Response to HDF Consultation Nov 22

 

Medway Council is currently consulting on their Hoo Development Framework (HDF) plan for the Hoo Peninsula.

You may have attended one of the consultation events locally. The consultation closes on Friday 25th November (this Friday).

Please see a template response below. If you would like to send it as your own response, fill in your details and click submit. You can also add your own comments to the submission if you wish.

Your response will go directly to Medway Council’s Planning Department and you will also receive an email showing the response you have sent. Please see the template submission in full below.

 

Dear Medway Council,

This is a representation in response to the Hoo Development Framework consultation and should be recorded as such – the consultation ran between Friday 23rd September and Friday 25th November 2022.  

I strongly object to the Hoo Development Framework and what is proposed.  This objection is split into two parts:  the first is fundamental issues and concerns with the rationale behind the Hoo Development Framework and the second is strategic issues and concerns with the contents of Hoo Development Framework itself.  

Fundamental issues and concerns with the rationale behind the Hoo Development Framework and pre-empting the supposedly objective and fair Local Plan process.  

The Council has recently issued a new Call for Sites and will be carrying out a Regulation 18 consultation in Summer/early Autumn of 2023 on “Alternative Development Options”.  This new consultation suggests that a range of development options and locations will be fairly assessed, including promoted sites in Capstone Valley and around Rainham – referred to as urban extensions.  With this in mind, the Council should also be carrying out development framework consultations for those areas as they may potentially be taken forward in the same regard as the Hoo Peninsula option.  

The scale of housing development envisaged in the Hoo Development Framework is dependent on this spatial strategy being selected as the most sustainable and deliverable option once the Local Plan process has concluded – this process will include a public inquiry and the independent examination by an Inspector.  

The Hoo Development Framework is enabled by the Council’s failing £170m taxpayer-funded Housing Infrastructure Fund (HIF) Project, which is critically required to increase transport infrastructure capacity, effect a fundamental transport modal shift from road to rail and mitigate environmental harm caused by this scale of development in the most environmentally sensitive part of the borough.  

The Council can’t make firm decisions on the location of large-scale housing development, with the Hoo Development Framework, without properly assessing and considering other reasonable alternatives first.  These options are less environmentally impactful and have better access to existing infrastructure, such as major motorways and mainline railway links, as well as existing employment areas and services.  These options also don’t require £170m of taxpayers’ investment.  

The Council’s planned “Alternative Development Options” Regulation 18 consultation is seen as acceptance that there has not been proper consideration to date of reasonable alternatives to large-scale development on the Hoo Peninsula.  The consultation and adoption of the Hoo Development Framework, prior to the Local Plan concluding, is not acceptable and predetermines the outcome of what is supposed to be an objective and fair process.  

At present, because of a lack of crucial supporting evidence, there is no credible explanation or justification for such a significant and disproportionate amount of development allocated for the Hoo Peninsula.  This is particularly compounded by the fact that developers in areas such as Capstone Valley and around Rainham appear to not be receiving the same level of consideration for their proposals as developers on the Hoo Peninsula – If they were, there would be consultation on development frameworks for their proposals.  

An explanation for the Council’s approach to date is the political reality of the situation, whereby a majority of elected Medway Councillors, who predominately live in and represent wards in Chatham, Gillingham and Rainham, would never sanction a development framework consultation or significant allocations in a Local Plan for their own areas – despite these options being a more sustainable approach.

Strategic issues and concerns with the Hoo Development Framework itself that are unacceptable or would not be acceptable elsewhere in the borough.  

Chattenden Barracks:  The fact that Homes England is promoting this land for housing development (500 homes) is very concerning when they the fund the Council’s HIF Project, to increase infrastructure capacity – which enables this specific development site to come forward.  The proposed HIF Project road and 500 homes will harm the Lodge Hill National Nightingale Bird Sanctuary SSSI (Site of Special Scientific Interest), due to their close proximity to the protected wildlife site.  These two proposals are contrary to policies in the National Planning Policy Framework (NPPF).  Organisations such as Natural England and the RSPB have recently raised concerns with the Council about other development proposals adjacent to the SSSI, as well as the Council’s general approach to housing development on the Hoo Peninsula in previous consultations.  The allocation of 500 homes, and the proposed HIF Project road, need to be removed from the Framework.  As has been mentioned by the RSPB, it may be more acceptable to place non-residential development in this location such as a non-emergency hospital to take pressure off Medway Maritime Hospital.  

Deangate Ridge:  The entire site of the former golf course needs to be allocated as a country park, with an element of Golf sport, for the benefit of Hoo Peninsula residents and residents in Strood and Rochester – a country park predominately for this side of the River Medway and borough.  It would not be acceptable to develop such a large Council/community-owned asset in other parts of the borough, so why is it acceptable on the Hoo Peninsula?  Pedestrian and cycling access needs to be improved and made safe from the top of Bells Lane, along Dux Court Road and into Deangate Ridge.  Similar to the Chattenden Barracks development and HIF Project road proposals, the proximity of housing development to the SSSI has raised significant concerns with organisations such as Natural England and the RSPB.  Deangate Ridge is very unlikely to be developed due to the environmental sensitivities of the adjacent SSSI.  The Council will also need to adopt the long-advocated 400m minimum buffer between the SSSI and new housing development.  This buffer will exclude many of the housing allocations in the Framework – these allocations can be sited in less environmentally sensitive locations across the borough.  

Chattenden Valley:  Despite the Framework wanting to protect open countryside on the Hoo Peninsula, the existing green lung and corridor between Chattenden and Hoo will be entirely consumed by the development allocations and a new spur road proposed in the Framework.  There won’t be a clear and acceptable green separation of local communities as the Framework amounts to urban sprawl and urbanisation.  This scale of gap removal between two settlements would never be acceptable in other parts of the borough, particularly Capstone Valley.  In fact, the development proposed in Capstone Valley, as a worst-case scenario, does not envisage consumption of the entire gap as proposed here in Chattenden Valley.  Along with the 400m buffer mentioned above, a large number of development allocations will need to be removed from the Chattenden Valley between Chattenden and Hoo.  The new spur road was not originally part of the HIF Project and has come about since the original bid because of later consented commercial/industrial development at Kingsnorth – this consented development has worsened the local transport capacity and effectiveness of the proposed infrastructure schemes.  This new spur road needs to be removed from the Framework as it visually harms and urbanises the Chattenden Valley.  

Railway station area:  A large concentration of development is envisaged around the proposed HIF Project railway station, with ugly and tall electricity pylons running right through the middle of this new proposed community – will prospective new residents be attracted to live in this area?  The Railway Scheme is unlikely to succeed and come to fruition, therefore this concentration of housing development, and supporting services, around the station needs to be removed from the Framework.  Although the Council and Framework intends to protect the green lung and corridor between Hoo and High Halstow, this is not convincing when considering that the placement of a railway station itself on the outskirts of Hoo will highly likely result in further housing development proposals coming forward next to or near to the station.  With the Chattenden Valley being destroyed by development, what is referred to as the Sharnal Valley between Hoo and High Halstow will also be destroyed in due course with further housing development as a result of the railway station.  

Kingsnorth expansion:  The expansion of the Kingsnorth Industrial Estate into surrounding high-grade and productive agricultural land is unacceptable.  The green lung and corridor that currently exists between Kingsnorth and the built-up area of Hoo will be completely removed by the Framework – housing development is envisaged to expand eastwards from Hoo and industrial development is envisaged to expand westwards from Kingsnorth – with no green lung or corridor between the two.  It’s also difficult to see how prospective new residents will be attracted to live right next to an industrial estate.  The expansion of Kingsnorth Industrial Estate needs to be removed from the Framework and this type of commercial/industrial development should be constrained to the footprint of the existing very large brownfield site.  A green lung and corridor must exist between the built-up area of Hoo and the Kingsnorth Industrial Estate.  

Vicarage Lane:  The Framework places new community and sports facilities east of Vicarage Lane in isolation.  This is unacceptable for a visually sensitive and generally inaccessible location.  Instead, such facilities should form part of a housing development site and be placed in a more suitable and accessible location.  

Cockham Community Parkland and Hoo Wetlands Reserve: Both of these proposals intend to mitigate the environmental harm caused by allocating such a large concentration of housing development on the Hoo Peninsula.  The proposed sites will also attract and attempt to satisfy recreational pressure from such large-scale housing development.  The location of the parkland and reserve is very concerning when considering the recreational disturbance that will be caused to the internationally and nationally protected wildlife site to the south of Hoo.  The Council recognises the serious issue with recreational disturbance to the Special Protection Area (SPA), Site of Special Scientific Interest (SSSI) and RAMSAR site which is the Medway Estuary and Marshes but offers no detail or evidence of the mitigation required.  At least, both of these proposed Strategic Environmental Management Scheme (SEMS) sites need to be removed from the Framework and the land should remain as productive agricultural land.  This agricultural land itself currently provides a buffer, with very little recreational use, between the protected estuary and marshes and the built-up area of Hoo.  New large parklands and recreational areas should instead be placed in the Chattenden Valley (with links to Deangate Ridge Country Park), away from the protected and sensitive estuary, acting to separate Chattenden and Hoo with green infrastructure. 

Lodge Hill Countryside Site:  It’s not entirely clear what the purpose of this specific SEMS site is.  It appears that what is being proposed here is non evidenced based compensatory Nightingale habitat due to proposed development of Deangate Ridge that threatens the SSSI.  In other words, the Framework is attempting to shift the Nightingale’s habitat further North in order to try and develop Deangate Ridge to the South.  Similar to Deangate Ridge, pedestrian and cycling access needs to be improved and made safe from the top of Bells Lane, along Dux Court Road and into Deangate Ridge.  Unlike the SEMS sites close to or adjacent to the protected estuary, which is sensitive to recreational disturbance throughout the whole year, seasonal access can be applied here in order to protect the integrity of the Lodge Hill National Nightingale Bird Sanctuary SSSI.  This is so local residents can benefit from recreational use of the sites around the SSSI, for most of the year, without harming or causing disturbance to the SSSI itself.  

Doubling the size of Chattenden, High Halstow and Hoo:  The Framework intends to double the size of Chattenden, double the size of High Halstow and more than double the size of Hoo.  It would not be acceptable in other parts of the borough to double the size of existing communities so why is it acceptable to do it here on the Hoo Peninsula?  The level of growth envisaged and placed upon Chattenden, High Halstow and Hoo will be most dramatic change in the shortest amount of time in their history.  The Framework needs to scale down the proposed development around Chattenden, High Halstow and Hoo and instead allocate this excess development elsewhere in the district on more suitable and sustainable sites – as part of the objective and fair Local Plan process.  

The Hoo Peninsula can play its part in contributing to the spatial strategy of a Local Plan, and supporting the need for housing, with a general dispersed pattern of development across the entire borough (as suggested by the previous Inspector of the Core Strategy) – prioritising the least sensitive and most sustainable sites first, supported by a strong and justified evidence base.  What is currently being proposed on the Hoo Peninsula is clearly unsustainable, unworkable, biased and outlandish, but also very divisive – turning one part of the borough against another.  

Until these fundamental and strategic areas are addressed I can’t comment on the more detailed elements of the Framework.

Kind regards,