated as an equal part of Medway?  Do you get the feeling we are being treated unfairly by our Local authority? Do Medway Councillors look across the water at the  Hoo Peninsula and  see it at as an industrial waste land ripe for development.?

Medway Council have just refused outline planning on the AC Goathams, Pump Lane development in Rainham after 1000s of objections to build 1250 houses.

Medway’s Labour Party said… “A very sensible decision, we need housing in Medway but it’s got to be the right housing in the right place and this proposal was not that” ….. We hope we can rely on the Labour Party for support when  applications come forward for 12,000 houses on the wholly inappropriate Hoo Peninsula Medway’s most internationally protected asset.

MP Kelly Tolhurst said in response to a recent letter from a resident… “I have also been following the Council’s progress with their Local Plan closely, and have been disappointed that they have kept pushing the date when they will release the draft plan as this is integral to shaping our future in Medway. I know that the threat of development hangs over the Peninsula and at a time when we are without a Local Plan, it is important that we continue to come together as a community to fight proposals that will only damage the fabric and environment of our area and strain our local infrastructure and services. I fully agree with your concerns about the existing traffic congestion on the Peninsula and the difficulties this already causes to residents across the area, even without the addition of more homes.”

Medway Cabinet

In the meantime  Medway Council’s Cabinet is keeping the people of the Hoo Peninsula totally  in the dark about its HIF Bid. It is completely unacceptable that Medway Cabinet are pressing ahead with proposals for major transport infrastructure to serve 12,000 new homes on greenfield sites on the Hoo Peninsula without being willing to tell us :-

The environmental impact

The effect of traffic emissions, even though the Four Elms area is an air quality action area.
The location and alignment of the new roads and roundabouts.
Whether they considered the need for new development and infrastructure to be zero carbon by 2050.

Refusal to answer questions


They have refused to answer questions about what they are doing and say they will not tell us until after the deal with Homes England is signed and sealed.
This is entirely contrary to the principles of democratic decision making. The Council’s plans, being cooked up without consultation, behind closed doors, in the town hall will cause immense damge to the rural character of the Hoo Peninsula.  The Cabinet is keeping it secret from those most likely to be most affected by this massive and damaging project. We demand to see a masterplan for the project and it should be shown to the people of Hoo before the Council commits itself to this project.


Four  specific questions for Medway Council


Why has the Council refused to answer the questions asked by HHPC about the  Environmental Impact Assessment?


Why will you not answer questions of the HHPC about  the location and alignment of the proposed new roads and roundabouts?


Why will you not answer questions of HHPC about emissions from the extra  traffic to be generated by the massive new development?


Why has the Council refused to say  whether they took account of the Paris Accord on reaching zero carbon by 2015 in making the  HIF bid ?


Re-Opening of High Street Safety

Hoo safety
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Re-opening our High Streets Safely



As you will be aware as from Monday 15 June 2020 non-essential shops will be able to reopen. In order to prepare for this my Town Centres team have been working extremely hard on a plan to ensure that our high streets are ready.

To date we have undertaken business and consumers surveys, liaised with Kent Police and are working closely with colleagues across the Council to implement the following;

Communications Plan – Press release and social media
Guidance Pack for Businesses – with links to a Toolkit
Social distancing signage
Social distancing stewards (for the first two weeks, then the need will be re-assessed)


Traffic, road and pedestrian high street management measures
Cleansing programme

We are keen to engage local Ward Members in this work to ensure that the high streets open safely and would welcome your support in sharing this message with your local communities.

Dawn Hudd 

Medway Council

Medway Council refusal to engage over HiF bid

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Medway Council the HIF Bid and Growth for Hoo and a refusal to engage
Sounds like a soap opera episode doesn’t it? But this drama is been played out right now and right here on The Hoo Peninsula.


The HIF £170 million grant potentially  makes Medway the biggest regeneration zone within the Thames Gateway. 
Once the deal is signed it will unlock a programme to build 10600 houses on the Hoo Peninsula. Not in the towns but here on our doorstep.  

We have the right to know how it will affect us 

 Peninsula Ward Councillors, Parish Councillors and members of the public have been asking Medway Council a series of basic questions about the plans that will affect our health and way of life over the next 30 years. The response we have had so far has been completely inadequate, to be frank Medway is conducting an exercise of evasion and point blank refusal. 

Instead Medway published a glossy brochure “Planning for Growth on the Hoo Peninsula”.  A developers sales brochure using stock photos of developments around the UK. Very few real images of the Peninsula and certainly :–

  • No pictures of dozens of parked HGV’s and the human waste that seem to accompany them. 
  • No pictures of the destruction of the  golf course.
  • No mention of overrun hard working GP services.
  • No mention of  our council run children’s services in special measures.
  • No details of the growing air pollution problems at Four Elms Hill.
  • No real information about housing numbers in the the areas .
  • No details of what real infrastructure will be provided at each stage.

My response to Medway Council

 The Planning for Growth on the Hoo Peninsula Consultation 2020 – Medway Council Local Plan
I most strongly object to the emerging Medway Council Local Plan and Medway Council’s current Development Strategy with regards to the development of a “Small Rural Town” around Hoo and Chattenden.

 I note that Hoo Parish Council will be making a full response and representation to Medway Council when they publish their draft Neighbourhood Plan and will also be presenting a comprehensive report, including evidence and statistics to the Independent Examiner and the Secretary of State. 

A very shiny and factually incorrect document has been produced. It’s a developers  sales pitch and bears no resemblance to Hoo and the way developments have destroyed the area.

Most of the  photographs are not of Hoo but rather they depict the “fairytale Medway” is trying to sell to the people of Hoo. This document lacks facts in every chapter and has no details of how many houses and where they will .

Residents have expressed time and time again that they have no wish for this level of development without a full assessment of the impact and a proper ‘Area Action Plan’ is produced to which they can have a real and meaningful input. Only  by a full consultation with the people of the Hoo Peninsula and listening and acting upon that consultation will residents become partners in a scheme of this magnitude. We cannot achieve the vision set out in this fantasy consultative document.

It is obvious from recent developments that Medway Councils local plan is in fact a developers led plan and that commercial priorities will influence and control the large number of developments.


Protection of the Ecology that surrounds and encompasses the whole of our Peninsula is crucial to the health and well-being of the whole of the Medway,  Kent and beyond. “Planning for growth on the Hoo Peninsula“ and the Local Plan does nothing to protect our ecology and makes no mention of the fundamental need to asses the impact of such a large number of homes..

The Local Plan must avoid harming the natural environment and protect the best of our heritage. The inclusion of the Hoo Peninsula into the Kent Downs AONB is a way forward of protecting and developing our natural and historical area with its  ancient woodlands,  grasslands intertidal habitats and marshes, all of which are of national and international importance. The Peninsula was not included in the Kent Downs ANOB in the late 1990’s although it is an obvious inclusion especially being a natural escarpment of the North Kent Downs.

Inclusion in AONB would not be a deterrent to development.  It demands a better quality of build and the use of materials which are integral to the character of the area and is harmonious within the landscape. However, this of course should not be seen as a reason not to build “affordable housing”.  In fact it could and should lead to a growth in community led rural housing.  Much of this type housing should be  ring fenced for people with a link to the Peninsula or work here. Providing this type of housing would enable young people and families to remain in close to home and this in turn benefits the whole community.

We need to encourage the vast numbers of empty homes in Medway back into the housing market.  Have all of the  many homes, flats and apartments above shops and maybe ex-military homes and government houses  been identified and included into local housing needs?

Whilst Medway planners talk up cycling routes and public transport, we all know that for all new rural developments, the private car is the chosen form of travel being more reliable and for many the only option.  This has a knock on effect for our air quality. Let’s not forget that during the construction of these houses, rail station and roads the concentrations of air pollutants will be exacerbated.  No suggestions to reduce this impact has been made for the movement of construction materials during building and  the thousands of tons of waste removed offsite  by rail, road and water. How does the Local Plan mitigate for the the Carbon targets agreed in the Paris Accord?.

The rural town this plan talks about for Hoo creates many problems, the village has lost its banking facilities and what town can survive without banks. Our stand alone Post Office with sorting office used for the whole Peninsula has gone, along with our Police Station with no local police contact point. What town would you like to live in without a proper police presence. And of course this plan has not included any housing numbers for each of the neighbourhoods mentioned, making it very difficult for people to get a sense of the scale of destruction of our Peninsula.

School and school places must keep up with all these new developments and new communities as soon as they are planned and NOT after. These school places must be ring fenced for local children to prevent excessive travel.

The closure of Deangate Ridge Golf Club, a massive social and sporting area is at odds with improving sports, social facilities and well being. Why was it not recognised that Deangate Ridge should be a centre for sports, and well-being? A Peninsula sports and leisure centre is imperative.  Deangate Ridge  could become a Country Park that includes a  swimming pool, indoor sports and fitness centre. This would go a long way to create health and social well being across the whole Peninsula.

Hoo Peninsula has a rich history of agriculture and fruit farming and these fields and orchards should be protected.  Over the last few years these are falling to development and the Local Plan should protect such areas. The retention of high quality farm land is a priority, once concreted over they are lost forever. Large scale development without  thought of the demand on fresh water supply, which we all know is a finite commodity, will make things  worse. Are there any plans to protect surface and groundwater resources?What plans are there for the treatment of the obvious massive increase in waste water?


Air quality is a major concern. Monitoring of air quality seems very minimal and any increase in vehicle transport particularly HGVs will have exacerbate levels of nitrogen dioxide. What measures are in place to monitor ongoing air quality?
Public transport on the Hoo Peninsula is abysmal and the inclusion of a rail service has been added as an afterthought. There is nothing to suggest a bus terminal at the proposed station therefore encouraging car movements across the Peninsula. This will not help air quality. Why is there no mention of utilising the rail link to take HGV traffic away from Kingsnorth by having goods transported by train? Why is there no thoughts on river usage around Kingsnorth? Would the remote rural areas of the Peninsula be better served by mini buses to and from a bus hub at the new station or Kingsnorth?

Healthcare is one of the major concerns to people of the Peninsula and it is important that provision is made for a healthy living centre or other supplementary healthcare facility. This will take away the constant need for travel to Medway Maritime which is becoming difficult for the elderly and disabled. This would of course take pressure off this very busy hospital. We cannot ignore the fact that the life expectancy for Medway residents is lower than the average for England.

Any encroachment of our villages beyond their present envelopes must be avoided as each and every village of the Peninsula has its own character and the green buffer zones between villages must be preserved and enhanced . It is with this that comes the problem of developers using the cheaper option of contributing to existing open spaces, rather than incorporating new open spaces within developments

Developers should be encouraged to use distinct character of the area and not just squeeze as many dwellings on a site as possible.  People need to be comfortable with their new surroundings. The inclusion of communal space for all residents is essential The Coronavirus virus emergency has shown the need for local and domestically  grown food, which help with supply and mental well-being. More allotments and larger gardens should be supported and advice given to developers to create these. 

Four Elms Hill,  the gateway to the Peninsula has been upgraded in the past but it has never kept place with development. The provision of a relief road, and new and upgraded roads is the latest promise.  I and many residents are believe  that these latest suggestions, which KCC have commented will be inadequate,  will be insufficient for the residential development proposed and woefully inadequate if you add the vast amount of commercial development being undertaken and proposed at Kingsnorth.

Medway Council are vastly under estimating the investment in transport infrastructure required to sustain a development on the Peninsula on this scale.  

Resident will never agree to 12,000 extra houses here and like me are incensed by Medway Council plans to that the to concrete over our unique Peninsula at all costs.

These plans for changing Hoo village into a rural town (whatever a rural town now is) are unsustainable.

Ron Sands
Hoo Peninsula Ward Councillor

Peninsula Post latest

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My original thoughts on this has been widely supported by all Peninsula Parish Councils, Ward councillors Cllr. Filmer, Cllr. Pendergast , Medway Cllr Simon Curry and our MP Kelly Tolhurst (Parliamentary Under-Secretary of State at the Department for Transport).  

RSPB,  Kent Wildlife Trust and officers at Medway Council have also been very helpful and supportive. Of course, progress has taken a bit of backward step because of the Coronavirus emergency.

It has become evident after much discussion that an Area of Outstanding Natural Beauty [AONB] would be a better and more appropriate designation.

So what is the difference between an AONB and a National Park ?
AONBs and National Parks are actually of equal importance for landscape and scenic beauty, the difference is that AONBs exist for the purpose of conserving and enhancing their natural beauty. National Parks, in addition to this, have a second purpose – To promote understanding and enjoyment of the area’s special qualities by the public. Because of this extra (and substantial) layer of responsibility they have their own independent National Park authorities with full planning powers running them.

AONB designation usually covers a wide area and many types and uses of land. Not all parts of an AONB are necessarily open to the public. In fact, most are not, as they are privately owned just like anywhere else. Towns and villages are sometimes included, and often small areas which are not at all beautiful get included too, with a secondary aim of meeting the need for quiet enjoyment of the countryside and having regard for the interests of those who live and work there.

We are continuing with the work behind the scenes and hope to bring you news as it develops. In the meantime please indicate your support be completing the survey if you haven’t done so already.

Should the Peninsula be a National Park
First
Where do you live

Peninsula park update

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My original thoughts on this has been widely supported by all Peninsula Parish Councils, Ward councillors Cllr. Filmer, Cllr. Pendergast , Medway Cllr Simon Curry and our MP Kelly Tolhurst (Parliamentary Under-Secretary of State at the Department for Transport).  

RSPB,  Kent Wildlife Trust and officers at Medway Council have also been very helpful and supportive. Of course, progress has taken a bit of backward step because of the Coronavirus emergency.

It has become evident after much discussion that an Area of Outstanding Natural Beauty [AONB] would be a better and more appropriate designation.

So what is the difference between an AONB and a National Park ?
AONBs and National Parks are actually of equal importance for landscape and scenic beauty, the difference is that AONBs exist for the purpose of conserving and enhancing their natural beauty. National Parks, in addition to this, have a second purpose – To promote understanding and enjoyment of the area’s special qualities by the public. Because of this extra (and substantial) layer of responsibility they have their own independent National Park authorities with full planning powers running them.

AONB designation usually covers a wide area and many types and uses of land. Not all parts of an AONB are necessarily open to the public. In fact, most are not, as they are privately owned just like anywhere else. Towns and villages are sometimes included, and often small areas which are not at all beautiful get included too, with a secondary aim of meeting the need for quiet enjoyment of the countryside and having regard for the interests of those who live and work there.

We are continuing with the work behind the scenes and hope to bring you news as it develops. In the meantime please indicate your support be completing the survey if you haven’t done so already.

Should the Peninsula be a National Park
First
Where do you live

Norse Planning

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Mr Chairman 

Thank you for the opportunity to address this Planning committee.

Deangate Ridge is a site of the highest sensitivity in the Medway area:

Its is Protected in the Local Plan as an Area of Local Landscape Importance and in an 

area designated as Protected Open Space. 

The site is also adjacent to the Chattenden Woods and Lodge Hill Site of Special Scientific Interest (SSSI). 

It is registered as an Asset of Community Value  which is not mentioned in the report as far as I can see.  It is clearly a “valued landscape” in national policy terms, which should be “protected and enhanced”. I would ask you to refer to  National Planning Policy Frame work  paragraph 170.

The Report does not deny that the development is directly contrary to the development plan and causes harm to amenity but claims that this is outweighed by public benefits of providing what is effectively a depot for Council service vehicles. The report tugs at our heart strings by referring to transport for special needs children an argument used, if I recall when this Council chose to close the site.

In fact the vehicles to be stored there are: 12 small vans, 11 flatbed vans, 12 tippers, 3 tractors, including trailer towing, 38 mini buses  which may increase to 42 and 17 shipping containers, all to be  kept at the site.

There is reference to an alternative sites assessment but no details are provided. The report says all the alternative sites were rejected for various reasons, including excessive costs.

 Can I ask again for a copy of that “alternative sites assessment”?

If this action is just the Council saving money it cannot be a relevant consideration or justification for development that is directly contrary to both national and local policy.

There is also no reference to the shameful precedent that development of this site sets:

Norse – the occupier –  unlawfully moves onto a rural leisure and public open space  site in breach of planning control without planning permission; fells five mature trees and clears open green area; deposits 17  large shipping containers and brings some 76 diesel engine vehicles onto the site. Who gave them permission to do this – the Council?

It then applies for planning permission and offers, in mitigation, to paint the containers green when the weather improves  and replant some trees on the site (not semi mature) .

Government policy is that this kind of behaviour is to be discouraged.

Further, it is conceded by the officers’ report that the development will add to the traffic movements all of which will go through the Four Elms Air Quality Management Area, which already exceeds legal standards.. The vehicles stored on the site are entirely diesel-engine buses vans and lorries and will go  “exclusively” through the Four Elms Air Quality Management Area, mostly in the peak hour – when at its most polluted. 

The Four Elms Air Quality Management Area was declared because it is transport related pollution and exceeded the maximum permissible levels of Nitrogen Dioxide. This development will add to the levels of pollutants already harmful to human health.

 The Council is under a statutory duty to improve air quality in the Four Elms Air Quality Management Area in accordance with its own Air Quality Management Plan;

 Medway now has the second worst air quality in the south east outside London.

 An article in the national press describes official attitudes to this area, the Thames Estuary including the Hoo Peninsula  as if it was some kind of “cultureless wasteland… as if it was a vast brownfield site for which any kind of development can only be counted as an improvement. 

The Report utterly fails to reflect the environmental sensitivity of the site and the mitigation offered is derisory. The development will further degrade the golf club, its landscape  and blight its prospects of being brought back into public use.

Officers are recommending you grant planning permission with no guarantee that the temporary permission (to October 2021) will not be renewed or extended?

I would ask to  refuse the permission or defer the decision pending the occupier providing a full, up to date Alternatives Site Assessment.

Councillor

Ron Sand

Norse planning application at Deangate

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Image by Tony Broad
Image by Tony Broad

In liaison with the Deangate Community Partnership I have submitted further objection to the recent planning application for change of use of part of the Deangate site.

I hope these images and the knowledge that Medway Council ignore the fact  that the entire Deangate site is registered as an Asset of Community Value  inspire you to write and comment to : Planning.representations@medway.gov.uk and say that “Deangate should play a vital role in the Heath and Wellbeing of the residents of Medway and the Hoo Peninsula and not be used for commercial use”.

 

Response from the Deangate Community Partnership on behalf of its members.

Image by Tony Broad
Image by Tony Broad

Proposal: Temporary change of use (until 31 October 2021) of first floor of clubhouse building to office use and temporary use of former golf course car park (until 31 October 2021) for parking of associated office workers cars; minibuses; grounds maintenance equipment / vehicles and storage of 17 Shipping containers.

Location: Deangate Golf Club Dux Court Road, Hoo St Werburgh, Rochester, Medway, ME3 8RZ

Application Type : Full Application.

The Deangate Community Partnership wishes to register its fundamental objection to this development.

It is stated in the Transport Statement that the development  has taken place at the invitation of Medway Council.  This is a retrospective application for development which has already taken place without planning permission and is therefore in breach of planning control and unlawful.

As such, it sets the worst possible precedent and example to other developers and to the community  by carrying out the development first and then seeking retrospective permission once the change of use has taken place.

In a written ministerial statement in December 2015, the then Housing Minister, Brandon Lewis, outlined the Government’s concerns about the harm caused by unauthorised development and announced a change to planning policy to make intentional unauthorised development a material consideration that would be weighed in the determination of planning applications (including retrospective applications) and appeals.  The policy was put in place following concern about unauthorised development in the Green Belt, but applies equally to all unauthorised development, including this proposal.

The fact that the development has taken place with the encouragement of the Council which is also the local planning authority is wholly unacceptable action by a responsible public authority, and is directly contrary to the Government’s policy.

The development is not in accordance with relevant saved policies in the  Local Plan or the National Planning  Policy Framework 2019.

The current statutory Local Plan is the 2003 Medway Local Plan. The site is within the countryside, lying well outside the settlement boundaries. It is a site to which relevant saved policies in the Local Plan would apply. Policy BNE 25 Development in the Countryside is one of the saved policies in the Local Plan  and has been extended by direction of the Secretary of State. It accords with the NPPF and should therefore be given full weight.

BNE 25 states:

Development in the countryside will only be permitted if:

(i) it maintains, and wherever possible enhances, the character, amenity and functioning of the countryside, including the river environment of the Medway and Thames, it offers a realistic chance of access by a range of transport modes; and is either;

(ii) on a site allocated for that use; or

(iii) development essentially demanding a countryside location (such as agriculture, forestry, outdoor or informal recreation); or

(iv) a re-use or adaptation of an existing building that is, and would continue to be, in keeping with its surroundings in accordance with Policy BNE27; or

(v) a re-use or redevelopment of the existing built-up area of a redundant institutional complex or other developed land in lawful use; or

(vi) a rebuilding of, or modest extension or annex to, a dwelling; or

(vii) a public or institutional use for which the countryside location is justified and which does not result in volumes of traffic that would damage rural amenity.”

The proposal does not maintain and enhance the character, amenity and functioning of the countryside, Nor does the development fall within any of the categories (ii) to (vii) in BNE25 above and therefore is directly contrary to the principal countryside protection policy in the statutory development plan. There is therefore a statutory presumption in section 38(6) of the Planning and Compulsory Purchase Act 2004 against the development. The NPPF requires the Council, in determining applications to recognise the intrinsic natural beauty of the countryside.

The development is also directly contrary to the NPPF which seeks to protect existing open space, sports and recreational facilities.

The NPPF statesExisting open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use.

Whilst the development does not involve new buildings as such, the 17 storage containers have a particularly unattractive industrial character and adverse visual impact and are damaging to the rural character and amenity of the area. The development leads to the use of the site for storage of heavy equipment which requires goods vehicles to transport it and which are often parked on the site.

Deangate is a vital part of Medway’s network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. The NPPF requires that applications for development of such sites should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities.

The application fails to support a strong environmental objective by contributing to protecting and enhancing our natural environment. Developing Deangate as described in the application fails to make effective use of land by help to improve biodiversity, use natural resources prudently, minimising waste and pollution or move us towards tackling climate change or a low carbon economy, contrary to the NPPF.

The application describes the Golf Course as “redundant”. This prejudges the question as to whether there is a viable future for the golf club. The use has not been abandoned nor could it be unless a permanent material change of use has been granted.

There is no recognition that the site is part of an Asset of Community Value, which is a material consideration as the site has a social objective in supporting the strong, vibrant and healthy communities of Medway and the Hoo peninsula.  It provides an accessible service and open space that reflects  the current and future needs of health, social and cultural well-being of residents.

The Transport Statement submitted with the application is inadequate as it appears to make no assessment of the effect of goods vehicles on the site which has poor access to the primary road network. It amounts to a short and limited traffic count which does not appear to distinguish the heavy vehicles using the site. Dux Court Road has an alignment that is notoriously narrow and twisting. There is a particularly narrow pinch-point between the site entrance and the roundabout onto Peninsula Way.

The Deangate Community Partnership urges the Council to refuse permission and to use its enforcement powers and take all necessary steps to require the use to cease as soon as possible.

Yours sincerely

For and on behalf of the Members of 

The Deangate Community Partnership (unincorporated body)