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12th June 2018


Medway Local Plan: Development Strategy Options consultation


Final Decision-Maker

Strategic Planning, Sustainability & Transportation Committee

Lead Head of Service/Lead Director

Rob Jarman, Head of Planning & Development

Lead Officer and Report Author

Sarah Lee, Principal Planning Officer (Strategic Planning)




Wards affected



Executive Summary


Medway Council is consulting on Development Strategy Options for its emerging Local Plan (2012-35).  The next stage will be for Medway to produce a draft Plan for formal consultation (Regulation 19) before the end of the year. This report sets out matters for inclusion in the council’s response to the consultation, focussing on the proposals’ potential implications for transportation, air quality and the ecology of the borough’s Special Areas of Conservation with additional comments on employment and Gypsy & Traveller provision.



This report makes the following recommendations to this Committee:

1.   That the response to the Medway Local Plan Development Strategy options (March 2018) set out in Appendix 1 is approved.







Strategic Planning, Sustainability & Transportation Committee

12th June 2018

Medway Local Plan: Development Strategy Options consultation






1.1     Medway is preparing a Local Plan which will cover the period 2012-35. It is currently consulting on a Development Strategy Options document which is a third ‘Regulation 18’ consultation following an Issues & Options document in January 2016 and a Development Options consultation in January 2017. The current consultation document and supporting documents are available here:


1.2     The purpose of the current consultation is “to assess the most sustainable approach to meeting Medway’s growth needs”. Four development strategy options are proposed:

·   Scenario 1 - Meeting the housing need of 29,500 homes in line with Medway’s Strategic Housing Market Assessment analysis of the number of homes needed to support the area’s population growth and change up to 2035. The net number of additional homes needed would be delivered on urban brownfield sites (approximately 50%), at the proposed Hoo ‘rural town’ and at the edge of villages (approximately 30%) with some 10% achieved through suburban expansion including in the Capstone Valley and at the edge of Rainham. Although the consultation document is not explicit, it is presumed the balance is projected to come forward on windfall sites.

·   Scenario 2 - Investment in infrastructure to unlock growth. If Medway is successful in bids for major new funding for the area, the speed and rate of development could be boosted on the Hoo rural town with higher density development linked to improved public transport (new rail and bus services) plus improved highways infrastructure. The pattern of development is as for scenario 1, including development at the north western edge of the Capstone Valley and north and east of Rainham. This approach also achieves 29,500 homes.

·   Scenario 3 - Meeting Government’s target of local housing need of 37,000 homes, in line with the Government’s proposed standardised methodology. The consultation document states that there is considerable uncertainty about the ability to deliver such numbers and there are concerns about the infrastructure requirements and environmental implications associated with it. Development at the north western edge of the Capstone Valley and north and east of Rainham would be potential components in this approach in conjunction with very high density development within the urban area. This option has the potential to deliver some 35,961 homes (i.e. a shortfall of 1,182 compared with the standard methodology figure). It would necessitate the more extensive use of employment sites for housing which is likely to increase the rate of out commuting.

·   Scenario 4 – This option incorporates some development within Lodge Hill SSSI. Homes England is preparing a new planning application for this area for up to 2,000 homes with supporting services which would protect much of this designated site for wildlife but would involve some development on some protected areas. Development at Lodge Hill SSSI would substitute for some of the sites in the Capstone Valley.  This scenario could achieve 37,000 homes.


1.3     In respect of employment, the consultation document identifies requirements for 49,943sqm new offices, 155,748sqm industrial floorspace and 164,263sqm warehousing over the plan period. The document reports that these requirements can be met through the consolidation and intensification of existing employment sites, through mixed use developments close to the main town centres and through select new locations.  In terms of the latter category, the document signals a potential new office location close to M2 Junction 4 but provides little detail in terms of scale and exact location at this stage.


Proposed response


1.4     The proposed response to the consultation is included in Appendix 1 for the Committee’s consideration. In summary, the response;


·   Highlights that the (unpublished) transport modelling undertaken by Medway to date does not, as yet, incorporate the specific pattern and volume of traffic generated by planned developments in adjoining boroughs, including Maidstone. Medway has now requested this information from its neighbours and Maidstone’s information has been supplied.  Medway’s future consideration of what highways mitigation schemes will be necessary must extend to include any mitigation required with Maidstone borough.  This analysis could signal the necessity for measures at M20 J6 and J7, A228 (Blue Bell Hill) and potentially Boxley Road.

·   A linked issue is the potential for Medway’s planned growth to impact on air quality. Medway is yet to undertake strategic air quality modelling associated with its growth plans. Again the proposed response signals that this assessment and any identification of mitigation measures should extend to include impacts on air quality in this borough, most notably on the Maidstone Air Quality Management Area (AQMA).

·   The interim Habitats Regulations Assessment study published by Medway indicates that the growth proposals could detrimentally impact on the North Downs Woodland Special Area of Conservation (SAC) and Queendown Warren SAC both of which fall within Maidstone borough. In particular these environments are sensitive to increased nitrogen dioxide levels associated with increased traffic volumes. Further, more detailed assessment is planned.

·   The response requests that the forthcoming assessments and resultant mitigation proposals are shared with Maidstone council at an early stage so that positions can be agreed prior to Medway concluding on the content of its Regulation 19 pre-submission version of its Local Plan.  At the same point, officers would seek confirmation of the scale and mix of uses at the proposed commercial site allocation in the vicinity of M2 J4 to determine whether it could affect this borough’s new and established employment locations.

·   The response affirms that Medway should make specific site allocations in response to its identified need for additional Gypsy and Traveller pitches over the plan period.

·   A statement of common ground (SCG) will need to be prepared between the two authorities in association with the Regulation 19 version of Medway’s plan and it is anticipated that  transportation and air quality matters will be the leading cross-boundary issues to be addressed in this SCG






2.1     There are two options available to the Committee.  The first is that the Committee decides to submit a response to the Development Strategy Options consultation.  The second, alternative option is that no response is made.


2.2     Electing to submit a response will ensure that MBC’s position and interests are brought to the attention of Medway Council as it progresses its Plan and could influence its content.  To not make such a submission would be a missed opportunity for this council to engage positively with the preparation of a neighbouring authority’s key strategic land use plan.






3.1     For the reasons set out in paragraph 2.2 above, the submission of the response in Appendix 1 is recommended.



4.       RISK

4.1    The risks associated with this proposal, including the risks if the Council does not act as recommended, have been considered in line with the Council’s Risk Management Framework. We are satisfied that the risks associated are within the Council’s risk appetite and will be managed as per the Policy.






5.1    The consultation closes on 25th June; the original deadline of 11th May was extended to take account of the late publication of a Sustainability Appraisal report. Thereafter, the timetable is for Regulation 19 consultation to take place in Winter 2018, submission of the Medway Local Plan in March 2019 with adoption to follow in 2020.










Impact on Corporate Priorities

We do not expect the recommendation will by itself materially affect achievement of corporate priorities. 

Rob Jarman, Head of Planning & Development

Risk Management

Please see ‘risks’ section.  

Rob Jarman, Head of Planning & Development


The proposal set out in the recommendation can be achieved within already approved budgetary headings and so need no new funding for implementation.


Suzan Jones , Finance Officer


We can deliver the recommendation with our current staffing.

Rob Jarman, Head of Planning & Development


The duty to cooperate was created in the Localism Act 2011, and amends the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities, county councils in England and public bodies to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters.

It is considered prudent to engage positively with the preparation of Medway’s Local Plan to (a) ensure MBC’s interests are communicated and (b) help understand the implications of the Plan’s proposals for this borough.

Cheryl Parks, Lawyer (Planning) Mid Kent Legal Services

Privacy and Data Protection

No specific issues are identified at this stage.


Cheryl Parks, Lawyer (Planning) Mid Kent Legal Services


The recommendations do not propose a change in service therefore will not require an equalities impact assessment

[Policy & Information Manager]

Crime and Disorder


Rob Jarman, Head of Planning & Development



Rob Jarman, Head of Planning & Development & Section 151 Officer






The following documents are to be published with this report and form part of the report:

·         Appendix 1: Proposed consultation response to Medway Local Plan: Development Strategy Options






The Medway Local Plan Development Strategy Options consultation document and supporting documents are available here: