Queenborough Summary of comments
RefNo Fullname Organisation Comment Response
QR001 Catriona Riddell SEERA The draft South East Plan supports the Noted. The Masterplan is in conformity with RPG9 and has taken regeneration of the Isle of Sheppey, in particular account of the emerging Draft South East Plan. draft Policy KTG1 which sets out the Isle of Sheppey's role in meeting Swale's housing No change agreed. targets. Also, draft Policy KTG6 recognises the Island as a location for new employment use. The Assembly welcomes this SPD which seeks to give effect to draft South East Plan policies but have no specific comments. They remind the Council that any SPD should be in general conformity with the current Regional Spatial Strategy (RPG9) and take into account the emerging Draft South East Plan.
QR002 N Lakhan Dragon Property Ltd Dragon property acknowledge that their site does This notation will be corrected. not fall within the boundary of the Masterplan but note that on page 21 of the Masterplan it says that Change agreed. the predominate land use outside of the Masterplan boundary "is mainly open agriculture land, often grazed and with marshland character." On the accompanying map their land is labelled as agricultural land and public open space and they would like this removed as it is a private site and has no right of access to the public.
QR003 Mr P West Supports the proposals, adding that the water Noted. gives it huge potential. Thanks all involved and No change. hopes the project is successful.
QR004 Various Pupils Queenborough First School Children from Queenborough First School would The ideas for a fishing facility, bike riding places, play areas and new like a variety of facilities to be included within the parks should all be reflected in the open space section of the development, including a football stadium, a lake Masterplan. for fishing competitions, places to ride their bikes, play areas, an amusement park, new parks, Change agreed. separate roads for lorries and cars and an ice- cream factory.
QR005 Anne Pilcher Sittingbourne Library 1/ The respondent is keen to make the library a 1/ Noted. really good facility for local people. Is supportive of the marina area and the new housing as it will 2/ See Main Report. improve the area. 3/ This is already addressed in the Masterplan with 25% of new 2/ Highlight the importance of keeping local dwellings being affordable and a 5% commuted sum to improve heritage alive and accessible to more people. existing affordable stock. No change agreed. 3/ State that it is important that local housing is improved and more social housing is provided. RefNo Fullname Organisation Comment Response
QR006 Mr D Kearl 1/ The respondent is very impressed with the 1/ Noted. plans and feels that they will be a real improvement for the local community and 2/ Noted. economy, whilst increasing community pride. 3/ See Main Report. 2/ Highlight the success of the marina idea at Portsmouth and suggest it would provide an attraction for Kent as a whole.
3/ He would like to see more made of the historical aspects of Queenborough.
QR007 M J Williams 1/ The respondent feels that the housing is too 1/ See Main Report. high a density, that more open spaces are needed, that more needs to be made of 2/ Noted. Queenborough's character and that jobs should be high on the list of priorities. 3/ The Environment Agency raised no objections to houses being built on floodplains. No Change Agreed. 2/ The respondent also feel that the public need to 4/ The Masterplan allocates land for employment use but does not be made aware that the marina will push prices specify the type proposed. This will be determined at the planning up. application stage. No change agreed. 3/ The respondent wants no housing until the link road is finished and question whether the sea wall will be made higher as houses are being built on flood areas.
4/ The respondent feels there will be no need for road furniture to stop the lorries coming through the town once the link road is done. They question whether the type of land these factories/warehouses are being built on dictates that only certain types of industries can use this land.
QR008 R J Collins The respondent's comments are unclear from his No change agreed. written representation. RefNo Fullname Organisation Comment Response
QR009 Mr A Cole Aesica Queenborough Ltd 1/ The respondent draws our attention to a couple 1/ Change map in line with respondent's comments. of errors or omissions within the Masterplan relating to the Aesica Queenborough Ltd 2/ SBC to ask SEEDA to check if the map is correct and if not make pharmaceutical facility (previously owned by the necessary changes. Abbott Laboratories Ltd). Change agreed.
2/ They state that although the full extent of the 3/ SBC to ask SEEDA to check and make any necessary changes. Change Agreed. Aesica-owned land is not indicated on the map shown in the above document (the map does not 4/ SBC to ask SEEDA to check and make any necessary changes. extend sufficiently far north), they want to ensure Change agreed. that the land usage is shown correctly.
3/ They say the land west of Whiteway Road as far as the sea wall and bounded to the south by North Street and to the north as far as the roundabout with the Brielle Way should be shown as industrial use and that the land east of Whiteway Road and bounded to the south by North Street and the residential roads leading off it and to the east/north by Brielle Way and the railway line to Sheerness has outline planning permission for industrial use.
4/ They are concerned that the map wrongly suggests these areas as being designated "public green open spaces (parks)" and they feel we need to ensure that the correct nomenclature is used to during the consultation stages to avoid any confusion.
QR010 Mr D Wyatt MP 1/ The respondent would like us to consider 1/ Noted. Not an issue to be dealt with through the Masterplan. making sure the name of the 'new town' is named after something local and that the names of roads 2/ The Masterplan already takes account of this and social housing and businesses are named after local people and will be "pepper-potted" throughout the development. old businesses. 3/ There is no demand for a further station as there are already 2/ He recommends that the social housing is stations at Queenborough and Swale. interspersed throughout the area and not concentrated in one area.
3/ Asks if any thought has been given to creating an additional railway station, like the Swale stop. States that there is a rather poor railway line down to the Wharf.
QR011 M Devereux Requested longer to view the proposals in order to Respondent was emailed a list of places to view the documents and make comments on recreational facilities for the the website addresses and was told how they could purchase copies new inhabitants. of the document.
No further response was made by this respondent.
QR012 Mr A Hayward Premier Timber Ltd The respondent requires information regarding the This request will be passed to SEEDA. future of their business as they are on the Klondyke estate. No change agreed. RefNo Fullname Organisation Comment Response
QR013 Mr J Milham The Queenborough Rowing Club require a secure This could be explored further with SEEDA at the planning facility within/next to the inner marine basin. application stage.
No change agreed.
QR014 J Christmas Asked if Queenborough Rowing club would be This could be explored further with SEEDA at the planning offered a site at the marina to store boats and application stage. equipment and use as a base for the club. No change agreed.
QR015 Mr K Hitchins Respondent feels that if the plans happen it will be Noted. great for the area but has concerns that existing No change agreed. troublemakers in the area may prevent this.
QR016 Mr B O'Dowd 1/ The respondent feels that Rushenden may well 1/ The planning application for Neatscourt has been agreed and was benefit from this development but has a number of allocated through the Local Plan process. concerns. Firstly, they are concerned that the high ground for the proposed Aldi warehouse is of key 2/ The Council has some sympathy with the respondent but it would importance to the feel and landscape of Sheppey need to be pursued with the Port outside of the Masterplan process. and should not be built on. Argues that it would No change agreed. urbanise the Island's gateway.
2/ Secondly, they think that the Port land (the car park) should be compulsory purchased and used for the industrial units and not the land mentioned above. They believe that if these two things do not happen then the effect on Sheppey will be negative.
QR017 Rebecca Rowden The respondent feels that the warehousing The planning application for Neatscourt has been agreed and was development along the Rushenden link road is allocated through the Local Plan process. The Council agrees that one of the "most devastating and short sighted there will be landscape impacts but these will be mitigated through a planning decisions conceivable." They argue that detailed design process. The lost grazing marsh will be replaced Sheppey's landscape and grazing marshes are through compensatory habitat elsewhere. integral to Sheppey's character and that the view from the bridge would be ruined if the warehouses No change agreed. were to be built. States that landscape value and heritage are no less significant than economic concerns. Agrees that development is needed on Sheppey but believes that warehousing in this location will lead to a permanent loss of character for the grazing marsh.
QR018 G K Mullett 1/ Respondent feels that the Masterplan conveys 1/ Agree with the Respondent and thank them for their enthusiasm. a long overdue vision for Sheppey that will hopefully use the Island's unique land and sea scape to ensure an exciting and sustainable future 2/ Any habitat lost will be replaced through compensatory habitats for its inhabitants. elsewhere. Aspirations will be raised through the provisions of a range of jobs and skills training and the extra traffic will be mitigated 2/ However, they are worried that building through detailed high quality design methods. No change agreed. warehouses on marshland will industrialise an increasingly rare habitat for the sake of low-paid jobs and increased heavy traffic. RefNo Fullname Organisation Comment Response
QR019 Elaine Ball 1/ The respondent believes these are very nice 1/ The Council thanks the respondent for their comments. plans which they hope will be fulfilled. 2/ Visitor and tourist parking will be dealt with at the detailed planning 2/ However, they note that they did not see any application stage. The Green Charter document of the Masterplan areas marked out for visitor and tourist parking states that "developers and architects will also have to ensure that and for recycling facilities. either storage space for segregated waste within dwellings or convenient neighbourhood collection facilities and recycling points (or both) will be designed into the site." No change agreed. RefNo Fullname Organisation Comment Response
QR020 Owners of The Foundry, Rushenden State that the Land use map shows The foundry SBC have asked SEEDA for a view on these issues. Road site as proposed for mixed use yet on the Land use Residential Plan it is shown as residential. Their client is unclear what use is actually being suggested here. Clearly any mixed use were the building is suggested as up to 5 stories offers little practical available employment space given its current use and the significant allocation and commercial competition at Neats court. They would suggest to give certainty and confidence to the redevelopment of this "Gateway Site" an appropriate residential use alone would be better.
They state that on the Buildings Height Plan The Foundry site is shown as a range of heights of between 2-3 storey to 4-5 storey. Yet on the Urban Grain Plan the height is shown comparable with heights suggested around the Marina of 5+ storey. They would request greater clarity is given to the appropriate design height on this site given its important location.
Commenting on the Density Plan they suggest a density of lower 50-70 dph for The Foundry site. This is lower than the urban grain density along Rushenden Road at up to 80dph and similar to the predominant housing development on the Klondike site. They believe it also appears lower than the suggested number put in the previous draft Masterplan i.e. 90 units. This also excluded any intended " employment use" on this site. Given the total site area is around 0.55 hectares this site at best would only yield around 38 flats ( assuming on employment on site ).They strongly oppose this density guide and is no way consistent with the previous suggested density of 90 units. The circumstances or character of this site have not changed since the publication of the previous draft Masterplan. They request the density guideline be changed to reflect this i.e. 90+dph.
In an additional submission, they note inconsistencies between the Masterplan and the Project Delivery especially regards the phasing of The Foundry site . It is shown, they feel inappropriately for development in phase 3 of the Masterplan i.e. 10/15 years, yet in phase C1 in the Delivery document i.e. the 1st phase of the residential development. They state that as already expressed and agreed in correspondence with SEEDA this is an important visual "gateway" for the redevelopment of the Klondyke site and should therefore be included in phase 2 in the Masterplan consistent with the phasing outlined in the Delivery document. They wish to receive the Borough Council's support to this clarification. RefNo Fullname Organisation Comment Response
QR021 Julie Argent Crime Reduction Officer The Masterplan refers to sustainability which they These are detailed comments for the planning application stage and believe includes designing out crime, so it is will passed on to SEEDA to be used at that time. No change agreed. important that the appropriate measures are put in place to help reduce criminal activity.
They appreciate that creating a safe and secure environment has been considered and the principles contained in the publication "Safer Places – The Planning System and Crime Prevention" will be addressed. In due course they would like to ensure that the Design and Access Statement includes, in detail, the methods to be implemented regarding Crime Prevention Through Environmental Design.
Crime Statistics -
The perception by the public is that this area suffers from medium to high crime, so it is important that the fear of crime is reduced.
Alleyways and Pathways -
Narrow paths running behind houses between close boarded fences are not desirable. Such paths are not easily overlooked and therefore can be perceived as a haven for all anti-social, and possibly criminal, activities. Acute changes of direction in the path should be avoided so that no blind spots for users are created.
Such routes may adversely affect householder's privacy and security, and appear threatening. Attractive pedestrian links and cycleways can be formed trough amenity open space.
Wherever possible, footpaths and alleyways should be wide, clear of hiding places, well lit, and should be a direct route.
Entrance to the Development -
It is often recommended that a rumble strip, change of road surface together with brick pillars be incorporated at the road entrances to new sites in order to create a symbolic barrier. This gives the impression that the area beyond the 'barrier' is private to the community.
Landscaping -
All specified shrubs and hedges should have a maximum growth height of 1m, whilst all trees should be pruned up to a minimum height of 2m, which maintains a clear field of vision around the site. Trees when mature should not mask lighting columns nor become climbing aids.
All hard landscaping and street furniture should be securely fixed down in order to prevent removal, vandalism and/or use as potential ammunition.
Care needs to be taken when introducing street RefNo Fullname Organisation Comment Response
furniture because benches and street art can be crime generators depending on their location and can be used as climbing aids if not secured in an appropriate location.
Defensible Space -
It is very important that defensible space be built into new developments to address:
Territoriality: Using real and symbolic barriers to help the community manage the transitions from private to public space.
Surveillance: In order that the community can survey what is happening in and around public space.
Building Image: In order that the community won't feel stigmatised and isolated.
Juxtaposition of residential areas with other facilities: So that the strategic geographical location of intensively used communal facilities aids the security of adjoining areas.
Perimeter and Dwelling Boundaries -
Site perimeters and all rear gardens should be secured with a robust fence or wall, without footholds, to a minimum height of 1.8m. The rails of any timber fence should face the garden. The topography of the land should be taken into account.
A 1.8m fence and gate, with anti-lift hinges and a lock, should be erected between all houses as close to the front elevation as possible. A padlock is not acceptable, it must be a key operated lock with the slam shut facility. The above helps prevent unauthorised persons gaining access to the rear of properties, where most burglaries take place.
Boundary walls, bins and flat roofs should not be located so as to become climbing aids for intruders to gain access to upper floors. Meters should be located on the front elevations.
Such details can be discussed at a later stage.
Street Lighting -
The street lighting layout should be carefully designed to cover all vulnerable areas and must not create shadows. Well-positioned lighting will deter and reveal potential intruders.
Guidance for suitable lighting schemes can be obtained from BS5489 Part 9: 1996 under the subtitle 'Code of Practice' for lighting for urban centres and public amenities. RefNo Fullname Organisation Comment Response
High pressure sodium (SON) units should be used where possible, particularly at school crossings etc. Low-pressure units (SOX) emit poor quality light and consequently poor colour definition, which in turn makes it difficult to see intruders
Lighting should allow visibility along and around routes. Lighting should adequately illuminate paths, inset spaces, access and egress routs and signage. Shadows from buildings and landscape element should be considered when layout out the lights in order to minimise dark corners and insets.
Lighting should also be consistent in order to reduce contrast between shadows and illuminated areas. It is vital to avoid dark spots, which can offer as much opportunity to the criminal as general darkness and in addition can cause much personal anxiety. Every effort should be made to avoid distorting people's features and making them as readable and recognisable as possible.
Public Access -
One of the keys to the security of a development is the discouragement of casual intrusion by non- residents, therefore footpaths should be designed to serve the estate rather than provide unnecessary access. Community safety in respect of pedestrian links falls into two categories. The first is that properties and their perimeters, which adjoin footpaths, are susceptible to crime and vandalism and the second is personal safety, which includes risk or fear of assault, risk of abduction of children and danger from vehicular traffic. Additionally footpaths with links to adjacent estates can provide easy escape for persons having committed crimes. Therefore with the above in mind it is recommended that the pedestrian links be designed very carefully.
Wherever possible, footpaths and alleyways should be wide, clear of hiding places, well lit and should follow a direct route. They can provide a space for people to congregate which can lead to disturbance and nuisance to residents.
The Masterplan refers to permeability in many places. Offenders crave anonymity. Too much permeability can give them anonymity along with legitimacy. Many existing locations on the Isle of Sheppey have far too much permeability in the way of narrow, dark, vulnerable alleyways. These dangerous footpaths do not reflect a safe environment but provide uncontrolled access and escape routes for potential criminals. It is imperative that the permeability for Queenborough and Rushenden is carefully designed with this in mind.
Car Parking - RefNo Fullname Organisation Comment Response
In-curtilage parking is recommended but where communal parking areas are essential they should be well lit, open to natural surveillance and have obvious pedestrian routes. Traffic calming measures may be employed across the main entrance to communal car parks.
Serious consideration should always be given to the Secured Car Park scheme.
Any provision made for cycle parking should be secure and subject to good natural surveillance and well overlooked.
Large car parks open to the public can attract nuisance vehicles so I recommend that access control measures be implemented around car parks where appropriate.
Graffiti -
Careful consideration is required to minimise the risk of damage and graffiti. The following items should be given special consideration:
Materials: Vertical tile hanging, weatherboarding and large flat areas of sheet materials should not be used in vulnerable locations, if timber is used in high risk areas, it should be close-grained with an impregnable preservative finish and any areas of small sets or other blocks should be embedded to prevent their removal.
Applied surfaces: Strongly textured surfaces generally suffer less graffiti than smooth ones, walls with strongly patterned surfaces or bold contrasting colours are less liable to receive graffiti, however, the pattern should not be too large otherwise graffiti could appear within one area of colour, damage to applied surfaces is particularly pronounced when the surface colour is very different from the colour of the material below, material used below the surface finish should be as durable as possible.
Components and Services: External light fittings should not be accessible, wall mounted light fittings should be recessed or concealed where possible, rainwater pipes located near intensely used areas should be concealed or recessed and all pipes and cables should be concealed where possible.
Play Areas -
They have specific information regarding the design of play areas and open spaces, which can be provided if required.
ATMs -
They have specific information regarding cash point machines, which can be provided if RefNo Fullname Organisation Comment Response
required.
Security Lighting -
All external doors should have opaque, vandal resistant, compact fluorescent bulkhead lights, operated by photo-electric cells fixed above them at the highest inaccessible points. No switch should be fitted.
Drainpipes and Guttering -
It is recommended that all guttering down pipes must be flush fitting and square profile. Square pipes make climbing and gripping extremely difficult. All eaves should be between 300mm to 600mm overhang to prevent climbing. A small overhang will reduce the possibility of gaining access to the roof.
Secure by Design -
The use of the ACPO/Home Office Secured by Design (SBD) award scheme is strongly recommended as a planning condition for all new developments and regeneration projects. Note that all fixtures and fittings should meet or exceed the recognised standards as advised within SBD. SBD is an independent award, which ensures the adoption of appropriate security design and features in accordance with basic levels of insurance specification. For further information please visit www.securedbydesign.com
Recesses -
Recesses can become crime generators and attract unwanted visitors to gather out of hours. Recesses need to be removed wherever possible.
They appreciate that recesses may provide aesthetic interest in a design but they also create security weaknesses and opportunities for crime. Over the years, a recessed door, be it an emergency exit or an entrance, has been the scene of just about every type of crime and disorder you could imagine. Apart from them providing shelter for unwanted visitors and a resting place for litter, they also provide a hiding place for a burglar whilst a door is forced open. Removing recesses removes opportunity for crime.
CCTV -
They think there is scope for additional Council CCTV cameras in this area. Further information regarding security cameras can be supplied if required. I think it will be prudent to ensure that some strategically placed lampposts are equipped with the capacity to run the police mobile CCTV system (Hawkeye) in order to be proactive. Further information can be supplied at a later stage. RefNo Fullname Organisation Comment Response
Bins -
All waste disposal areas should be designed away from buildings as they can be a target for arson and provide access to roofs and windows. Industrial bins should be secured in a freestanding area away from perimeters and buildings.
Crime and Disorder Act -
Attention should be drawn to section 17, of the Crime and Disorder Act 1998, which clearly states "It shall be the duty of each authority to which this section applies, to exercise its various function with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent crime, disorder, ASB and substance misuse in its area".
Crime Prevention advice is given feely without the intervention of creating a contract. Kent Police does not accept any legal responsibility for the advice given. If however such advise is incorporated into the project design, the opportunity for criminal actions may be greatly reduced. Once a development has been completed, the main opportunity to incorporate crime prevention measures has gone.
QR022 Julie Bodiam Feels that the proposed height and density of the See Main Report. proposed residential development on the Klondyke estate will have a serious impact on her home. Feels that there will be serious consequences for privacy and intrusion into her home. They believe that it would result in her family living in an impossible position with no prospect of ever selling and moving. Attached a map highlighting her comments.
QR023 Adrian Leng Robert Pearson & Company Respondent sent a brochure of their water and The Respondent's details have been passed on to SEEDA. energy saving products and asked us to consider them for the development. No changed agreed.
QR024 D Kemp Timbmet Respondent informed us of all their timber related The Respondent's details have been passed on to SEEDA. products and asked us to consider them for the development. No changed agreed.
QR025 Mr D Bateman IJM Timber Engineering Ltd No comments on the Masterplan but a request to The Respondent's details have been passed on to SEEDA. consider their timber products for use in the development. No changed agreed. RefNo Fullname Organisation Comment Response
QR026 Mr D Brown 1/ The respondent would like to see buses pulling 1/ There will need to be a detailed discussion between SEEDA and up in front of the station rather than at the stop at the rail and bus operators to agree the public transport provision. the top of the road. They would also like to co- ordinate the buses arrival with the 2/ See Main Report. arrival/departure of the trains. they state that there is no-where to securely leave a car at the station.
2/ They would like the new school to be built nearer the station to reduce school traffic. RefNo Fullname Organisation Comment Response
QR027 Mr N Whitburn Action with Communities in Rural Kent The Kent & Medway Community Rail Partnership Noted. SEEDA to provide comments on the points raised. No strongly support the regeneration of change agreed. Queenborough and Rushenden. However, they believe that reference to the rail services serving Queenborough Station is too brief and inaccurate.
They make the following specific comments -
Chapter 2; Context, Page 29
“Traffic, Access and Footpaths - Current problems have been identified and the impact of the proposed regeneration assessed in traffic and transport terms. The traffic and transportation strategy has been developed with input front Swale Borough Council and Kent County Council Technical officers, Arriva, the local bus operation and Network Rail. Discussions have been held with the Highways Agency at various stages of the scheme development and it is anticipated that these will continue as detailed proposals come forward.”
They state that it is unfortunate that Southeastern Railway do not appear to have been part of discussions although they recognise that perhaps early consultations took place during the change of franchisee.
“Rail Services - The use of the Sittingbourne/Sheerness Railway by the residents of Queenborough and Rushenden does provide access to the National Railway Network via Sittingbourne. However survey results suggest that the use of this transport mode is declining, probably due to its lack of frequency.”
They find the comment about declining usage surprising. Their data shows quite the opposite. Figures for usage of Queenborough Station for the Agree. Change agreed. last three years are as follows;
Year Total 2004/05 162,234 2005/06 162,249 2006/07 170,447
The figures for the latter 2 years only include passengers travelling to/from the top 20 See Main Report. destinations from Queenborough whereas the first year is a total count. In either case there is clearly an increase in usage of the station as shown from ticket sales, not a decrease as stated in the Masterplan. They would therefore not want the potential of the rail service to contribute to the local community to be overlooked or minimised.
They also note that Southeastern have conducted a study into expected increases in passenger usage of all their stations with particular reference to the effect of the introduction of high speed services to St Pancras in December 2009. For Queenborough they expect to see an increase of RefNo Fullname Organisation Comment Response
15% by 2010/11 compared to 2006/07 and an increase of 23% by 2013/14 over 2006/07.
They state that the comment in the Masterplan on service frequency is also wrong. They believe that there can be few branch lines in the country that enjoy a more frequent service.
Chapter 3
“Vehicular Access Movement - Rail services will continue at Queenborough Station, which is on the course of the bus routes. Access to new development from the station is within easy walking distance through the new footpath routes proposed, as are the employment areas at Neatscourt. Footpaths and cycle paths will connect with road and rail links at key nodes. It is intended to improve the environment of the station area to make access and the user experience better.”
The CRP is keen to see improvements to the station environment and to access routes. They have also undertaken a survey of bus/rail interchanges here with Kent County Council and Arriva and suggested several improvements which have yet to materialise. They would request that specific proposals be drawn up in consultation with Southeastern and the Community Rail Partnership. RefNo Fullname Organisation Comment Response
QR028 G King 1/ Supports the idea of having short cuts from 1/ Noted. Rushenden to Queenborough as it will make it quicker to walk to the station, library and school. 2/ The marina will provide an image "uplift" for the area and will provide more usable waterspace, especially for children. 2/ Question the need for a marina when there is already water for leisure uses. Believes it is to sell 3/ 50% of the dwellings will be houses and the number have been properties overlooking the marina for more money. increased since earlier discussions with SEEDA. The mix is appropriate for the local need.
3/ Questions building apartment blocks when this 4/ The Local Plan, which went through consultation and an inquiry, sort of building is being demolished elsewhere. set the number of dwellings. Argues that people like their own gardens and parking spaces which they can overlook. Would 5/ The decision will be made by Kent County Council as the process like houses instead of apartments and the marina. progresses.
4/ Questions why so many properties are being 6/ This is a detailed planning application point. squeezed in as it will double Queenborough and 7/ The marina will not be tidal and a management company will run change it forever - something the resident do not the marina. want. Questions if the properties are therefore being built for immigrants and not local people.
5/ States that the Masterplan says a new school will be built if needed but they believe it will definitely be needed, especially as Sheppey schools are changing already, and a new school should therefore be built before the housing.
6/ Argues that no-one will want to park in underground car parks due to muggers and believes people like to be able to see their car from their house.
7/ Asks if the marina will be tidal as they are still waiting for the existing sluice gates to be fixed and they want to ensure someone properly manages the new marina.
QR029 Esso Petroleum Company They support the proposed mixed use vision for This would be dealt with at a planning application stage not in the regeneration at Queenborough and Rushenden. Masterplan. SBC will inform SEEDA of Esso's aspirations. They believe a roadway between the two roundabouts adjoining their site (see attached map), forms a natural boundary to the employment use development area and that the Masterplan should refer to their site as a trunk road service area capable of servicing all routes, including both the Island as a whole and Queenborough and Rushenden. They believe this need is best met at their site. They believe this site would also service local residents, both at Thistle Hill and Queenborough and Rushenden. They want their site identified in the Masterplan as a service area facility. RefNo Fullname Organisation Comment Response
QR030 Mr A Hill 1/ Regarding the existing position he notes that 1/ The appeal was on a piece of land outside of the Masterplan. the SPG reflects the current planning status of the No Change Agreed. land that is split between the existing ‘brownfield’ site, which comprises the site and curtilage of the 2/ SBC to ask SEEDA to investigate this. dwelling, ‘Nil Desperandum’, and the adjoining open land to the rear of the existing properties in 3/ SBC to ask SEEDA to investigate this. Alsager Avenue. State that these uses have been 4/ SBC to ask SEEDA to investigate this. recognised and accepted by the Borough Council in relation to the recent appeal submissions on the 5/ SBC will ask SEEDA to investigate this. site. In this context they support the identification of the existing curtilage of the dwelling within the area of land that is identified as developed on the Masterplan (see plan 3.3) as they believe that this ensures consistency and reflects the fact that this area is accepted as being of residential use as shown on the Context Plan (p27).
2/ Regarding social infrastructure, he accepts that the currently open land is located between Rushenden Hill and the Swale, but point out that no part of this is used for public recreation and it does not have public access as recognised by the Transport Plan (p28). They state that as confirmed in recent studies, the land is not of Changed agreed. significant value for nature conservation and is only partially subject to flooding at its northern end. They have no objection to the partial Change agreed. development of this land in terms of flooding as confirmed by the recent FRA submitted on the appeal and accepted by the Inspector. The identification of their client’s land as ‘Proposed Open Space’ as shown on plan 3.6 under the proposed ‘Swale Park’ is therefore strongly objected to. They argue that this fails to recognise Disagree. the status and ownership of the land and imposes No change agreed. a requirement that is at odds with the legitimate aspirations of the public authorities.
3/ In particular, they object to the inference on plan 3.6 that this area is already a public resource, when this is clearly not the case.
4/ In addition, they note that it is proposed to introduce a ‘main pedestrian route’ across our client’s land as shown on plan 3.8. They strongly object to, especially the chosen route, which runs right through the centre of the site.
5/ Regarding delivery issues they believe that this open land should not be included within the Masterplan, being shown beyond the Development Area and is not subject to the associated delivery proposals. They believe it should not therefore be used to provide for the open space requirements for the adjacent development areas. However, they state that the Project Delivery Strategy contained in Volume 2 confirms that landowners will be encouraged to bring forward their land for development in a manner that meets the objectives of the Masterplan. In this context, they would confirm that our client would be prepared to consider the release of part of his land for public open space RefNo Fullname Organisation Comment Response
providing that the residual land next to the existing residential curtilage is agreed to be released for housing purposes as a minor scale of development. They say that this is a matter that could be subject to subsequent negotiation in order to secure the open space objectives of the plan. They stress that in the event that the redevelopment of this site for housing is resisted by the Borough Council, their client would not be prepared to release any of his land for open space or other infrastructure unrelated to the use of his land. RefNo Fullname Organisation Comment Response
QR031 Mr M Miles-Lea Swale Joint Commissioning Partnership This response is from the 3 RSL's in the Swale These are extremely detailed comments which need to be discussed Joint commissioning Partnership which between the respondent and SEEDA. As suggested to the Swale comprises- Joint Commissioning Board for RSL's an agreement or Charter needs to be agreed between SEEDA, SBC Housing and the HA's ·Amicus Horizon Group (including Swale Housing and RSL's to deal with these detailed points. Association) ·Hyde Group Where factual errors are pointed out these should be changed in the final version of the Masterplan. ·Moat Housing
Please note, the following comments are in addition to the comments from Swale Borough Council (Alaine Bunce) and from Amicus Horizon Group (William Miller) and Swale Housing Association (Brian Horton).
The 3 associations welcome the approach being adopted by strategic partners, Swale Borough Council, SEEDA, KCC and others.
Masterplan Volume 1
·Page 7 – Strongly support the aim of the process to connect Queenborough and Rushenden together by producing a third new integrated community so that all three gain in the process.
·Page 9 The Vision – Agree and Support the Vision.
·Page 10 – They support and agree the policy objectives. They would wish to see priority and emphasis on 'the creation of a more balanced and sustainable community with better access to jobs and services. With the breakdown of physical and psychological barriers between Queenborough and Rushenden'.
·Page 11 Sustainability – Agree and support thrust of this element. They would be keen to investigate the benefits of a CHP system for new and existing residents.
·Page 22 Socio-economic Indicators – Agree with the emphasis on Rushenden and the need to address the challenges Rushenden faces within the Masterplan delivery.
·Page 35 – Project Delivery – Strongly agree and support objectives 1, 2, 3, 4 and 5 as listed.
·Page 43 – Connectivity – Strongly agree and would recommend this element is further emphasised and highlighted. 'A fundamental part of the Masterplan is to connect and integrate existing areas'.
·Page 45 – Agree and support point 27 streetscape and environment and regeneration opportunity to Rushenden.
Think it is helpful to see the site of Rushenden Court and the Rushenden shops identified as a redevelopment opportunity contributing to the RefNo Fullname Organisation Comment Response
Masterplan.
Extension of Rushenden redevelopment site – they formally request that the Rushenden redevelopment site (No. 27) is extended to the north to include the opportunity for redevelopment on the village hall site and the now vacant former garage site (Rushenden Road/Manor Road junction).
·Page 47 Integrating Rushenden – From the housing associations perspective this is an essential element of the Masterplan concept. They strongly support the integration of Rushenden and the need for the Masterplan to provide the planning basis and programme delivery basis to see this achieved. Strongly agree and support.
·Page 48 – They strongly agree the inclusion of the site at Rushenden Court and the adjacent shops for residential development.
·Page 50 – good to see residential development sites within the Rushenden estate but would encourage the expansion of identified infill development opportunities.
·Page 51 – The sentence "25% to be built as affordable housing with options for shared equity purchase" might be misconstrued to mean that no rented accommodation should be provided. For the avoidance of doubt this should be re-worded to make clear that affordable rented accommodation will be required.
·Page 62-65 – Generally approve and support the water space and sustainability sections.
Masterplan Phasing
·Page 66-67 – Support the indicative phasing. Support the need for Volume 2 and a strategy for implementing the Masterplan.
·Page 70 Design Concepts and Principles – Agree and strongly support principle 1 integrating and linking Queenborough and Rushenden. Generally support all 10 design principles.
·Page 72 – Support proposal on a high proportion of new dwellings to be affordable housing integrated throughout the scheme.
·Page 75 – Support development and integration with Rushenden.
·Page 76 – Support landmark and views.
·Page 80 Building Heights – They support the proposals for 4 to 5 storey height development on the site of Rushenden Court and the shops, although we are not clear as to whether you have RefNo Fullname Organisation Comment Response
any preferences for the density of such a development.
·Page 112/113 – Support design concepts and principles for Rushenden.
Volume 2 Project Delivery
·Page 4 – Agree and support benefits as listed in project delivery executive summary.
·Page 6 – 1.2 Generally support project delivery arrangements.
·Page 11 Project Delivery – They support the proposal that minor development within exiting built up areas would not be liable for contributions towards the infrastructure requirements. For the avoidance of doubt, please can you confirm that the 4-5 storey re-development of Rushenden Court and the shops, as shown in the Masterplan, counts as minor development within the existing built up area and is therefore not liable for contributions towards the infrastructure requirements?
·Page 16 – Support and agree 3.9, 3.10 and 3.11.
However, in clause 3.10 they need to be clear that funds raised by the 5% commuted sum are to be spent on upgrading the external environment of Rushenden, and are not to be spent on works inside properties or works which are the normal maintenance responsibility of the landlord or owner eg, kitchens and bathrooms.
Clause 3.11 should specifically refer to the three RSL partners selected by Swale Borough Council to provide the new affordable housing, ie, Amicus Horizon Group, Hyde and Moat Housing.
·Page 23 Planning Obligations – Affordable housing.
·The precise requirement and mix of affordable housing will indeed take into account market and site conditions, but must also be agreed with Swale Borough Council to ensure it meets identified needs.
There is no guidance on how the price for the affordable housing is to be calculated - this needs to be included.
The affordability of rents and sale prices of affordable housing may be affected by unnecessarily high service charges. They would like the document to ensure that the schemes are designed so that the affordable housing elements are not burdened with unnecessarily high service charges.
Whilst they note that precise requirements for mix RefNo Fullname Organisation Comment Response
of tenures and sizes of properties, location, phasing etc, will be set out in detailed planning permissions, they believe that the key principles guiding these matters should be scheduled out at this stage ie,:
·Affordable housing provision in each phase, to be generally in line with the dwelling types provided in that phase, eg, if a phase is predominantly 2 and 3-bed housing, the affordable provision should be predominantly 2 and 3-bed housing. However, minimum targets should be set for the number of wheelchair standard dwellings and larger homes (over 3 bedrooms) across the scheme.
·Tenure mix in each phase to be specified by the Local Authority (presumably in line with the housing needs survey).
·Affordable housing to be provided in clusters of say [6-12] units, with a minimum distance of 50m between clusters.
·Affordable housing to be provided to meet the minimum standards required by the Housing Corporation or equivalent funding body at the time of funding approval. The Housing Corporation's current standards are set out in their document 'Design and Quality Standards 2007'. In particular, good HQI and Building for Life scores, 100% Lifetime Homes compliance, and the relevant level of the Code for Sustainable Homes must be achieved, although it is hoped that the Green Charter will assist with the latter – see comments on Volume 3 below.
·In clause 4.15 they need to be clear that funds raised by the 5% commuted sum are to be spent on upgrading the external environment of Rushenden, and are not to be spent on works inside properties or works which are the normal maintenance responsibility of the landlord or owner eg, kitchens and bathrooms.
·4.16 – For the avoidance of doubt – is the affordable housing meant to contribute to the infrastructure costs as well? If so, this will have an impact on the values the private developers can achieve from RSLs and this needs to be included in any price paid by the RSL for the affordable homes, not on top of it.
-Page 32-34 Indicating Phasing Strategy – Agree and support.
-Page 36 Zone E Phasing and Triggers – Support wording of 5.17.
-Page 38 Project Delivery – Support future management partnership arrangements for project delivery.
-Page 46 – Generally support indicative RefNo Fullname Organisation Comment Response
infrastructure requirements and costs.
·Green Charter – Supporting Volume
They generally agree and support the proposals in the Green Charter, although we would also recommend more specific adoption of the 10 "One Planet Living" principles. On page 28 they welcome the requirement to achieve an increasingly high level of the code for Sustainable Homes over the life of the Project. RefNo Fullname Organisation Comment Response
QR032 Kent Police Although the provision for contributions to police As a general point, it would only be appropriate for developer services as part of the regeneration plan is contributions to be sought for capital schemes related to the commended, Kent Police has a number of development in question. SEEDA will be asked to clarify the source concerns about the draft Queenborough and of the figures on page 44 and this response in general. It would not Rushenden Masterplan. These are outlined below. be appropriate for the Kent Police to be part of the Management Group for Section 106 monies. It will be for the Local Planning The Delivery Strategy, outlined on page 67 of Authority to ensure that monies are spent in accordance with any grant of planning permission. To allow further bodies onto the Volume 1: Masterplan indicates that developer Management Group would create an unwieldy body, comprising a contributions will be tied to the construction of new potentially large number of public sector bodies all with similar claims buildings and facilities. However, the service to the Police. No change agreed. provided by the Police depends on much more than local accommodation for police officers and staff and it may not be that new buildings for the force are appropriate for the developments that are set to take place in Queenborough and Rushenden. The Police therefore do not want any contributions to be tied purely to the construction of new buildings and facilities.
In Volume 2: Project Delivery it states that SEEDA want to ensure that development will not be able to proceed before funding for the required infrastructure is in place, which will be achieved through the use of Section 106 agreements. This is an appropriate approach; however, basing these contributions on a 'pooled contribution' for communal infrastructure is not favoured by the Police.
They draw our attention to the fact that Kent Police require contributions in the form of funding with flexibility on how and where this is to be invested, in order to continue to provide a high level of service provision in line with the regeneration schemes outlined in the Masterplan. On page 25, the Council outline that they intend to gather payments for communal infrastructure into two funds – one held by KCC and the other held by the Council. This clearly does not meet the needs of the Force and limits the accessibility to developer contributions.
Also of significant concern are the figures outlined in Table 1, which on page 44 assigns an indicative figure of £1,000,000 to the Emergency Services and on page 46 explains that this figure is "Based on an estimate build cost for the additional accommodation as identified by Police (15 staff in 224m2 of space)". Kent Police have not identified this figure to SEEDA.
The quoted figure for developer contributions to the Emergency Services does not therefore reflect the Section 106 contributions that are required by the Police to provide an appropriate level of service provision. They are concerned that Swale Council have not asked to meet Kent Police to discuss these matters before drafting the Queenborough and Rushenden Masterplan, which unfortunately now represents an inappropriate approach to developer contributions, based on inaccurate figures. RefNo Fullname Organisation Comment Response
Local authorities are legally required under S17 Crime & Disorder Act 1998 to ensure they consider crime and disorder reductions and community safety in the exercise of all their duties and activities – including spatial planning and "place shaping". Planning Authorities should therefore facilitate the objectives of other legislation, such as S106 agreements concerning developer contributions, where land use considerations arise. Any omission or under- emphasis of community safety in local infrastructure strategies would clearly be contrary to this duty, and the emphasis given in Sustainable Community Strategies, sub regional strategies, some emerging Regional Spatial Strategies and other guidance such as PPS1 (infrastructure provision and safety generally).
In short, the draft Masterplan does not appropriately take account of the revenue cost of the police officers and staff or the capital costs of the associated accommodation and infrastructure that would be required to provide an appropriate level of service for the developments in question. The Masterplan is not consistent with the approach that Kent Police has taken in other parts of the country, and it is therefore requested that a meeting be arranged with the Council to rectify this.
They want to ensure that provision is made for police services in line with the increased demands placed on the force through needs generated by the regeneration of Queenborough and Rushenden. The respondent states that if done effectively, this will help tackle the key issues of community safety within the Borough and will help develop safe and sustainable communities.
QR033 Mr C Wyver All Tide Landing Board The respondent highlights the importance of the This does not relate to the development and it is therefore up to the 2012 Olympics for Queenborough and thinks that All Tide Landing Board to implement outside of the Masterplan European leisure sailors will visit during the process. However, the Council suggests that they contact SEEDA to games. They state that in order for this to be discuss this issue outside of the Masterplan process. profitable extensions of piled pontoons, both north and south of the All Tide Landing are required. They believe this would need to be included within phase one of the development, 2008-2009, for it to be economically beneficial. RefNo Fullname Organisation Comment Response
QR034 Mr W Miller Amicus Horizon Group (Swale HA) They are keen to see a comprehensive These are extremely detailed comments which need to be discussed regeneration of the neighbourhood to provide between the respondent and SEEDA. As suggested to the Swale significant improvements and opportunities for Joint Commissioning Board for RSL's an agreement or Charter local residents. They welcome the approach being needs to be agreed between SEEDA, SBC Housing and the HA's adopted and acknowledge the partnership role the and RSL's to deal with these detailed points. housing association itself plays as a key land owner/landlord, neighbourhood manager and Where factual errors are pointed out these should be changed in the final version of the Masterplan. prospective partners to deliver the much needed change for Queenborough and Rushenden.
In particular, both the comments on this Masterplan and the forward partnership work reflect the association’s ambition to prioritise actions that are of benefit to our residents.
They have many detailed comments which are listed below - Masterplan Volume 1 Page 6 Introduction; Study Area Analysis – Support of the inclusion of Rushenden and other Swale HA property interests within the development boundary. Page 7 – Strongly support the aim of the process to connect Queenborough and Rushenden together by producing a third new integrated community so that all three gain. Page 9 - Agree and support the Vision. Page 10 – Support and agree the policy objectives. Would wish to see priority and emphasis on ‘the creation of a more balanced and sustainable community with better access to jobs and services. With the breakdown of physical and psychological barriers between Queenborough and Rushenden’. Page 11 Sustainability – Agree and support thrust of this element. Would be keen to investigate the benefits of a CHP system for existing residents. Page 12 The Arts – Agree and support a significant focus on art within the proposed redevelopment. Page 22 Socio-economic Indicators – Agree with the emphasis on Rushenden and the need to address the challenges Rushenden faces within the Masterplan delivery. Page 35 Project Delivery – Strongly agree and support objectives 1, 2, 3, 4 and 5 as listed. Page 43 Connectivity – Strongly agree and would recommend this element is further emphasised and highlighted. ‘A fundamental part of the Masterplan is to connect and integrate existing areas’. Page 45 – Agree and support point 27 streetscape and environment and regeneration opportunity to Rushenden.
It is helpful to see the site of Rushenden court and the Rushenden shops identified as a redevelopment opportunity contributing to the Masterplan.
They formally request that the Rushenden redevelopment site (no 27) is extended to the north to include the opportunity for redevelopment RefNo Fullname Organisation Comment Response
on the village hall site and the now vacant former garage site (Rushenden Road/Manor Road junction).
Page 47 Integrating Rushenden - From their prospective this is an essential element of the Masterplan concept. They strongly support the integration of Rushenden and the need for the Masterplan to provide the planning basis and programme delivery basis to see this achieved. Strongly agree and support. Page 48 - They strongly agree the inclusion of the site at Rushenden Court and the adjacent shops for residential development. To best assist with the redevelopment of the site, they recommend that, while the residential emphasis is the primary focus for redevelopment, plans should allow for the potential inclusion of a small element of commercial or retail space. This would best allow the retention of one or two local facilities and perhaps their relocation into the new scheme. It would ensure the redevelopment process and one or two aspects of local provision might be retained. In seeking this amendment it would be clear that the scale of any mixed use on this site would be minimal and not act as an in detriment to the main new commercial area towards the centre of the Masterplan development (Rushenden Place). Page 50 – Good to see residential development sites within the Rushenden estate but would encourage the expansion of identified infill development opportunities. Page 51. The sentence “25% to be built as affordable housing with options for shared equity purchase” might be misconstrued to mean that no rented accommodation should be provided. This should be re-worded to make clear that affordable rented accommodation will be required. Page 52 Land Use Employment – The provision of mixed land uses at Neats Court is welcomed and supported by AmicusHorizon Group. The potential for offices, retail, hotel / dining and distribution is already demonstrated and will bring diversity to the Masterplan. Page 61 Vehicle Access and Movement – Agree with need for significant improvements to Rushenden traffic calming. The Masterplan must address the improved design of traffic calming for Rushenden. Page 62-65 – Generally approve and support the water space and sustainability sections.
Masterplan Phasing Page 66-67 – Support the indicative phasing. Support the need for Volume 2 and a strategy for implementing the Masterplan. Page 70 Design concepts and principles - Agree and strongly support principle 1 integrating and linking Queenborough and Rushenden. Generally support all 10 design principles. Page 72 – Support proposal on a high proportion of new dwellings to be affordable housing RefNo Fullname Organisation Comment Response
integrated throughout the scheme. Page 75 – Support development and integration with Rushenden. Page 76 – Support landmark and views Page 80 Building Heights – We support the proposals for 4 to 5 storey height development on the site of Rushenden Court and the shops, although we are not clear as to whether you have any preferences for the density of such a development. Page 98 Art Culture and Community – Support the thrust of this in the Masterplan. Page 100 Lighting Strategy – Support and approve lighting strategy, in particular, integration with Rushenden. Page 112/113 – Support design concepts and principles for Rushenden.
Volume 2 Project Delivery Page 4 – Agree and support benefits as listed in project delivery executive summary. Page 6 – 1.2 Generally support project delivery arrangements. Good to see the housing association identified within the various organisations. Page 11 Project Delivery – We support the proposal that minor development within existing build up areas would not be liable contributions towards the infrastructure requirements. For the avoidance of doubt, please can you confirm that the 4-5 storey re-development of Rushenden Court and the shops, as shown in the Masterplan, counts as minor development within the existing built up area and is therefore not liable for contributions towards the infrastructure requirements Page 16 – Support that AmicusHorizon Group and housing association partners are identified. Support and agree 3.9, 310 and 3.11. Clause 3.11 should specifically refer to the three RSL partners selected by Swale Borough Council to provide the new affordable housing, i.e. AmicusHorizon Group, Hyde and Moat Housing. Page 23 Planning Obligations – Affordable housing. 4.14. The precise requirement and mix of affordable housing will indeed take into account market and site conditions, but must also be agreed with Swale Borough Council to ensure it meets identified needs. 4.16 Strongly support offsite contribution to assist with the upgrading of existing affordable housing stock or works to the public realm (this equates to £1.5m set aside during the development on the basis of 2000 new homes). This is an essential element of the Masterplan tariffs and project delivery. It is expected the resources will compliment efforts to improve Rushenden street scene. This is an essential priority within the Masterplan and there should be concerns that a contribution of circa £1.5m will not be significant resource to achieve the street scene, environment improvements to help integrate Rushenden with RefNo Fullname Organisation Comment Response
the new proposed development to the north. They would welcome a strengthening of the proposed developer tariff contribution towards such works. However, there is no guidance on how the price for the affordable housing is to be calculated. The affordability of rents and sale prices of affordable housing may be affected by unnecessarily high service charges. We would like the document to ensure that the scheme is designed so that the affordable housing elemis are not burdened withy unnecessarily high service charges. Whilst we note that precise requirements for mix, location, phasing, etc, will be set out in detailed planning permissions, we believe that the key principles guiding these matters should be scheduled out at this stage, i.e.: Affordable housing provision in each phase, to be generally in line with the dwelling types provided in that phase, e.g. if a phase is predominantly 2 and 3-bed housing, the affordable provision should be predominantly 2 and 3-bed housing. Tenure mix in each phase to be specified by the Local Authority, (presumably in line with the housing needs survey) Affordable housing to be provided in clusters of say [6 to 12] units, with a minimum distance of 50m between clusters. Affordable housing to be provided to meet the minimum standards required by the Housing Corporation or equivalent funding body prevalent at the time of funding approval. The Housing Corporation’s current standards are set out in their document ‘Design and Quality Standards 2007’. In particular, good Building for Life scores and the relevant level of the Code for Sustainable Homes must be achieved, although it is hoped that the Green Charter will assist with this – see comments on Volume 3 below.
For the avoidance of doubt - is the affordable housing meant to contribute to the infrastructure costs as well? If so, this will have an impact on the values the private developers can achieve from RSLs and this needs to be included in any s106 ceiling price, not on top of it.
Page 32-34 Indicative Phasing Strategy- Agree and support Page 36 Zone E Phasing and Triggers – Support wording of 5.17 Page 38 Project Delivery – Support future management partnership arrangements for project delivery. Support AmicusHorizon Group noted as project delivery partner. Page 44 Project Delivery Infrastructure Requirements – Agree and support no.4 offsite affordable housing contribution. Page 46 – Generally support indicative infrastructure requirements and costs.
Green Charter – Supporting volume They generally agree and support the proposals in RefNo Fullname Organisation Comment Response
the Green Charter, although they would also recommend more specific adoption of the 10 “One Planet Living” principles. On page 28 they welcome the requirement to achieve an increasingly high level of the code for Sustainable Homes over the life of the Project. The wording of the Green Charter and statements within the Masterplan Volume 1 need to be reviewed so there is a better ‘cross read’ on the sections on eco-homes.
Style content and approach to Masterplanning They wish to record their support for the process being undertaken and the spirit of partnership being pursued by Swale Borough Council, SEEDA and other agencies. They would support the innovative and user friendly presentation and content of the Masterplan. RefNo Fullname Organisation Comment Response
QR035 Ian Lewis SBC - Ian Lewis Generally he feels that in the Masterplan there The perceptions of the green charter are not accepted. Green seems to be a gap between the good words and aspects are a key element of all the Masterplan documents but due aspirations and the delivery; the language is very to the importance of this theme, a separate document was deemed much along the lines of ‘we will seek to’ rather necessary to give it the weight it deserves. The green agenda is a than ‘we will’. E.g. How are developers of future constantly changing one and therefore having a separate document parcels within the Masterplan area be made to allows regular updating of that section to ensure that the latest incorporate certain elements within their sites – guidelines and ideas are incorporated into the developments. The objectives relate to the Masterplan and the targets are enforceable by such as key pedestrian or cycle routes? the Council and SEEDA. Whilst the 'green' title is not perhaps all embracing, the content of the documents wider in it's scope. He believes that the green charter seems to be a However, the title will be amended to 'Sustainability Charter'. Phasing little misplaced. Firstly, if the Masterplan was issues are considered in the project delivery and S106 parts of the articulating a lot of the aspirations of the charter document. then this additional document should not be needed. Secondly, is it more to do with In relation to the more specific comments. SEEDA will be asked to sustainability than pure green issues; green respond. conjures up thoughts of landscaping in a master plan context. The green charter should be more of a ‘golden thread’ through the Masterplan rather than what could be construed as a bolt on. They argue that in the Green Charter, and specifically with reference to transport, there is nothing in there that talks about managing transport demand. For example, greater provision of or access to services locally would reduce the need for travel. This would be sustainability; but how to provide this in the early stages needs consideration.
The respondent wants schools and the local centre, things that people need to avoid travel, to be provided early in the development. They consider that it is essential to provide these very early in the development to lock in sustainability from the outset. They believe the project delivery structure should be reconsidered to deliver these facilities at the outset rather than waiting for a critical mass, and the contributions strategy amended to reflect this, whilst bearing in mind that adjacent communities already suffer with lack of services.
Specific comments include –
Volume 1
* Page 28 The plan shows a sustrans cycle route from Kingsferry Bridge to Rushenden. This link was never implemented. However, there are now cycle facilities on the old A249 from the Bridge to Cowstead Corner.
* Plan does not show the cycle route from the east of the pedestrian bridge crossing the railway adjacent to Brielle Way that continues to Sheerness town centre.
* Page 58 The public right of way crossing the A249 (in a very hazardous location) to the west of the new Cowstead corner roundabout. – I thought this had either been stopped up or diverted?
* There is no indication of pedestrian/cycle links along Main Road heading towards Halfway, or up RefNo Fullname Organisation Comment Response
Whiteway Road. These are two key links to the surrounding area giving access to Minster and Sheerness respectively. Indeed, with the latter the opportunity should be taken to complete the link from Queenborough to the rail crossing at Brielle way to join up with the established route on the eastern side of the railway which continues on to Sheerness town centre.
* Page 60 Again, no recognition of transport links to Halfway, or Leysdown for that matter.
* In the Green Charter on page 14 reference to car pooling should be updated to reflect the car club concept more directly. RefNo Fullname Organisation Comment Response
QR036 SBC Regeneration SBC - B. Thompson/L Newton/N Mollett Overall they think the Masterplan represents very 1/ Eco issues are dealt with in the Green Charter and as it is a 'living' well the issues and challenges at Queenborough document it can be regularly updated to reflect emerging issues. and Rushenden and identifies the opportunities for No change agreed. the next decade. 2/ The Corporate Plan objectives are inherent in the Masterplan. See They have some specific comments, including: Main Report for Arts at the Centre. 3/ The phasing shows that the 'old' will be improved, with the Housing 1/ Ensuring that the development represents best Association already involved in environmental improvement works for practice as an ‘eco development’, especially as both the housing stock and public realm in Rushenden. The The Thames Gateway has recently called for the community centre at the Gateway will continue to be a community Gateway to be designated as an eco region and centre for both the old and new residents and shared facilities such therefore it expects partners to work be an as schools, health centres and Rushenden Square will provide exemplar of eco best practice so Swale needs to opportunities for all the communities to mix. See Main Report. ensure that developers play their full role. They No change agreed. believe that if this is achieved consequent opportunities for growth in associated employment 4/ £150,000 is allocated in the project delivery for this and the Housing Associations are keen for retrofitting to occur. sectors and in training and skills will occur. No change agreed.
2/ Ensuring it supports the delivery of Corporate 5/ The Masterplan states that a community facility will be provided, Plan objectives and aligns to the Green Grid and but the Masterplan is not the place of such assurances. Cultural Strategies with the additional caveat on No change agreed. the latter of reflecting the Art at the Centre ‘way forward’ strategy (see below). 6/ Arts is mentioned in the Masterplan document in it's own section and a commitment to art at a 'strategic art' level is mentioned in the 3/ State that there is much about the ‘new’ in the S106. SEEDA have previously indicated that they are not prepared to document but very little about the ‘old’ in terms of increase contributions towards art, although they remain committed to 'Arts at the Centre.' the existing residents and housing stock in No change agreed. Rushenden. Question what proportion of effort is going to be placed on ‘repair and extend’ agenda 7/ A management company will manage the waterfront park in the within the existing community against the ‘new long term. No change agreed. build’ agenda for the emerging community. They do not get a sense of balance in the 8/ Section 3 of Volume 2 deals with this issue. Theses issues will documentation. They see nothing of substance however need to be 'fleshed out' in the 'Constitution' of the delivery within the documentation that allays fears that body. these separate communities will be anything but No change agreed. that i.e. separate. There is risk which is 9/ SBC will suggest that SEEDA look into this idea. mentioned “Q&R presents a mixed physical and social picture” (p. 22). There is talk of the overarching aim (page 7) of bringing new 10/ The Green Charter will be renamed the Sustainability Charter. communities together but no specific objective(s) Change agreed. attached to this aspiration. Is there balance between existing and new? There is a further 11/ Disagree. Page 49 of the Masterplan sets out all the various reference on page 7 ‘Regeneration seeks to meld elements of sustainability. the new with the old….facilities’ but again no No change agreed. mention of how. Connectivity is referred to but no 12/ See Main Report for open space provision. Other matters can be details as to how this will actually work. State that dealt with either at the planning application stage or via the Steering much has been said about the challenge of Group with SEEDA. ensuring that the residents of Rushenden feel part of the regeneration scheme and the importance 13/ SBC recognise the importance of art in regeneration, hence the (and the potential impact for community cohesion) arts section of the Masterplan, but these details will be picked up at can not be underestimated. the planning application stage.
Highlights the importance of active and effective community development being stressed in the Masterplan, whilst ensuring that SEEDA are committed to the ongoing funding for a Community Development Officer.
4/ State that we must exploit opportunities to retrofit the existing housing stock so that these dwellings can also represent best practice in terms of energy and sustainability. RefNo Fullname Organisation Comment Response
5/ They would like assurances that the Gateway building is retained as it is synonymous with the regeneration proposals and any removal of this building (unless replaced with a better building) would be viewed very negatively by local residents.
6/ States that the plan rightly refers to the importance of art but that this is then reflected inadequately in the Masterplan and not translated into the developer contribution strategy. Art at the Centre could have had a higher profile as arts can provide an opportunity for social networking as well as being an excellent educational tool. This will not occur just by providing community facilities alone – a dedicated commitment to the arts is needed to help ‘nurture the seed of cultural richness’. They argue for a significantly higher contribution to the arts and for partners to work hard to ensure that art is an essential element of the design stages of the development and not just an afterthought.
Open space/landscaping, along with the arts programmes, have the potential to instil local pride in the area if they are given the profile and attention they deserve. They are the ‘glue’ in connecting old and new communities and they are concerned that insufficient attention is being paid these agendas. These are not peripheral projects.
Thinks that the role which could be played by architectural lighting has been missed and would like to see this issue given some prominence.
7/ Cannot see a reference to the long term maintenance of the waterfront park so questions how this will be managed and by whom?
8/ They want to ensure equitable distribution of assets emerging from Section 106 – this is a wide brief and often the softer elements (environment/culture) have a tendency to drop off the agenda. It is for SBC, with our strategic partners, to determine local priorities, which have been and remain grounded in community consultation. State that the Strategic Steering Groups accepts that substantially more work is required in determining the phasing and governance of the developers’ contributions strategy and we must not lose sight of this issue.
9/ Questions if there is potential to include Land Restoration Trust in discussions around land management/transfer of ownership/maintenance of access in perpetuity. State that they are set to have increasing involvement in North Kent through our more strategic agenda of Greening the Gateway Kent and Medway; this at least merits exploration in the context of these discussions.
The Green Charter for Queenborough and Rushenden RefNo Fullname Organisation Comment Response
10/ Believes it is a Sustainability Charter and is disappointed to see it branded as a 'green' charter as you immediately imagine that greater attention to detail might be given to the issues such as responses to climate change, landscape character, eco-systems etc., and need to be balanced against the sustainability issues.
Additionally, there is vision which is well articulated but little around the specifics of delivery – performance monitoring will be critical but without the detail it will be difficult to truly measure success and/or failure.
In it’s support, they commend the approach by adding that the elements within the documentation are important and reflect some of the relevant challenges in developing sustainable communities. They think it is a pity that the environmental agenda is not integrated more comprehensively into this document in terms of open spaces etc. State that they merit the same attention to detail as the other regeneration issues and challenges.
11/ They believe the definition of sustainability in the document is essentially around the development of a sustainable housing policy rather than a wider definition. Land Use (p. 49) – nothing much (anything?) for culture; there is scope within the community section to make provision for the arts sector in particular but they think that the green space section could also recognise the role of the arts within it.
12/ Public Open Space (p. 55) – Queenborough and Rushenden do benefit from their position in the midst of a unique landscape of marshes and waterspace. What of the new community though? What specific provision is being made in terms of support to this new community? It states communities are within easy reach of Elmley Marshes – they would dispute this. The existing infrastructure outside of Queenborough and Rushenden does not support walking but does lend itself more to cycling. The importance of a Green Travel Plan is therefore critical both for access to and within the area of development and to ensure connectivity to the wider community.
They question what criteria are being used to support the phrase: “there is an appropriate quantity of open space…” It goes on to say that current provision will suffice even with a new community – but is it situated in the right place for existing and new communities? State that it needs to reflect the importance of ‘green corridors’ in all development integrating open spaces. Connecting space too is critical (internally and externally).
13/ Art at the Centre RefNo Fullname Organisation Comment Response
State that the regeneration has the unique opportunity to take a coordinated approach to culture in the built environment, that is inclusive, diverse and experimental. Art at the Centre’s main purpose is to make art happen before and during the development to align both the public and the private participation to increase the quality and the quantity of the local cultural products. More people are creatively involved than ever before, and more are aware of the full potential gains art has to offer for both the well being and economy of the area.
Artists need to be engaged early on during the planning process to allow parts of the development to be influenced, instead of the traditional approach which leaves a plot of land for something to be installed at the very end of the process). This new approach makes the artworks integral to the functional space, for example street signage, lighting and furniture can all become part of the wider project to inject creativity on all levels. It is important to bring the art out of the community, not have it ‘done’ to an area, thus the emphasis is on inclusion and participation.
The Arts Strategy
They suggest a number of key locations for iconic gateway projects, welcoming arriving visitors to the area - Rushenden Hill, Rushenden Relief Road, The Castle Site and the Marina,
They state that the art could take many forms, sculpture, lighting, video, could be spread over many locations not just exist in one spot and could be educational, drawing viewers awareness to historical and environmental factors affecting the area, for example.
Art is full of potential to speak about Queenborough and Rushenden’s distinctive features which make it a special and exciting place to live. RefNo Fullname Organisation Comment Response
QR037 J Hattersley SBC - J Hattersley Executive Summary - Many of the respondent's points specific design issues which would be dealt with at the planning application stage. SEEDA have been States that SBC clearly values diversity and the asked to review these comments and update the Masterplan as policy document “Towards a Fairer Swale” reflects appropriate. this. Therefore, future developments should recognise the diversity in the Borough. This examination reveals what looks like a lack of consideration for a sizeable proportion of the community – those with mobility and sight problems. There is no reference to disability issues.
States that parking issues can be critical and developed wrongly can render an area inaccessible to those with a short ‘range’.. Town houses are impossible for wheelchair users to live in – they need one flat level (there are no bungalows in the Masterplan). There is no reference to Lifetime Housing even though the residents of Swale represent whole lifetimes.
States that the Masterplan could be perceived as representing a part of the community but where a SBC will discuss this with SEEDA . sizeable percentage of Swale’s real population Change agreed. might not be able to live. The one relevant thing the Masterplan does refer to is the set of socio- economic indicators that show the area to be about the worst in Kent – yet nothing is done to tackle one of the six issues that make up the indicators (disability). This is despite guidance from the World Health Organisation, The DfT’s own Joint Mobility Unit, the RNIB and Guide Dogs and other bodies.
States that there are already quite a number of blind people in Rushenden and the allegiance to shared spaces without the considering caveats Add a reference to disabled bays on page 86. Remove parking therein will cause blind people alarm at the widths on the pictures as this would be dealt with at a planning prospect of tackling them without the certainty they application stage. need to cross the road. The dimensions quoted for Change agreed. some parking examples will make it impossible for disabled people to use the spaces.
States that catering for the requirements of disabled people is something that needs to be covered at the design stage rather than later when The Masterplan does not banish visitor parking to distant locations. it might be too late. We are a very significant and No change agreed. normal (and growing) part of the community. The absence of inclusion of disability issues in the submission is not helpful. There is no Local Plan policy so it cannot be on the list but there are generic inclusivity policies here which cover disability. No change agreed. Specific Comments This is an existing land use and therefore cannot be dealt with Housing through the Masterplan. No change agreed. States that the report makes no reference to the need for providing housing for the people who actually populate real communities. Accessible Change text to black or blue in bold. housing needs to be taken as standard. Change agreed.
States that the Masterplan makes no reference to lifetime homes and a verbal comment at the See earlier point on Lifetime Homes. No change agreed. RefNo Fullname Organisation Comment Response
launch meeting seemed to indicate that this was a minor afterthought that could be left to a registered social landlord. All housing should be to LH standards anyway to avoid (sometimes Noted. No change agreed. impossible) adaptations afterwards. States that Medway has a policy of 50% affordable housing.
Mentions 2 reports worth taking into account when designing developments - Noted. The World Health Organisation: “Age-Friendly No change agreed. Cities” urges designers to bear age and disability factors into housing and town design. The report is available through http://www.who.int/ageing/age_friendly_cities/en/in dex.html
States that the Joseph Rowntree Foundation: instigated the concept of Lifetime Homes and their “sixteen points” identify the specific requirements that have been adopted by all the relevant organisations. http://www.jrf.org.uk/housingandcare/lifetimehome s/ http://www.jrf.org.uk/housingandcare/lifetimehome s/partMandLTH.asp http://www.jrf.org.uk/knowledge/findings/foundation s/2.asp
States that all the leading disability charities have accepted these standards. Indeed, Swale Borough Council has its own LH standards.
Disability Facilities Grants
States that it is wrong to assume that housing issues can easily be sorted out with a “DFG” when the need arises. Many houses cannot be adapted Noted. See earlier point on Lifetime Homes. properly and many can only be adapted at huge No change agreed. expense because of poor design in the first place. Says that the whole point about lifetime homes is that you don’t wait for a crisis – design the houses right and years later if the need arises, the solution is there. States that the extra carbon output as a result of undertaking major DFG works is huge in comparison to any marginal output when designing properties correctly in the first place.
Shared space
States that the blind community have taken great exception to ‘Shared Space’ as it would create a no-go area for them. The Masterplan makes no reference to the problem and the critical design issues that might follow consultation. It could be too late to find out that their scheme won’t work.
States that Guide Dogs for the Blind: “Shared Space > > > Safe Space” is essential reading for anyone thinking of imposing a ‘shared space’ on a community. It is available from: http://www.guidedogs.org.uk/uploads/media/Share d_space_-_safe_space_Ramboll_Nyvig_report.pdf RefNo Fullname Organisation Comment Response
States that the Swale Access Group – and other access groups – have come out strongly against the shared space concept because of the problems for blind people. These factors might influence street design significantly, hence it is essential that they are considered at an early stage not as an afterthought.
Parking place dimensions and locations
States that on page 86 the width of a parking space is quoted as 2.4 metres. Quite apart from the fact that the KCC standards have increased that to 2.5m, that width fails totally to consider the need for a disabled person to be able to open the car door wide enough to get in. That is why disabled bays have the 1.2m cross-hatching to the side. Restricting the width to 2.4 would banish disabled drivers from the area. Part M of the building regulations and British Standard 8300:2001 both require the 3.6m width. There is also a worry about a reference on page 90 to a length of 4.8m. It should be 6.0m (see appendix). This all seems to be symptomatic of a failure to consider the needs of a major vulnerable section of the community.
States that it would appear that parking places for visitors are banished to a few distant sites (P61). It will not be possible for some people to visit certain locations and it hardly seems inclusive when the Borough Council has to promote the interests of the disabled community (DDA) 2005).
Inclusivity
State that there are a number of references in the report to aspects of inclusion but no substance evident from a disabled person’s view. Appendix A on page 124 gives about 50 policies. Try finding one that is relevant here.
Land use
States that the Town Council currently meets upstairs in an inaccessible location and although the Borough Council has no jurisdiction over the Town Council, there is an opportunity to rectify something that is unacceptable.
The Masterplan document
States that the chapters are preceded by heading pages that has thin blue print on a dark grey background. It is very difficult to read and will be impossible for anyone with poor sight.
The indicators
States that it might be an over-generalisation but it RefNo Fullname Organisation Comment Response
is nonetheless true that age tends to bring with it the likelihood of increasing disability. It is therefore all the more important that we understand and follow the advice of the World Health Organisation and design “age-friendly cities”.
Swale’s major policies
States that in the recent major policy document “ Shaping the Future of Swale”, the major policy directions are explained. There are four top-level priorities that shape Swale’s thinking and, of course, a welter of legislation to ‘guide’ us as well.
Appendices
The respondent brings our attention to the following extract from the Manual For Streets:
7.2.10 However, shared surfaces can cause problems for some disabled people. People with cognitive difficulties may find the environment difficult to interpret. In addition, the absence of a conventional kerb poses problems for blind or partially-sighted people, who often rely on this feature to find their way around. It is therefore important that shared surface schemes include an alternative means for visually-impaired people to navigate by.
7.2.11 Research published by the Guide Dogs for the Blind Association in September 2006 illustrated the problems that shared surfaces cause for blind or partially-sighted and other disabled people. Further research to be carried out by the Guide Dogs for the Blind Association will consider how the requirements of disabled people can be met, with a view to producing design guidance in due course.
7.2.12 Consultation with the community and users, particularly with disability groups and access officers, is essential when any shared surface scheme is developed. Early indications are that, in many instances, a protected space, with appropriate physical demarcation, will need to be provided, so that those pedestrians who may be unable or unwilling to negotiate priority with vehicles can use the street safely and comfortably.
7.2.13 When designing shared surface schemes, careful attention to detail is required to avoid other problems, such as: • undifferentiated surfaces leading to poor parking behaviour; • vulnerable road users feeling threatened by having no space protected from vehicles; and • the positioning and quantity of planting, street furniture and other features creating visual clutter.
7.2.14 Subject to making suitable provision for disabled people, shared surface streets are likely RefNo Fullname Organisation Comment Response
to work well: • in short lengths, or where they form cul-de-sacs; • where the volume of motor traffic is below 100 vehicles per hour (vph) (peak) (see box); and • where parking is controlled or it takes place in designated areas.
1 The Guide Dogs for the Blind Association (2006) Shared Surface Street Design Research Project. The Issues: Report of Focus Groups. Reading: The Guide Dogs for the Blind Association
The Lifetime Homes 16 criteria
1 Where car parking is adjacent to the home, it should be capable of enlargement to 3.3 m.
2 The distance from the parking space to the home should be kept to a minimum and should be level or gently sloping.
3 Entrance approach gradients should be level or gently sloping.
4 Entrances should be illuminated and covered and the threshold should be level.
5 Where homes are reached by a lift, it should be wheelchair accessible.
6 The width of the doorways and hallways should conform to the Access Committee of England’s standards.
7 Wheelchair turning circle (1500 mm width) in all ground floor rooms and circulation space elsewhere.
8 The sitting room or family room should be at entrance level.
9 In two or more storey properties there should be sufficient space on the ground floor for a convenient bed space if required.
10 There should be a wheelchair accessible downstairs toilet with drainage and service provision to enable a shower to be installed if required.
11 Walls in bathrooms and toilets should be strong enough to allow the use of grab rails and hand rails etc.
12 The design should incorporate provision for a future stair lift and suitably identified space for potential installation of a house lift (through the floor lift) from the ground to the first floor (eg to a bedroom adjacent to a bathroom).
13 The bathroom/bedroom ceiling should be RefNo Fullname Organisation Comment Response
capable of being made strong enough to support a hoist at a later date. Within the bath/bedroom wall provision should be made for a future floor-to- ceiling door, to connect the two rooms by a hoist.
14 The bathroom layout should reflect ease of (possibly side) access to the bath and wc. Washbasins should also be accessible.
15 Living room window glazing should be at 800mm or lower and windows should be easy to operate.
16 Switches, sockets and service controls should be at a height usable by all (600mm to 800mm high)
QR038 Mr D Orpin CPRE - Swale 1/ They object to the dramatic increase in dwelling 1/ The Swale Borough Local Plan allocated this volume of housing numbers from 700 to 2000 as they believe at 700 and the Inspector supported it in his report. This scale of housing will it had a chance of becoming another Whitstable, provide an impetus for services and facilities. The regeneration will but at 2000 it will become an extension of bring the two areas together and not be an extension of Rushenden. Rushenden. No change agreed.
2/ Highlight the need for quality housing to be 2/ There is an identified local need for social rented housing in this area and all the housing provided will be to meet local needs and created, and advocate preventing the Housing designed to a high standard. Associations from building or buying large No change agreed. numbers for of units for social renting. 3/ There is also a community basin proposed for locals and local 3/ They are worried that the document says that people will be able to use the main marina. the Marina will accommodate visiting yachts, the No change agreed. inference being that the residents will not own any. 4/ This is not a Masterplan issue. 4/ They believe that the greenfield development at No change agreed. Thistle Hill will compete for any jobs created at 5/ This is not proposed but existing and therefore outside of the Neats Court. Masterplan's remit. No change agreed. 5/ They object to the proposed imported car parking on the approaches to the Island on the 6/ See Main Report. A249. No change agreed.
6/ They highlight the large area of grazing marsh 7/ The Environment Agency deal with flooding and it has been which will be lost by this development. carefully investigated to be mitigated against. No change agreed. 7/ They highlight flooding as a major issue for this site, worsening as protection to London is implemented. RefNo Fullname Organisation Comment Response
QR039 J Skelton 1/ The respondent believes that there are already 1/ The site allocations and the volume of housing was allocated in too many houses being constructed on the Island the Local Plan and supported by the Inspector. There is both a local which is way beyond any local need. This will and a Swale need for additional housing but some "incomers" will be mean that people will come from elsewhere to fill inevitable. Infrastructure, services and facilities will be provided as them. They feel that there is not adequate part of the development to meet the additional demand and to cover infrastructure, facilities and services and believe existing shortages. that it is a formula for social problems. They No change agreed. believe it is "reckless" and "criminal". 2/ The employment needs to be close to the A249 for access and to prevent industrial traffic driving through residential areas. The 2/ They think the industrial development should be employment will be for both existing and new residents. where the housing is planned, on brownfield land No change agreed. at Caradon Works and Klondyke. Additional employment opportunities are needed for 3/ The principle of housing and industrial development is within the Sheppey's existing population. They believe that Local Plan and compensatory habitat is being provided for any lost the industrial development "is the only part of the grazing marsh. total plan with any justification." No change agreed. 4/ There is an existing need for a link road but the new development 3/ They want no loss of grazing marsh and believe can not happen without it so to link it to the proposal is correct. there is no need for it to happen because without No change agreed. the 2000 houses and industrial development as outlined above there is no shortage of land.
4/ The link road from the A249 is already necessary and to "link it to the proposed Thames Gateway proposal is dishonest."
QR040 Philippa Sambrook GOSE GOSE are very interested in the proposals but Noted. have no detailed comments. No change agreed.
QR041 Mrs W Mayes The respondent highlights the need to complete 1/ Work on the relief road has already begun which will help to the relief road before any work begins so it can be reduce the impact of construction traffic on the existing road network. used to bring in construction traffic. No change agreed.
Questions whether the Council has thought of the 2/ The Environment Agency and other water bodies have been flooding issue and hosepipe bans as the consulted and their comments will be fed into the Masterplan. population increases. No change agreed. 3/ This is a key part of the Masterplan and volume 2 sets out the They believe local services must be built before phasing of services and dwellings. Discussions with service providers any dwellings are built. will ensure their appropriate phasing with development. No change agreed. They highlight the need for facilities for youths in the area as they are already disenchanted. 4/ Youth and community facilities will be provided and are highlighted throughout the Masterplan. They believe transport, especially buses, need to No change agreed. be improved, especially to other parts of the Island. 5/ This is a key aspect of the Masterplan and will be addressed by SEEDA, working in conjunction with the bus and train operators. They are worried about the impact of traffic with No change agreed. 2000 new homes on the roads, buildings and health of the communities. 6/ The Planning Application will need a transport assessment which will deal with this concern. No change agreed. RefNo Fullname Organisation Comment Response
QR042 S Tipping Kent County Council 1/ They note that the principle of development at 1/ Noted. Queenborough and Rushenden is well established No change agreed. in the Kent and Medway Structure Plan (KMSP) 2006 through policies SW1, which allows for a 2/ Given the passage of time and the near adoption of the SEP, there mixed use development at Queenborough and will be seem little to be gained by adding references to the KMSP. Rushenden for housing, employment and Whilst SEEDA has been informed about changes to contributions, community facilities, and EP4, which identifies the document is a living one and will be never be up to date. However SEEDA have been asked to present the latest position. Neatscourt as a strategic employment location. The focus of the residential proposals on re-use of 3/ SEEDA to amend the plan accordingly. previously developed and redundant employment land is in line with KMSP Policy SS4 and the 4/ Discussion concerning the school and sports centre are ongoing mixed use nature of the development is with SEEDA. See Main Report. encouraged by Policy QL5. 5/ With respect of the management of the Planning Obligations 2/ They state that the Masterplan refers to the Strategy see Main Report. Kent Design Guide (Policy QL1 of the KMSP 6/ It would not be appropriate to address questions of Sheerness Port refers) but they would welcome further reference in this document. This is a matter for the LDF. to the KMSP in the policy section in light of the KMSP’s continuing role as part of the 7/ SEEDA have been asked to review all of the specific comments development plan until the South East Plan is made in respect of the various volumes. adopted. They welcome references to KMSP policies, although those on page 3 need to be 8/ Amend page 70 to strengthen the role of Kent Design. The amended to SW1, EP4 and QL12 to reflect the sketches contained in the Masterplan document are conceptual and adopted version of the KMSP. would not have any weight at the planning application stage.
3/ They state that the section on environmental 9/ This detailed point can be clarified at the planning application stage. factors (page 32) does not separately distinguish the North Kent Marshes Special Landscape Area 10/ A general reference to this point could be made on page 101. designation (KMSP Policy EN5 refers), which Change agreed. adjoins the Masterplan site to the south. 11/ The use of higher buildings is targeted to particular focal points. Service provision and development contributions The point concerning Rushenden Road is noted, but have been included to make a focus at the proposed 'Rushenden Square'. The 4/ State that Policy QL12 and IM1 of the KMSP block would be a little distant from existing 2 storey development, require that provision for new community facilities although it would be reasonable to make an appropriate reference in the document to the need to avoid overwhelming existing buildings. be identified in LDDs and that where needs arise Change agreed. from development, contributions can be required to meet the costs of providing the necessary 12/ The images used to illustrate the document are not intended to infrastructure. There have already been extensive represent the definitive design approach. However, perhaps some negotiations on the matter of development examples to illustrate how development has responded to built contributions with KCC officers and consultants. heritage would be appropriate. Change agreed. The proposals as they are currently presented would result in the following: 13/ It is agreed that reference should be made on page 95-97 to introducing marshland plants into the heart of the scheme and the biodiversity benefits that would result. Change agreed. ·Education (including adult education) will require a contribution in the sum of £11,537,976 to include 14/ It is agreed that reference could be made to the use of green the cost of land purchase. The land acquisition roofs to create a green roofscape on relevant parts of the document. price is not to exceed £1m. Should it do so then Change agreed. SEEDA should absorb the uplift. i.e. the contribution made to KCC Education shall not be 15/ This is agreed, but is not directly related to the development. It is less than £10,537,976. Education will require a envisaged that this will be progressed as part of the Green Grid site of not less than 2.05ha inclusive of playing Initiatives. fields and this must be for their exclusive use. Some family /child facilities (i.e. a couple of 16/ This has been discussed with SEEDA who are considering this issue. See Main Report. rooms) will need to be provided at the school site as part of the overall development. 17/ The point is noted, but does serve to illustrate other wider initiatives. No change agreed. ·Adult Social Services will require a contribution of £2,705,520. 18/ This issue appears to have been addressed. No change agreed.
·Youth and Communities and libraries will require 19/ An Appropriate Assessment has been prepared. SEEDA will be a contribution of £1,395,585. asked to ensure that it's recommendations are included in the Masterplan. See also Main Report. RefNo Fullname Organisation Comment Response
All of the above contributions will need to be index 20/ It is agreed that such references should be incorporated into the linked and the proposals for this in the Project Masterplan. Change agreed. Delivery Report are noted. 21/ Noted. The library service have previously indicated that they would require a small amount of space in the community centre (i.e. a kiosk or information point) as the major facility would be in the new building at the old school site in Queenborough.
State that there is some uncertainty regarding the possibility of joint arrangements with the Primary Care Trust for the delivery of adult services and health services in a new building. Adult social services would welcome shared use of the health care facility but are unlikely to want to use a significant amount of their funding on the provision of a new building. They would also like to provide some sheltered residential care units (probably for 4 persons) at Rushenden or nearby, and to run the community cafe at the old school site at Queenborough, which may mean some subsidy or calls on the funds.
State that there has been some discussion in respect of the provision of a sports centre within the overall development. This should not be incorporated with the school facility, but it could be on land nearby if space permits. KCC is not responsible for the delivery of this facility.
5/ The Planning Obligations Strategy is recommending that contributions are held in two designated accounts, one held by KCC for matters within its statutory remit and one held by Swale BC. This arrangement is essential. SEEDA appear to have recognised the case for forward funding some community infrastructure which is seen as sensible in the circumstances. KCC will want to look carefully at the triggers for the release of the monies from the KCC held fund. Service providers will need to draw down their financial requirements as development progresses. It is noted that contributions under the tariff would be ‘ pooled’ and not ring fenced to specific facilities. The basis for apportioning the contributions collected to the two accounts should be clearly spelt out.
They note that the affordable housing quota is only 25 percent with an additional five percent of development value being used to improve the existing stock of affordable housing in the area and /or its environment. This is consistent overall with the affordable housing percentage proposed in the current Local Plan review. Certainty for the longer term as to the proportionate contribution to affordable housing to be sought is desirable in terms of securing the economic viability of the project and the full range of its community and infrastructure provision envisaged.
6/ They believe that the Masterplan does not RefNo Fullname Organisation Comment Response
address the future use of the Port of Sheerness land which lies in the central part of the development area. An indication of the approach to future development of this land, regardless of ownership, would be beneficial to allow for the coherent planning of the whole area and clarity as to its role, if any, in contributing to the infrastructure requirements and costs associated with regeneration of the Masterplan area.
7/ The suggestion that incubator units be provided with the employment uses is supported and should be subject to funding under the commercial tariff process.
The Masterplan refers to the uses at the Gateway centre (formerly the Jewsons building) and its role in capacity building, yet little information is provided about what these activities include and where they might go in the final development.
Specific comments relating to Volume 1 regarding development contributions:
P.44 - Plan 3.1 - Reference 24 - Delete "with adult education" as this is not easy to accommodate within a primary school.
P.43 - Plan 3.1 - Reference 28 - Delete "community playing fields". Subject to the educational needs of the school the playing fields may be capable of use for structured team games outside school hours but not informal use i.e. dog walking.
P.49 - Residential Proposals – Policy HP6 of the KMSP 2006 encourages developments to include homes built to lifetime homes standard but no reference is made to provision for this in the Masterplan. Provision should be made for a percentage of the development to meet this standard.
P.57 - Table 2.4 - Community Space/Facilities - The site area for a 2FE (Form Entry) school is 2.05ha and the area for the community facilities (Reference 22 - Plan 3.1 - P.44) should be quoted separately.
P.57 - the reference to a health care facility should be expanded to include adult social services. References to the health care facility could be re- titled as health/community/social facilities.
P.57 - The proposed primary school - Delete "including the sports fields".
Specific Comments on development contributions relating to Volume 2:
P.26 - 4.28 - Although 4.39 (P.29) indicated that costs are at 2nd quarter 2007 this needs to be emphasized either within 4.28 or better still as a RefNo Fullname Organisation Comment Response
note before section 4.25.
P.27 - 4.31: 4.32 & 4.32 (1) & (2) - Comment as above.
P.27 4.32 (2) - Because of the financial constraints and to ensure infrastructure and services are ready and capable of servicing the community prior to completion of development the phasing of payments should be brought forward. The following is suggested:-
·30% payable upon completion of 25% of the development. ·A further 30% payable upon completion of 50% of the development. ·The remaining 40% playable upon completion of 70% of the development.
P.27 - 4.33 - Please add a new sentence to this section. "In this respect KCC revise their costings on an annual basis and the contribution payable to the KCC held fund should be based upon the latest figures”.
P.27 - 4.34 - Reference to "standard unit rate" in the last line - need to clarify what this rate is as at 2nd quarter 2007. Is it 4.32 (1) (b or c).
P.28 - 4.36 - I assume reference to "section 3.11 below" is incorrect.
P.29 - 4.39 - Suggest additional wording at the end of the existing sentence "either by virtue of 4.33 above and/or indexation.
P.29 - 4.41 - Amend to read "The contribution payable will be the contribution set out in 4.32 (1) above or as varied by 4.33 and/or 4.40. Where indexation is to be applied the revised contribution shall be calculated by multiplying the existing contribution by the percentage increase in the index specified in 4.40 above from the 2nd quarter 2007 to the quarter date immediately proceeding the date of the actual payment of the contribution for the development in due course.
P.29 - 4.45 - Need to mention that 'long stop' triggers may need to be reviewed.
P.46 - Appendix 3: Table 1 - Notes - item 1 - delete reference to £1m and amend to "including an allowance for land purchase".
P. 46 - The requirements of adult social services could be better reflected in Appendix 3 (notes) of Volume 2, Project Delivery. Wording could incorporate the following:
“The contribution will be utilised to provide permanent or flexible infrastructure and services for the benefit of the community. This may include new buildings or the renting of space to provide RefNo Fullname Organisation Comment Response
services; for example (but not an exhaustive list):-
·A social enterprise community cafe for the training and development of those with learning difficulties and/or other social groups. ·Respite flats for those with learning and physical difficulties, including training space for transition to independence. ·Drop in facilities, information and activities, shared space for psychologists, psychiatrists, care managers etc. ·Adult changing and washing facilities. ·Space for the elderly i.e. social activities etc. ·Other services considered necessary which will benefit the community.
It is currently envisaged that provision of these services will be delivered within new facilities constructed as part of the development and Masterplan proposal or nearby in existing buildings. These buildings may be a new or existing community hub(s)/centre(s), GP practice(s), the Old School & Library etc.”
P.46 - Appendix 3: Table 1 - Notes - item 9 - Amend second sentence to read "Anticipated to be provided in close proximity to the primary school and the potential for shared use can be investigated.
Design concepts
The design concepts promoted are welcomed. The high degree of local consultation and involvement across the age ranges is to be applauded.
8/ The reference to the Kent Design Guide is welcomed as the regeneration project in the area provides a real opportunity to show case the work of the Guide and provide an exemplar of good design. References to the role of the Guide in guiding development could be strengthened; for instance page 70 could refer to the need to judge developments against not only the Masterplan and national guidance but also county guidance such as Kent Design. Believe that development at Queenborough and Rushenden provides a real and substantial opportunity to work with house builders to secure this higher quality. As the Masterplan only provides sketches and indicative drawings it is important that the thorough approach of Kent Design is used to inform future development at Queenborough and Rushenden alongside its Green Charter.
They have some concerns around the contextual relationship between the old town of Queenborough, Rushenden, the surrounding marshland and the development proposals. Although sound conclusions are drawn through the analysis, the supporting images let down the overall message. It may be misguided to allow RefNo Fullname Organisation Comment Response
sketches to suggest a building ‘style’ in master planning exercises The sketches suggest a ‘stock’ , urban solution in building terms that convey not only a conventional building style but conventional layouts and landscape approach as well.
9/ One of the concepts establishes a spatial street hierarchy, with the path identified as the lowest level. This is defined as “primarily a pedestrian route but accessible for emergency vehicles and refuse collection” (p.85) although the picture of the path on p85 clearly does not fit with this description. Is further information about their proposed usage needed to provide further clarification?
10/ The sensitive approach identified to lighting under principle 7 is welcomed although reference could be made to the need to design lighting, in terms of type, positioning and timing, to have a minimal impact on nocturnal biodiversity, such as bats.
Height and density
11/ The Masterplan proposes a range of heights across the development, from 1 storey to over five storeys. There are some reservations about the density of the new development and the building heights proposed. The flat, marshy landscape is horizontal in nature and although there are pockets of high density (80 dph) in the old town, this is not expressed in height, the standard being 2 – 2.5 storeys. The use buildings of five storeys or more therefore needs to be carefully located; for instance the proposal for five storeys plus along the Rushenden Road near Rushenden risks overwhelming the existing buildings and making integration between the old and the new more difficult. The development of taller buildings is accepted as more appropriate around the marina area, which would enable the opportunities for development along the waterfront to be maximised.
12/ The need to ensure that the built heritage is preserved and new development respects the local context is recognised on page 73 but this principle does not seem to have been carried through into other parts of the document, particularly the images used to describe potential development. New development must ensure that it is sympathetic to the existing surroundings, especially given the aim to integrate Queenborough and Rushenden with the new development.
Landscape
13/ They welcome the requirement for buildings located adjacent to sensitive landscape (such as those in Neatscourt adjacent to the marshes), to be sensitively designed to ensure minimal impact RefNo Fullname Organisation Comment Response
on the landscape (p. 78 and p.95). There is reference to the need for key gateway buildings along the A249 (p81) which should also meet the criteria of sensitive design and minimising impact on the landscape.
They support the concept of preserving water through run-off and the provision of SUDS and is a judicious response to the ditches of the marshland landscape. A network of ditches and swales would provide the opportunity to introduce rushes and other marshland plants right into the heart of the development, thus providing corridors for local wildlife. Although trees are few and far between in the island’s open landscape shows of willow, elder, thorn and other local species could provide a more interesting solution than the suggested standard ‘lollipop’ street trees.
14/ The landscape ‘feel’ could be enhanced by an aspiration to create a green roofscape for much of the development and would have a number of benefits as well as blending with the marshland context. Green roofs and green porous hard standing (car storage area) would help minimise rainwater run-off. Green roofs can also provide undisturbed habitat for a range of more unusual plant and insect species.
15/ Access from the development into the surrounding country has been considered, but falls short of an aspiration to create a new section of coastal path that could be used by everyone that would contribute to the Government's Coastal Path initiative.
Sustainability considerations
Believes that the latest version of the Green Charter represents a significant improvement on previous versions and the targets and monitoring table has been updated to reflect current thinking on sustainability standards, with built in provision for review as these standards become more challenging.
16/ They welcome the provision for Combined Heat and Power (CHP) but state the timing of site acquisition for the plant is highlighted in Volume 2 on Project Delivery and comes at the front end of the development. However, there is no indication of the timing for construction of the plant or the point at which it will become operational. This is crucial given the key role of this infrastructure in helping to achieve higher standards of sustainability and to reduce CO2 from energy use. Provision of the CHP plant should therefore be linked in someway to construction of the new housing and its occupation.
17/ State that plan 4.12 refers to eco-tourism but this is not carried through elsewhere in the RefNo Fullname Organisation Comment Response
document and the proposed area for this is outside the master planning area. Further explanation of this should be included or the reference should be removed. The sustainability considerations and sustainable construction techniques set out should be vigorously pursued, in line with KMSP Policy NR1.
Transport
18/ The provision of cycling and pedestrian links and the provision for cycle storage across the development is supported in taking forward the principles of KMSP Policies TP3 and TP11. The Masterplan treats increased connectivity across the development as a key principle and this is supported, but it is equally important that wherever possible, cycle paths should connect to existing cycle and pedestrian routes outside of the development area. The proposed public transport improvements, such as changing bus routes, are also welcomed.
Biodiversity and Landscape
The Masterplan site is adjoined by important national and international nature conservation designations and to the south by an area designated for its strategic landscape value (North Kent Marshes SLA). Sensitive treatment of the interface between the Masterplan site and these areas is needed. This is recognised in the Masterplan, for example it recommends that development in the Neatscourt area, nearest to the Marshes, is low storey to minimise impact on the landscape.
19/ State that given the proximity of the Masterplan area to the Medway and Swale Estuary SPA the question of prospective impact on the integrity of the SPA, and the species/habitat for which the SPA is designated, does arise. Whilst this and the nature of ecological mitigation/compensation is considered within the context of the SA/SEA there is no indication of the outcome of a screening process for the relevance of Appropriate Assessment and the probability or otherwise of significant effects on the SPA arising from development of grazing marsh at Neatscourt and or the proposed marina. State that whilst the Masterplan is ‘fleshing out’ proposals where the principle of development has been previously established in ‘higher level’ development plan documents, their timing has not involved formal consideration of Appropriate Assessment.
The need to identify land as compensation for the loss of environmentally important habitat to the development is recognised in the Masterplan (page 10) and the Project Delivery report (page 34) and has been an issue in the recent consideration of specific planning proposals for the Rushenden Link Road and Phase 1 of the RefNo Fullname Organisation Comment Response
employment development at Neatscourt. It is in this part of the Masterplan area where impacts arising from the loss of grazing marsh are primarily located as in recognised in Volume 2 Project Delivery – Zone B Phasing and Triggers. Believes it would be helpful for the Masterplan to set out more fully the nature of the ecological mitigation measures that may be required e.g. in terms of habitat replacement and /or enhancement also but also the reasons for this. This is set out more fully in the SA/SEA including the principles and considerations that should apply to habitat replacement/enhancement and possible locational opportunities for this. It is noted that the any mitigation measures would have a claims on the funds generated by the Masterplan’s contributions strategy.
20/ KMSP Policy EN8 states that wildlife habitats and species should be protected, conserved and enhanced, and the recognition given to improving biodiversity in the Masterplan, for instance through the provision of varied landscapes, a nature conservation area near the Creek and wildlife corridors, is supported. Other opportunities for improving biodiversity, such as providing space for nesting birds or bats, would also be welcomed and could be stated in the biodiversity section of the Green Charter.
21/ KCC would wish to be formally represented on the Queenborough and Rushenden management panel. RefNo Fullname Organisation Comment Response
QR043 Phil Garland SBC - Housing Services They believe their views need to be taken into 1/ The points are noted, but not entirely shared. A wide number of account to achieve the aspirational goals set out in initiatives intended to assist with integrating communities are the Executive Summary and to meet the needs of underway/proposed. It would be helpful however if page 7 were the new and existing communities. updated and fleshed out. Change agreed.
Specific Comments include - 2/ Where factual errors are pointed out these should be changed in the final version of the Masterplan.
VOLUME 1 MASTERPLAN 3/ See response to point 1.
1/ Pg 7 – Introduction 4/ The reference to the Code and Lifetime Homes should be made. Paragraph 6 - Important statement regarding Change agreed. Queenborough and Rushenden appearing to be being separate communities, but does not get 5+6/ Questions relating to CHP and SUDS are detailed points to be expanded upon or explored in the rest of the considered at a later stage. No change agreed. document, Rushenden remains marginalised throughout. 7/ The issues are considered to be adequately covered. No change agreed.
2/ Penultimate paragraph talks about Rushenden 8/ It is understood that data cannot be produced for the separate but the area it refers to is actually Queenborough. communities. No change agreed.
3/ The final section of the last paragraph still 9/ This section describes the existing situation. No change agreed. ignores the periphery of Rushenden only talking about Queenborough, the new build and the main 10/ SEEDA will be asked to clarify this data. road in Rushenden. This does not help link the existing Rushenden community with the new 11/ This s a detailed point. No change agreed. development or the parts of Queenborough that 12/ It is agreed that the paragraph is a little difficult to are not included in the development area. understand.SEEDA will be asked to clarify it. Change agreed.
4/ Pg 11 – Sustainability 13/ This page should be updated in the light of more recent work. This refers to Eco-Homes very good but should Change agreed. talk about the Code for Sustainable Homes Level 3 but as it is SEEDA I expect to see either 4 or 5 14/ Such matters can be given no future certainty at this stage. achieved. Must also talk about 100% Life Time Homes if it doesn’t meet Better Homes within 15/ See Main Report. Code for Sustainable Homes. 16/ See Main Report.
5/ Exclusive use of CHP removes buyers options 17/ It is considered that there are limited further opportunities beyond to use gas etc – could impact on sales. those identified. However, these can be further examined. No change agreed. 6/ High maintenance issues of SUDs plus pest (mosquito, midge) control. 18/ These issues are not appropriate matters to be addressed by the Masterplan. No change agreed. 7/ Pg 22 – Context No mention of Rushenden in Queenborough and 19/ See Main Report. Rushenden today, physical indicators. 20/ This is a detailed matter. No change agreed.
8/ Socioeconomic Indicators paragraph does not 21+22/ The point is noted, however the opportunities to extend SUDS talk about percentage of social housing in further is limited. No change agreed. Queenborough so presents a distorted picture of the regeneration area as a whole (they understand 23/ Noted. No change agreed. that this is the base being used for the 25% provision across the site). 24/ Theses are too detailed points at this stage. No change.
9/ Final paragraph, first column - how will the lack 25/ Such matters are the subject of on-going discussions with KCC and the RSL and SBC. No change. of investment and low property values be overcome? Owner occupiers in this area are on 26, 27+28/ These are detailed points that can be discussed outside low incomes and unable to finance works of the masterplanning process. No change agreed. themselves 29/ Noted. No change agreed. 10/ Pg 25 – Rushenden The level of social housing in Rushenden is 30/ This is intended to illustrate the facades on the new development 33.4%, yet the Masterplan says approx 50%. See areas. No change agreed. also comments P26 of Delivery Plan. 31/ Yes this effect was considered by the masterplanners. No change RefNo Fullname Organisation Comment Response
agreed. 11/ Pg 32 No mention of the impact that SUDs might have 32+33/ This is too detailed for the masterplan.No change agreed. on the “waters”. 34/ The map illustrated shows existing and those within the development area. No change agreed. 12/ Pg 36 Condition Survey. An extremely confusing 35/ Theses issues should be addressed elsewhere. No change paragraph, which needs rewriting. Also mixes agreed. tidal flooding parameters with river flooding parameters and applies them both to the same 36/ See Main Report. situation. 37/ The first comment is too detailed for the Masterplan. The plan will 13/ Pg 37 be amended to show the correct labelling. Change agreed. Flooding estimates based on existing data and no 38/ See Main Report. allowance for climate change effects or future predictions. Unrealistic. 39/ SEEDA will be asked to comment on these views. See also Main Report. 14/ Pg 44 Very little development in Rushenden confirmed. 40/ Theses areas are outside the AAP and as such it would not be Areas 24 and 26 are only “potential”. reasonable to collect monies for these areas. No change agreed.
15/ Pg 47 41/ The Delivery document sets out how money will be collected and Danger that flats around Marina will become the Section 106 agreement will state how the money will be spent. S106 Agreements are legal docments and therefore must be second/weekend homes – no input into adhered to. No money will there get 'lost' in the system. community. While not wishing to undermine the No change agreed. development of the marina and its potential for employment, boating/yachting is an expensive 42/ This is a detailed point, however reference to the Council's pastime probably beyond the reach of most Developer Contributions SPD which contains much of this detail locals. Additional affordable leisure facilities need would be appropriate in Volume 2. See also Main Report. Change to be considered. People from Rushenden will not agreed. visit the Marina areas if its shops and cafes are too expensive and aimed at a yachting clientele. 43/ SEEDA have been asked to clarify this point. The integration of Rushenden is mentioned in the 44/ SEEDA has been asked to review the Green Charter and final paragraph of this page, but is not carried consider these points. through in the rest of the document.
16/ Pg 51 – Residential – A mix of tenures and sizes 25% affordable – this should be 30% in line with Council policy. Want equal percentage of sizes and types – 30% per phase pepper-potted in clusters of 6 50 metres apart. Mix will be 60:40 rented: shared ownership.
To quote the Local Plan inspector with regard to this in his comments on the new Local Plan “Over and above those sites already with planning permission to the south of this site, it is estimated that there is the potential to yield some 1,900 dwellings on this site over the next 15-20 years. This will be considered in more detail in the Master Plan. A range of housing types will be provided, but, it will be the highest value housing that will have the greatest potential to lead the regeneration of the area, though 30% of the new homes provided will need to be affordable. The Council wishes to promote high standards of design and will use the Regional Design Panel to help ensure that the standards of design on this development reflect the importance attached to this site as a catalyst for regeneration. It will also be an ideal opportunity to promote some energy efficient homes. RefNo Fullname Organisation Comment Response
For the land and buildings south of Queenborough Creek, the Master Plan will need to:
2. promote a mix of new housing, including 30% affordable provision to meet the needs of those unable to enter the housing market unassisted; 3. foster a high degree of innovation and creativity in design and layout, including the provision of some houses as energy efficient;
17/ Pg 58 Need for more cycle routes in Rushenden and parts of Queenborough. Most routes are concentrated in the new housing areas.
18/ Pg 61 The particular problems of First Ave (Bordering Caradon Site) and part of Second Ave have not been picked up. Parking issues/unmade roads.
19/ Pg 62 CHP plants appear to be in isolation to the ring mains. Rushenden is left off initial CHP ring. There are high levels of fuel poverty in Rushenden which could be tackled through connecting to CHP at an early stage.
20/ Pg 63 There is a danger that the SUDs will be high maintenance. Regular cleaning will be necessary. If rubbish is allowed to enter them they will not work properly.
21/ Pg 64 Despite the comment above, SUDs could be used to develop some water features in Rushenden, thus increasingly the link to Queenborough and continuing the theme.
22/ Pg 65 SUDs paragraph This states that SUDs will be used “throughout the Masterplan area – this is clearly not the case.
23/ Pg 75 – Linking Queenborough and Rushenden Infrastructure Is Rushenden square technically in Rushenden, they would say it was more Queenborough. It is the link between Queenborough and Rushenden, but nothing seems to be in Rushenden itself.
24/ Amenity The brief does not explain what new initiatives will actually provide for Rushenden e.g. footpaths linking the marina and Swale Side Park, what street scene work will actually be carried out? Need specifics.
25/ Development Definition of partnership – SEEDA are stating what they require and are not acting in line with SBC policies. Also there is little evidence of KCC Social RefNo Fullname Organisation Comment Response
Care being consulted. Refers to “may be opportunities for some redevelopment of existing buildings and sites within Rushenden such as Manor Road; the centrally located sheltered housing block that does not meet the standard required for future needs”. ·How are these going to be funded – Social housing is the responsibility of the landlord not the Masterplan and commuted sums derived from the regeneration. ·The land vacated by Rushenden Court can be redeveloped by Swale HA and should not be funded by the project. ·Any commuted sums raised should be invested in streetscape and the private sector. ·There is no mention of Queenborough in this – what about the areas outside the development area i.e. Harold, Stanley, Gordon Ave location.
26/ Housing opportunity ·What land adjacent to Rushenden is referred to here? ·The affordable housing needs to be pepper potted throughout the site in clusters of no more than 6. ·Serious plans need to be tabled to break the mono-tenure in Rushenden possibly via “property swaps” with the new build but not to the detriment of 30~% provision within the new build. (Additional social housing is NOT required in Rushenden). ·Reducing the percentage affordable housing provision in the new build will be detrimental to future aspirations of people who wish to reside in the whole area. ·Bringing the “new” into Rushenden should be about “property swaps” (owner occupation) not new affordable provision.
Integration 27/ ·What environmental improvements are being proposed? ·How will this be funded – little/no explanation of the Contributions Strategy. ·Need an explanation of the First Avenue proposals. I would suggest a tenure approach of: Social housing in the new build mixed with the existing social housing represents good integration.
28/ Sense of Place ·Need to explain what the new development in Rushenden will consist of (and how is this being funded) ·Need to explain how the physical connection and integration…. Will make Rushenden part of a bigger and exciting place.
29/ Pg 76 There are no landmarks in Rushenden – all views look away. Church spire view will be blocked for some people by the flats. RefNo Fullname Organisation Comment Response
30/ Pg 78 Most of Rushenden and some of Queenborough left out. Is not the facade of the Victorian houses in First Ave where it meets the new development not a ‘key façade’?
31/ Pg 83 Has the effect of wind channelling through the apartment blocks been considered?
32/ Pg 88 SUDs Streets. High maintenance – will need regular cleaning.
33/ Pg 95 What about pest control within SUDs? Any stagnant water will be a breeding ground for mosquitoes and midges. Where these are below flats this could be a particular problem.
34/ Pg 98 Lack of landmarks and hotspots within Rushenden
35/ Pg 103 – Sustainable Development at Queenborough and Rushenden. ·There is no mention of the Code for Sustainable Homes. ·There is no mention of Life time Homes. ·There is no mention of Commuted sums for Telecare.
36/ Pg 108 Danger that existing local population are priced out of both housing and amenities.
37/ Pg 112 ands 113 No mention of the source of funding for private sector regeneration. Arrows not labelled on plans.
VOLUMN 2 -PROJECT DELIVERY
38/ Pg 16 – Amicus Horizon/ Housing Association Partners ·There is no mention of Queenborough here at all. This ignores a section of the population purely due to their location. ·Investment in the RSL properties in Rushenden, both social and physical infrastructure, should not be funded at the expense of the provision of new affordable homes – Upgrading existing homes is the landlords responsibility so should be funded from their Business Plan. ·30% affordable housing should be provided on site. After this has been accounted for a view could be taken as to whether an additional 5% could be provided to finance work to private sector properties that otherwise will not see any benefits from the scheme. (At no stage should any funding of this type be used to benefit RSL properties where funding could be raised from other sources). This money could be used to fund streetscape issues as well as renovation grants for the private sector. RefNo Fullname Organisation Comment Response
·It is important that Queenborough is not forgotten in all this. ·30% provision is important in planning for the current and future (plus aspirational) housing needs of the Borough. The 2005 Housing Needs Survey Update states SBC needs 495 new affordable housing units per year to meet its current need alone. ·Also, when considering the percentage affordable housing provision reference should be made to the Corporate plan and objectives;
·RS14 - Provide assistance to improve the poorer private sector housing and reduce the number of empty properties across Swale. ·RS15 -Continue to work with partners to develop affordable housing options that meet the needs of the Swale communities . ·RS16 - Continue to work with partners to prevent homelessness and to meet the housing needs of vulnerable people in Swale.
Whereby it highlights the Strategic Priorities of the local authority in meeting its unmet housing need and providing sustainable homes for all.
39/ Pg 23 – Affordable Housing
·The % of social housing in Rushenden is 34.4% yet the plan states 43%. More importantly it fails to consider the level of social housing across both Queenborough and Rushenden. This figure will be much lower as the % of social housing in Queenborough is just 13.5%. ·When referring to Rushenden the plan only ever talks about the Manor Road area, no mention is ever made of the area to the right of Rushenden Road as you head south. ·Other than not agreeing to 25% affordable housing provision and using 5% of the money to invest in existing social housing that is the landlords responsibility, if a commuted sum where to be considered on the lines originally suggested whereby there was a 30% on site provision and 10% commuted sum, what are SEEDA planning to use this money for? The plan only alludes to “ doing up” the affordable housing equating to double subsidy. ·The funding arrangements are unclear. How is the £1.5M generated to be used? Is the extra £1000 in lieu of the on-site provision to be levied, limited to the 5% (100 dwellings) and is this in addition to the £1.5M? ·There is no mention of the much-needed investment in the private stock, 17% of which is categorised as unfit, either in Queenborough or Rushenden. No thought seems to have been given to the private stock on the fringes of the Masterplan area that do not seem to get any direct gains from this development. ·There needs to be some detail about property and tenure mix, location, phasing and clustering of RefNo Fullname Organisation Comment Response
affordable provision. Also there is no mention of either cost or Life Time Homes. ·All sites need to have a phasing strategy so that each site is subject to 30% provision pepper potted in clusters of 6 across it. ·Also, there is no mention of Supported Housing (other than one oblique reference to a sheltered housing scheme), which supports my fear that Social Services Adult Team has not been consulted on either the current, or future needs (especially those that will arise over time, including the length of the project, due to the population growth).
40/ Pg 25 – Methodology for calculating communal infrastructure payments The boundaries for the development miss out a lot of Queenborough so any commuted sums raised will be needed to invest in the private sector in this area.
41/ Pg 26 – Establishing the Contribution Levels 4.27 – There is no structure as to how the sums will be raised or what they will be spent on. Nor is there any indication of how these will be future proofed; ·Items ‘get lost’ especially if the project goes over budget and compromises have to be made. ·Need to state that the S106 enshrines items absolutely and is not negotiable as it is a legally binding sealed document that states what will be done. The current statement is not strong enough and offers too many ‘escape routes’.
42/ Pg 35 – Phasing and Triggers 30% affordable housing provided on site should be provided per small parcel/phase (which ever is the smaller) i.e. Zone C = C1 = 30% = 90 units C2 = 30% = 210 units C3 = 30% = 600 units
This will be provided in clusters of 6 pepper potted throughout the phase sited at least 50 metres apart. This ensures all residential properties are tenure blind. 100% of the affordable housing will be to a minimum of SBC’s Life Time Homes Standard (the same should apply to the houses for sale). The properties will meet a minimum of Level 3 of the Code for Sustainable Homes and will be a minimum of 60% rented, 40% shared ownership. Cost will be no more that 50% TCI (or the equivalent that is in place at the time) to include all on-costs. The provision of affordable housing will reflect the types of units provided in the relevant phase with two notable exceptions; ·20% of the units will be to wheel-chair standards (these will mainly comprise of 3 bedroom houses) ·Provision of 5 and 6 bed units in order to meet the affordable housing need. RefNo Fullname Organisation Comment Response
The approach of 305 per small parcel ensures; ·The scheme is easier to monitor for compliance with the Brief and S106 ·Is tenure blind ·The affordable housing is delivered equitably in fair timescales. This means as the community grows it is sustainable (and the affordable housing does not end up being squeezed in on mass to ensure compliance with the S106 e.g. East Hall Farm and Fulston Manor verses the Thistle Hill experience.
Pg 44 – Table 1 – Indicative infrastructure requirements and costs 4. Affordable Housing Off Site Affordable Housing Contribution This was not the original intention of the 30:10 split for the 40% affordable housing contribution. It was aimed at investment in private housing in the areas both within and adjacent to the Masterplan area (e.g. Queenborough).
43 The indicative costs are shown as £37.567M yet the contribution totals from the various zones appears to total £28.769. There is a shortfall of £9M.
The section does not make clear how this is to be met. Are elements of the Masterplan not currently funded.
44/ SUPPORTING VOLUMN - THE GREEN CHARTER
Pg 11 Retro fitting of existing stock is not mentioned and could be done to improve energy and water efficiency? Non-residential savings very vague and not ambitious enough. Should aim for the higher savings of 50% in non-residential buildings.
Pg 12 Water – no mention of how these targets will be achieved – dual flush toilets, low flow taps etc??
While 155 litres is the correct national figure for water consumption, in the South East it has been closer to 165 and this should be reflected in this document. Reductions in water consumption should not incur a fall in standards of living. No mention of grey water recycling. Rainwater harvesting has limited use in blocks of flats.
Pg 13 Blue bin scheme has been rolled out.
Pg 14 Transport Public transport must be improved as stated in the plan. RefNo Fullname Organisation Comment Response
Car parking space is very limited and will be difficult to enforce if alternative transport is not in place.
Pg 19 Urban Design and a Sense of Place. Important that the social housing is built to a standard that does not mark it out from privately owned property.
Pg 21 Materials and Procurement. No mention of using rail or sea to transport materials to site. Difficult to source materials on the island.
Pg 22 Buildings and Buildings Performance. Enforcement of standards beyond building control regulations may be difficult.
Pg 26 -28 Sustainability Targets and Monitoring: Green Charter Table Affordability 2007 Performance Standards: Building Regulations/Local Plan; SBC Local Plan encourages 25% of housing to be affordable…. Their understanding is not only do we have an adopted policy of 30% that is being reflected in current S106 agreements so what makes this scheme so different, but we are also working to the First Review Re-deposit Draft of the Local Plan that states 30% (Policy H3, point 3.115 page 57). Finally, the inspectors comments on the new Local Plan recommends 30% The Draft Local Plan originally stated 40% provision for this site and due to the nature of the scheme we should be stretching the boundaries here to prove that Swale (and SEEDA) can lead the market on the provision of affordable housing within the Growth Areas. Important that rigorous monitoring occurs and this feeds back into the targets for later stages of the development. Need for householder education to achieve some of the targets (particularly relating to energy, water and waste). RefNo Fullname Organisation Comment Response
QR044 Rebecca Moberly Natural England Given the importance of the project, they believe 1/ Agree. The principles of sustainable development are integral to that the regeneration should fully encompass the the Masterplan.However SEEDA have been asked to re-visit the principles of sustainable development. SA/SEA and undertake an Appropriate Assessment. No change agreed. States that Planning Policy Statement 1 (PPS1) makes it clear that the core principle underpinning 2/ It is agreed that environmental objectives should be listed on page planning is sustainable development and that 10 and amendments made to reflect the Appropriate Assessment. Change agreed. sustainable development should be pursued in an integrated manner, with environmental, economic 3/ Reference to the SPA should also be addressed on page 11. and social objectives achieved together over time. Change agreed.
1/ Notes that the Masterplan includes a number of 4/ SEEDA have been asked to address these issues via a revised positive statements and principles relating to the SA/SEA. natural environment and the value of the environment to the local economy. However, they 5/ The principal of this green area is considered to be adequately are concerned that as it stands there is not addressed by the Masterplan. Theses detailed points can be addressed at the planning application stage. No change agreed. sufficient detail on how, in practice, the natural environment will be protected and enhanced 6/ Whilst noting the point, when the separate plans are examined it is through development of the Masterplan area, and clear that there is considerable synergy between each. No change there appear to be a number of conflicts between agreed. current aspirations. 7/ It is agreed that this would be a positive amendment to the In addition, there has not been adequate Masterplan. Change agreed. assessment of the implications of the Masterplan on the environment. In particular, no assessment 8/ It is agreed that 'enhancement' is a more appropriate term, SEEDA of the impacts of development on internationally will be asked to consider whether further 'enhancement' notations could be shown on page 62. Change agreed. important wildlife sites has been undertaken, which is required by law. Their detailed comments 9/ SEEDA have been asked to provide comments on this. See also are provided below. Their advice is that the Main Report. Council should not adopt the Masterplan until these issues have been addressed. 10/ See Main Report.
Habitats Regulations Assessment - 11/ These matters will be considered by the Appropriate Assessment.
State that the Masterplan site lies adjacent to two 12/ SEEDA have been asked to respond on this issue. internationally important nature conservation sites, 13/ SEEDA have been asked to re-visit the SA/SEA to address these The Swale Special Protection Area (SPA) and issues. Wetland of International Importance (Ramsar Site) and Medway Estuary and Marshes SPA and Ramsar Site. SPAs are European sites, as defined under the Conservation (Natural Habitats , &c.) Regulations 1994 (the ‘Habitats Regulations’ ). As a matter of Government policy, Ramsar Principles are suited to the level of the Masterplan but details are sites should receive the same protection as best dealt with at the outline planning application stage. No change agreed. designated SPAs. Changes to the Habitats Regulations were brought in by the Conservation (Natural Habitats, &c.) (Amendment) Regulations Agree. This is being dealt with. 2007, which came into force on 21 August 2007. No change agreed. Regulation 85B states:
“Where a land use plan— (a) is likely to have a significant effect on a European site in Great Britain or a European offshore marine site (either alone or in combination with other plans or projects), and (b) is not directly connected with or necessary to the management of the site, the plan-making authority for that plan shall, before the plan is given effect, make an appropriate assessment of the implications for the site in view of that site's conservation objectives.”
State that the Regulations define "land use plan" RefNo Fullname Organisation Comment Response
as including “a local development document as provided for in Part 2 (local development) of the 2004 Planning Act other than a statement of community involvement under section 18 (statement of community involvement) of that Act” . Therefore they believe that the Regulations apply to this Supplementary Planning Document (SPD).
It is their view that the Masterplan is likely to have a significant effect on The Swale SPA and Ramsar Site and Medway Estuary and Marshes SPA and Ramsar Site and, as it is not directly connected with or necessary to the management of these sites, requires an Appropriate Assessment before adoption of the SPD. They note that they advised on the recent planning applications for Neatscourt Phase 1 and Rushenden Relief Road that both required an Appropriate Assessment under the Habitats Regulations. They believe that a number of impacts on the aforementioned designated sites are likely to arise from the proposals outlined in the Masterplan. These include: 0Noise and visual disturbance resulting in a reduction or displacement of birds due to: -construction works increases in recreational activity on the river -increases in access to designated sites or in close proximity to sites -operational activities on site -buildings and other structures in an open landscape -lighting -Behavioural disturbance of Ramsar invertebrates due to lighting -Loss of feeding/roosting habitat used by SPA birds -Damage to habitats and direct species survival, impacts on food availability for birds due to: -Changes to surface water run-off regime and hydrology -Water quality -Air quality -Increases in access to designated sites
State that the assessment also needs to consider in-combination effects and should take into account: ·Approved, but as yet uncompleted, plans or projects; ·Permitted ongoing activities such as discharge consents or abstraction licences, and ·Plans and projects for which an application has been made and which are currently under consideration, but not yet approved, by competent authorities. (In some circumstances, it may be appropriate to also include plans and projects not yet submitted to a competent authority for consideration, but for which sufficient detail exists on which to make judgements on their impact on the European site.) RefNo Fullname Organisation Comment Response
State that these impacts require full assessment by SBC before adoption of the plan. Regulation 85(B) makes it clear that the Council should only give effect to the SPD after having ascertained that it will not adversely affect the integrity of the designated sites, subject to considerations of overriding public interest. The Council is required to consult Natural England for the purposes of the assessment and may consult the public.
Masterplan -
Note that the Masterplan area is surrounded by sites that are internationally designated for their wildlife importance. In addition, the site itself supports areas of biodiversity value. The surroundings are characteristic of the distinctive flat, low-lying landscape of the North Kent Marshes with open estuary to the west. It is their view that opportunities should be sought to enhance the environment of the site and its surroundings and to develop it in accordance with the distinctive local character of the area.
2/ They welcome recognition of the outstanding ecological value of surrounding area and what it can add to local economy in the Introduction (P.7). The Context section of the Masterplan highlights the surrounding assets and the value of existing views. They are therefore disappointed that the aims of the Masterplan under Delivering Planning Policy Objectives (P.10) do not include environmental, as well as social and economic objectives. They are also concerned by the statement on the same page under Compensatory Land acknowledging that the Masterplan will have an environmental impact.
State that the Good Practice Guide accompanying PPS9 makes it clear that planning decisions should take a five-point approach to planning decisions for biodiversity (Paragraph 5.1), avoiding impacts wherever possible, mitigating unavoidable impacts and only resorting to compensation where these are not possible. We understand that the Compensatory Land section on P.7 may be referring to measures already agreed for the Neatscourt Phase 1 development. However, this is not clear and we would expect further development of the site to be designed around existing environmental assets, not look to simply compensate for losses, where these could be avoided.
3/ The Masterplan should recognise the existing value of the site for biodiversity, as well as its surroundings, as evidenced by surveys carried out for the Neatscourt Phase 1 and Rushenden Relief Road Environmental Impact Assessments. We would have expected this to be flagged up on P.11 Sustainability, in the Context section and elsewhere. The surrounding SPA designations should also be highlighted, in addition to the RefNo Fullname Organisation Comment Response
Ramsar Sites and SSSIs, here and elsewhere in the document, given that SPAs are afforded the highest legal protection.
Natural England welcomes the incorporation of sustainability and environment themes as part of the proposals, as outlined in principle on P.43. However, it is unclear how these themes will be taken forward in practice and we have some concerns about the impacts of the Masterplan proposals on surrounding designated wildlife sites. Further detailed comments are provided in the attached annex to this letter.
Sustainability Appraisal -
4/ Natural England welcomes the production of a Sustainability Appraisal for the SPD. However, we have a number of concerns about the methodology employed and it is our view that the likely significant effects of the Masterplan on the natural environment and measures to offset adverse effects have not been sufficiently addressed to meet the requirement of the SEA Directive (European Directive 2991/42/EC). In addition, the Sustainability Appraisal does not consider cumulative and synergistic impacts.
The Sustainability Appraisal does not appear to include comprehensive monitoring proposals as required by the SEA Directive.
The Sustainability Appraisal process should be part of the development of the SPD and used to inform it. Our detailed comments are provided in the attached annex to this letter.
Natural England has been in discussion with the applicant about proposals on this site for a number of years and we remain happy to continue discussions to ensure the most appropriate development of the site.
Annex to Natural England’s letter re. Queenborough and Rushenden Masterplan
Detailed comments on Masterplan -
5/ They welcome proposals to enhance the tidal pool, green space by Queenborough creek and wetlands on the site set out on P.45, as well as the recognition of opportunities to encourage biodiversity within the Masterplan area (P.63), but it is difficult to judge their appropriateness or likely efficacy given that no detail is provided. For example, enhancement of the tidal pool and wetlands will need to take into account the saline lagoon present in this area. They are also concerned that these principles in some cases conflict with other aspirations and it is unclear how these conflicts have been (or will be) addressed. They would expect this to be a key issue for the Masterplan to resolve. RefNo Fullname Organisation Comment Response
6/ They are pleased that the Public Open Space Strategy (P.55) is a key element of the Masterplan and that the plans will result in better access to existing open spaces, but we would expect to see more emphasis on the multi-functional benefits of green space. As well as providing a multitude of benefits to the local community, including recreation space, walking and cycling ways, drainage and local climate control, green space can provide excellent opportunities for biodiversity, if appropriately designed. Given the existing biodiversity assets on and surrounding the site, we would expect to see targets for the provision of accessible natural green space. Consideration should also be given to an overall green space strategy rather than separate Public Open Space and Green space and Landscape strategies (P.95) as currently proposed. This would allow the multifunctional benefits of green space to be delivered more effectively.
7/ In relation to the Green space and Landscape Strategy (P.95), they recommend the use of native species throughout the site, rather than a distinction between formal and informal spaces as currently proposed. (Use of native species is one of the principles of the Green Charter in relation to biodiversity (P.15).) Consideration should also be given to the water needs of planting.
8/ They would like to see the ‘areas of biodiversity intensification’ identified in the Sustainability Masterplan on P.62 extended throughout the development, though would question the use of the word ‘intensification’ in relation to biodiversity enhancement. It should be noted that most of these areas are of existing biodiversity value and include the designated sites outside the Masterplan area. Consideration should also be given to creation of new biodiversity assets on site.
9/ Targets for green space should encompass more than just outdoor play space (the National Playing Fields Association standards). Suggestions include obtaining Green Flag status and Natural England’s Accessible Natural Green space standards. The Green Flag award recognises good quality, well-managed parks and green space, whilst Natural England’s green space standards provide a set of benchmarks for access to places of wildlife interest. Currently the open space proposals rely heavily on Rushenden Hill and existing assets and will result in a reduction in the open space available per resident from the existing situation, which is disappointing.
10/ Green space should be integrated with development and we would like to see more new green space proposed in development areas, rather than in separate areas surrounding the site. Green corridor links associated with the pedestrian and cycle access proposals (P.59) RefNo Fullname Organisation Comment Response
should also be considered.
11/ Design of green space also needs to take into account the sensitivity of surrounding areas. They are concerned about the potential impacts of the linear park in the west of the site on the adjacent intertidal areas, which are part of Medway Estuary and Marshes SPA, Ramsar Site and SSSI. The design for the linear park needs to recognise the sensitivity of these areas. The birds that are part of the interest features of these sites are very sensitive to human disturbance. They are pleased to see recognition of the sensitivity of Marshside areas on P.120, but this appears to conflict with the plan on P.113, where enhancement proposals include ‘increase access to marshland’. In addition bridge connections across Queenborough Creek could have significant implications for the environment, if they are not designed in an appropriate manner.
They are also concerned about the impacts on designated sites resulting from provision of a marina, as well as other proposals, such as an all- tide landing and flushing of Queenborough Creek. They welcome recognition of the conflict between boating and wildlife (P.105). However, no details of measures to manage this conflict are put forward and the statements here do not recognise the international importance of the wildlife affected.
T12/ hey welcome targets for water consumption, waste production, use of renewable energy and resources (P.11 and The Green Charter) and recommend that the Council seeks the advice of the Environment Agency and others in relation to the appropriateness of these targets. They would like to see appropriate targets set for biodiversity on site, relating to Kent Biodiversity Action Plan. At present, the target is to ‘deliver a gain for biodiversity’, but no detail on what this gain will be is provided.
They are pleased that the importance of good design is recognised (P.73) and that proposals will improve pedestrian and cycle access (P.59 and 75). It is important that the points raised above are incorporated into design.
Detailed comments on the Sustainability Appraisal -
13/ They are surprised that the Sustainability Framework developed for the Swale Local Plan Sustainability Appraisal (SA) has been used for this appraisal. Whilst they would expect a Sustainability Framework to be based on that developed for the Local Plan SA, given the scale of the Masterplan proposals, their view is that a more locally specific framework should have been developed. They are disappointed that they were not consulted on a Scoping Report for the appraisal, so were unable to raise concerns about RefNo Fullname Organisation Comment Response
the appraisal methodology at this stage. They understand that there is a legal requirement under the SEA Directive to consult the consultation bodies at the scoping stage.
As far as they are aware, the statements about replacement habitat in Table 2.1 are incorrect. Also, it should be pointed out that the replacement habitat is to mitigate impacts and is not enhancement of the biodiversity value of the site. The issues identified in this table appear to relate to the Neatscourt Phase 1 development, not to the entire Masterplan area. The Sustainability Appraisal should be used to inform the SPD, rather than incorporated into the future regeneration of Queenborough and Rushenden as part of the Green Charter as suggested in Paragraph 4.3.2.
Baseline information: 5.14 – there is no reference to coastal processes at the site. These are important in relation to the impacts of proposals including the marina and flushing the creek. 5.15 – there could be an assessment of likely impacts on the site resulting from climate change, one source of information being the Shoreline Management Plan. 5.17 – Biodiversity – we are pleased to see use of survey data already collected here. 5.19 – Landscape – we welcome consideration of local issues and reference to The Swale Landscape Character Study. They are concerned that there is no consideration of a ‘no development’ alternative or alternative sites in 6.1. This section explains how the options were considered, but does not undertake an appraisal of these options, which we would expect to see. This is also a concern under 6.3 in relation to Marina options, where there is no consideration of the ‘no marina’ option. Given the likely environmental impacts of the marina, an assessment of its sustainability and the sustainability of different options would have been useful. Explanation of the impact and appraisal: 7.2.21 – It is unclear how the conclusion has been reached that the marina will not affect coastal processes and whether this is based on satisfactory evidence. 7.2.23-7.2.29 – This section appears to focus on the loss of habitat resulting from the Neatscourt Phase 1 development. Other areas of the site have biodiversity value and we would expect the impacts of development on these to also be assessed. As highlighted above, the principle should be to avoid impacts wherever possible, mitigate only where impacts are unavoidable and compensate only where mitigation is not sufficient to avoid impacts. It is unclear how this principle is adopted in relation to the Masterplan. 7.2.31 – As highlighted above, impacts on the SPA and Ramsar Sites should be considered now, RefNo Fullname Organisation Comment Response
not at a later stage in the development of proposals. 7.2.33 – mitigation for bird disturbance from marina is not mentioned in the Masterplan and there is no commitment to providing such measures. This is a significant concern, given the potential for impacts on the SPA and Ramsar Site. There is no assessment of the impacts of increased access to the foreshore and marshes, which is highlighted as a positive effect in 7.2.34. The surrounding sites are sensitive to human disturbance and any access needs to be appropriately managed to ensure the sites are not adversely affected. Table 7.1 – 13.2 – what are the improvements to bird habitat proposed? Conclusions of appraisal: Table 8.1 – it is unclear how impacts can be ‘Positive/negative’. It should be noted that impacts to consider under Objective 15 do not just relate to direct habitat loss, also indirect impacts as a result of the proposals. There has been no consideration of the cumulative and in-combination impacts of the Masterplan. Annex I of the SEA Directive requires that the assessment of effects include secondary, cumulative and synergistic effects. RefNo Fullname Organisation Comment Response
QR045 Mr J Feetam Sport England Sport England believe that the planning system SEEDA has been asked to provide further information on this issue. has a vital role to play in helping to meet the See also Main Report. Governments’ target of increasing participation in sport and active recreation. This role is of particular importance within Swale given the low participation levels recorded for the area by our Active People Survey. They provide website links to view their Active People profile for Swale and to find out more about the survey. As well as providing fun, exercise and a sense of achievement for all, participation in sport and active recreation underpins people’s quality of life and is fundamental to the delivery of broader Government objectives, including the creation of sustainable communities, health and well being, social inclusion and educational attainment. The importance of this agenda has been embraced by the emerging South East Plan in Policies S3 ‘ Supporting Healthy Communities’ and S7 ‘Cultural and Sporting Activity’ which have been endorsed by the resulting Inspectors Report and also increasingly recognised within the development of LDF's.
Sport England is pleased to see the inclusion of a variety of sport related provision within the Masterplan including open space, playing fields and a proposed multi-purpose sports centre. However, they would welcome additional information on the rationale behind the inclusion of these facilities and the levels proposed (e.g. of playing field provision) and how they fit in with the wider requirements for sporting provision identified by the Borough Council. This information is required in order to assess if the Masterplan will be providing an adequate range and level of provision to provide for the demands of the new residents, along with facilitating an increase in participation. On this point it would be worth noting what the population of the development would generate for sports hall and swimming pool provision according to our Sports Facility Calculator. As an indication the calculator, taking the 2,000 residential units and the average household size for Swale of 2.44 taken from the Census, suggests demand for 1.38 sports hall courts at a cost of £1,037,512 and 50.15sqm of swimming pool space at a cost of £553,417.
Linked to this indication of provision and costs Sport England would welcome further information on the allocated £1.4m for the proposed sports facilities (sports hall and synthetic turf pitch) presented in Table 1 of Appendix 3 to the Project Delivery Volume 2 document. Sport England has an updated lists of costing for major sports facilities available to view on our website which it can be seen would require in excess of this level of funding for such facilities.
Additionally, they would like to draw our attention to Sport England’s recently published guidance “ Active Design” which seeks to ensure that the RefNo Fullname Organisation Comment Response
design and layout of new developments enables communities to lead a more active life. The master planning of major new housing and mixed use development schemes has a vital role in providing easy access to a choice of opportunities for sport and active recreation, making new communities more active and healthy. They attach PDF documents of these documents.
Sport England hope that given the above participation agenda and our Active Design guidance with its principles and checklist the guidance can be added as a key tool to be promoted by the Masterplan and used to aid and evaluate the development of the site and future planning applications. RefNo Fullname Organisation Comment Response
QR046 Mr J Clarke Queenborough Town Council 1/ Integration of Existing Population: They are 1/ This has been a major consideration for both SEEDA and SBC concerned about the effect of this major throughout the process and the provision of the Gateway community redevelopment on the existing population. There centre was for this very purpose. Work with the local housing is felt to be a need for a formal study into the association is taking place to implement environmental needs of existing residents, who will have to improvements to Rushenden to help integrate it into the regeneration. absorb major changes to their local environment. It is understood that some work may have been 2/ See Main Report. done on this by Swale Forward and the Town 3/ This would be looked into by the Environment Agency at the Council would be interested to learn of their planning application stage. findings. No change agreed.
2/ Building Density: They have commented, on 4/ This is too detailed a point for the Masterplan and has already previous occasions, about the increases in the been agreed at the planning application stage for Neatscourt. number of dwellings to be provided (750 then No changed agreed. 1200 and now 2000 plus). There is concern that, despite modern practice in layout and design, the 5/ This is not relevant to the Masterplan and consultation will take place at the planning application stage. resulting density of housing could be detrimental No change agreed. to the overall concept and, in years to come, could lead to slum conditions developing. 6/ This would have been undertaken as part of the Masterplan process. 3/ Sea Defences: Obviously, the maintenance of No change agreed. adequate sea defences will be vital to the project. In this respect, it is noted that the proposed boat 7/ This would be up to the PCT and is not an issue for the Masterplan. moorings, along the existing foreshore could No change agreed. present a weak link in the chain. 8/ This would be determined the planning application stage and the provision of specific shops and services is controlled by market 4/ Neatscourt: The proposed developments at forces and not planning. Neatscourt (Aldi etc,) will be among the first No change agreed. structures seen by travellers to the Island when negotiating the Sheppey Crossing and will be 9/ This is a detailed planning application point. important factors in determining their impression No change agreed. of Queenborough and, indeed, the Island as a whole. With this in mind it is vital that the designs 10/ This will be considered as part of the ongoing discussions selected are of a suitable standard to set the right between SEEDA and the local Housing Association. image. No change agreed. 11/ The Masterplan does cover public transport with proposals to 5/ Emergency Services: Steps will need to be revamp Queenborough station and to improve access to it. The new taken to instigate high level consultations with all link road will improve linkages between Queenborough and the emergency services to ensure that appropriate Rushenden and will provide the opportunity for a circular bus route, cover is available to serve the increased linking to Neatscourt. population and the inevitable changes to the levels No change agreed. of risk created by the new builds. 12/ Parking has been fully investigated and proposals follow current 6/ Review of All Public Utilities: A comprehensive guidelines. The Masterplan proposes a mixture of parking solutions for both residential and visitor parking. Exact parking spaces will be review of all utilities should be undertaken to determined at the planning application stage. safeguard the future of these services. In No change agreed. particular, the adequacy of the domestic water and sewerage supply should be given careful 13/ Noted. It will be up to the Police to enforce this. consideration. No change agreed.
7/ Medical Facilities: It is noted that a new 14/ Contamination will be looked at at the planning application stage. healthcare facility is planned, incorporating GP The riverside park will contribute to the enhancement of the area, Surgeries, pharmacy, nurse facilities and space however, the beach area is outside of the Masterplan area. for support staff. This is a vital component of the No change agreed. overall development, since the existing provision 15/ If the proposed footbridge is abandoned then pedestrian access will be inadequate to cater for the increase in in this area will need to be re-looked at. population. However, it is felt that the opportunity No change agreed. should be taken to incorporate the full range of medical and welfare services, including dentistry. 16/ This is already being investigated by both SBC and SEEDA and construction training courses are already underway at the Gateway 8/ Local Amenities: While the introduction of community centre. café/restaurant facilities is to be welcomed the No change agreed. main emphasis should be on the provision of the RefNo Fullname Organisation Comment Response
day to day needs of residents. This should include a suitable range of shops including a small general type store. The existing post office is currently under threat, due to government policy and every effort should be made to retain the facility. Banking facilities should be made available and consideration given to a launderette, which could prove useful to visiting yachts people as well as the residents.
9/ Public Toilets: Public toilets will need to be provided, especially in the Marina area, where shower facilities should be incorporated for the use of visiting yachts people.
10/ Sheltered Accommodation: The recent closure of Rushenden Court has left the town with very little accommodation specifically allocated to the elderly. During the recent Master Plan presentation to Town Councillors by Rummey/SEEDA, this fact was mentioned and the response indicated that this aspect would be looked at. They feel quite strongly that proper provision should be made for elderly residents, many of whom will have lived in the town all their lives.
11/ Public Transport: Present day thinking on transport is, quite rightly, putting greater emphasis on the use of public means rather than the private car. In order to encourage people out of their motor cars, there will need to be a reliable, safe and efficient system offering links to all parts of the Island and to the main transport arteries on the mainland. Bus services, in particular, will need to improve to meet these criteria.
12/ Parking Facilities: It is a fact that many households, these days, own two or more vehicles. There is some concern over the statement that …'residential parking will generally be on-street….'. It had been hoped that the planners would take the opportunity to incorporate parking facilities more fully into the design of the residential properties eg., the semi-basement car parks described in the Plan. In addition, the parking needs of the many visitors expected to be attracted to the services and leisure facilities proposed will need to be adequately provided for.
13/ Traffic Calming: It is noted that the proposed 20 m.p.h. speed limit will be extended to cover existing roads. This is to be welcomed, but will need to be rigorously enforced to be effective.
14/ Beach: The regeneration project provides an opportunity for the imaginative development of the natural foreshore as an attractive leisure facility to enhance the amenities to be made available to both residents and visitors. However, this possibility does not appear to have been given any prominence in the Master Plan document. It must be said that, prior to any development taking RefNo Fullname Organisation Comment Response
place, it would be necessary to identify and remove any harmful industrial waste that may be present as a result of the area's industrial past.
15/ Tidal Pond: It is understood that the 'tidal pond' may be designated as an SSSI and that, for this reason, the proposed footbridge over has been abandoned. The removal of this facility will increase the walking distance for Rushenden children attending the existing school quite significantly.
16/ Apprenticeship Schemes: The increase in employment, to be offered with the new commercial developments, is to be welcomed and it is suggested that some form of apprenticeship scheme (2/3% of the total workforce) should be negotiated to provide meaningful training opportunities for the young. RefNo Fullname Organisation Comment Response
QR047 Mr R Eatwell Queenborough Society They support the Masterplan but have a few 1/ The Masterplan proposes restoring the Old School and library but comments - more could be said of protecting and enhancing the High Street. Change agreed. 1/ The High Street should be protected at all costs and where possible, be enhanced. 2/ This is dealt with in the Masterplan on page 65 which proposes opening up access to the creek and linking it to the proposed marina. 2/ The Town Creek should be protected and No change agreed. where possible, be enhanced. 3/ Noted. The road will be progressed before the any other building work commences. 3/ Rushenden Relief Road should be progressed No change agreed. as quickly as possible. 4/ Redirecting water would need to be agreed by the Environment 4/ Land water from the marshes to the north of the Agency and could affect the water table and flooding. Therefore, this town should be directed into the Town Creek to is not appropriate here. maintain a constant flow of water in both directions. No change agreed. 5/ This is not a Masterplan issue but should be discussed with 5/ The marina should be developed together with SEEDA by the respondent alongside the Masterplan process. improved funding for an improved All Tide landing No change agreed. and additional step ashore pontoon moorings. The whole visitor yachting system should be made 6/ This is not a Masterplan issue but could be considered at the more user friendly. planning application stage. No change agreed. 6/ Consideration should be given to the self build housing concept, together with training and 7/ Pedestrian and cycle links are integral to the Masterplan and professional guidance for builders. It would transport around the area and the Island as a whole is also dealt with. enhance the spirit of the community and mitigate No change agreed. against an 'us and them' mentality. 8/ Community facilities are a key aspect of the Masterplan and all locations are currently being considered by SEEDA. The Gateway 7/ Concerned about the provision of infrastructure Centre will continue until a replacement is found. and facilities. Highlights the importance of No change agreed. pedestrian and cycle links across the Town Creek and transport into, out of and within the town. 9/ This is not a Masterplan issue but the examples will be passed to SEEDA. 8/ Given the increase in population priority must No change agreed. be given to developing the Queenborough Community Centre.
9/ They would like the naming of the development to reflect people and businesses who have influenced Queenborough and Rushenden. A list of examples is given. RefNo Fullname Organisation Comment Response
QR048 Mr R Thornby Medway Ports Whilst supporting the Masterplan in principle they We note your concerns but the location of the school is indicative would, on behalf of Medway Ports, wish to make and as part of the Masterplan SEEDA will need to ensure that the the following comments: school is delivered. It will be a matter for them to deal with the process of aquiring the land. They note that Medway Ports currently occupies approximately 35 acres of land fronting Cullet No change agreed. Drive which is used for the storage and distribution of vehicles imported through the Port of Sheerness. They say that agreement has been reached with SEEDA and the KCC for the sale of some of that land, required for the Rushenden Relief Road, and the Port has willingly entered into these negotiations to ensure that the road scheme proceeds even though it will mean the loss of valuable land required for its continued business at Cullet Drive.
They state that the Masterplan does however indicate that the development of Rushenden and Queenborough would include the provision of a Primary School to be situated on the northern part of the Port's land at Park West in Cullet Drive. They argue that the loss of further land at Cullet Drive at this time would be detrimental to contract negotiations currently being undertaken with potential customers of the Port and tenants of the land at Cullet Drive. The Port is striving to increase its share of the import car market and is finding great difficulty in satisfying the requirements of potential customers for storage land. The Port believes this will benefit the local economy not least through the creation of new employment opportunities. They feel the loss of further land would be unacceptable unless suitable replacement land was made available which was contiguous with the existing car compounds.
They understood that the proposal for a school is at this stage only a safe guarding exercise and the Port would wish to make it clear at this time that it will object to such a scheme if it is sought to implement such a proposal. RefNo Fullname Organisation Comment Response
QR049 Alison Giacomelli RSPB The RSPB supports the comments made by 1/ SEEAD are re-visiting the SA/SEA and are undertaking an Natural England, the Environment Agency and Appropriate Assessment and the Masterplan will not be adopted until Kent Wildlife Trust. SBC are content with the findings.
Whilst the RSPB strongly supports the 2/ It is agreed that environmental designations should be mentioned sustainability principles within the Masterplan, it on page 7 and that the biodiversity value of the grazing marshes has concerns about the treatment of ecological should be mentioned in the Masterplan.Change agreed. areas. 3/ SEEDA are working on this at the moment and are well aware of the need for suitable compensatory habitat and will make developers Assessment under the Conservation (Natural aware of this too. Habitats &c) Regulations 1994 (as amended) (The No change agreed. Habitats Regulations) - 4+5/ Theses issues will be addressed through the Appropriate 1/ As the Masterplan is to be adopted as a Assessment (AA) and these comments will be passed to SEEDA to Supplementary Planning Document, an ensure that they are incorporated into the AA. Appropriate Assessment is needed of the impacts No change agreed. of the Masterplan on the Medway Estuary and 6/ A full technical survey of the marina has been undertaken and it's Marshes Special Protection Area (SPA) and impacts will also be assessed in the Appropriate Assessment. Ramsar site and the Swale SPA/Ramsar. They No change agreed. state that if it cannot be found that the Masterplan will not adversely impact the integrity of the SPAs, 7/ These objectives will be amended to refer to environmental then it cannot be adopted, subject to further tests objectives. Change agreed. regarding alternatives, overriding public interest and compensatory habitat. The RSPB has 8/ Theses are matters for the detailed planning application stage. produced guidance on the Appropriate Assessment of spatial plans, which was attached 9/ Agree with the respondent and the Masterplan will be changed to reflect these points. Change agreed. to the letter. They are concerned about impacts on the SPA/Ramsar sites from disturbance to birds 10/ SEEDA have been asked to examine this point. (from construction, land- and water-based recreation, operation of the development and lighting); loss of habitat (associated with the proposed marina and built development on grazing marsh); and impacts on water quality and hydrological regimes.
Biodiversity -
2/ They state that the Masterplan should make it clearer that the area surrounding the development area has the highest environmental designations (the SPA is not mentioned alongside the other designations in some places, e.g. p.7) and that it should also be clear about the biodiversity value of the grazing marsh habitat that will be lost to the development.
Compensatory Habitat -
3/ They comment on page 10 of the Masterplan where it mentions the need to mitigate the environmental impact of the proposals by provision of compensation land. They believe this section needs to be clearer about what the compensatory habitat is needed for, what are the legal/policy drivers, how much habitat is needed, and when it must be provided. Developers need to be absolutely clear that where replacement habitat is needed for losses to habitat functionally linked to the SPA, and hence used by birds for which the SPA is designated, this habitat must be found before the development can be built (as has been the case for the Neatscourt Phase 1 development). They state that the time and RefNo Fullname Organisation Comment Response
resources needed for the provision of replacement habitat should not be underestimated.
Public Open Space -
They support the principle of providing high quality open space within developments to benefit both wildlife and people and say that developments should first avoid detrimental impacts on existing habitats, and then seek to provide additional habitat within the development area.
4/ Page 55 of the Masterplan sets out proposals for a ‘Swale Park’ and ‘Creek Park’. Swale Park is adjacent to the Medway Estuary and Marshes SPA and the RSPB is concerned that there is potential for adverse impacts on the SPA through disturbance to birds. They state that the risk of adverse impact should be assessed through an Appropriate Assessment and should be informed by low- and high-tide bird counts. If it is determined that an adverse effect is likely, mitigation should be put in place to minimise disturbance. Consideration should be given to setting back flood defences, thereby creating new intertidal habitat and providing more of a buffer between birds and people. Other mitigation measures might include routing paths away from the intertidal area or screening to remove the visual intrusion of people.
5/ Creek Park is not directly adjacent to the Medway Estuary and Marshes SPA, but birds using the SPA are likely to also be found in the Creek. Therefore, the impact of the creation of the Creek Park should also be assessed under the Habitats Regulations. Consideration should be given to creating intertidal habitat as part of the park.
Marina development -
6/ The RSPB is concerned about the impacts of a marina on the Medway Estuary and Marshes SPA. Principally, this centres of the loss of intertidal habitat due to dredging to create an approach to the marina, and disturbance to birds from recreational users. They believe there is potential for both wintering waterbirds feeding on the adjacent mudflat, and seabirds breeding on islands in the Medway, to be affected.
Sustainability -
7/ The RSPB strongly supports the principles set out in the Masterplan for the development to minimise water and energy use and waste production, therefore it is disappointing that the planning policy objectives (p.10) do not mention either sustainable development or greenspace.
8/ They welcome the commitment to use of Sustainable Urban Drainage Systems (SUDS), RefNo Fullname Organisation Comment Response
though urges caution regarding the risk of pollution events to adjacent designated nature conservation sites. They argue that it should also be made clear in the Masterplan which organisation will be responsible for the management and maintenance of SUDS.
Volume 2 – Project Delivery
9/ Paragraph 4.10 mentions the need for onsite ecological features and landscaping. However, this section should also be clear, open and up- front about the need for off-site replacement habitat and habitat enhancements.
They believe that paragraph 4.19 should recognise the potential environmental impacts of a marina development, and the need to assess the proposal under the Habitats Regulations.
Green Charter -
10/ They support the general principles set out in the Green Charter, subject to the comments above. They comment that on page 28 the table states that there are no compulsory policies for ecology in Swale. However, the Swale Local Plan contains ecological policies, as does the Kent and Medway Structure Plan, each reflecting the requirements of PPS9 . The RSPB suggests a target to conserve and enhance SSSIs, SPAs and Ramsar sites in the area. RefNo Fullname Organisation Comment Response
QR050 Sheppy Ltd They refer to their letter to Mr B Lloyd on 22nd 1/ The Council does not see an inconsistency. Page 67 does refer to March 2007 which sets out many points they wish demand bringing these sites forward quicker. However the phasing the Borough Council to consider as relevant points reflects, in part, the time taken in bringing the site forward having in the Master Plan and Project Delivery regard to constraints, etc. No Change Agreed. Documents. 2/ SEEDA to review the two plans to ensure consistency. Phasing 3/ See Main Report.
1/ They think the phasing section of the Master 4/ This initiative is being explored outside of the Masterplan process. Plan is not consistent with the Project Delivery However, it is agreed that a general reference could be made to Document. The Klondyke area is illustrated on displaced businesses. Change agreed. page 67 as phase 2 Medium (5-10years) yet page 36 of the Project Delivery Documents has the 5/ Disagree. Addressing contamination is a cost to development and phasing as C1 where residential development “will not a matter for the contributions strategy. Likely contamination costs be for the housing market to determine the rate of should be reflected in the land value a developer would expect to supply on any one site.” pay. No change agreed. 6/ The point is noted and been the subject of considerable 2/ The respondent states that the Master Plan discussion. Whilst demand for services as a result of employment acknowledges that the Project Delivery Document development no doubt occur, they are more difficult to quantify and sets out in detail the approach to delivery phasing establish a clear link with the development. Employment sites are and management. However, they feel it would expected to contribute towards certain provision, however a balance therefore be appropriate that the plan is consistent needs to be struck with the need to encourage investors - especially to both the Master Plan and Project Delivery. in current economic circumstances. No change agreed. They request that SBC remove current Indicative Phasing Plan 3.12 in the Master Plan and replace 7/ All proposals of this type have been applied consistently as 'on- with Plan 5.1 page 32 of the Delivery Documents site' provision. It would seem a reasonable approach to a relatively modest requirement. and delete indicative phases on page 67. Confirm Zone C1 as short/medium phasing subject to 8/ See Main Report. market forces. 9/ This is a detailed point to be considered at planning application New Employment Development stage.
3/ They state that in the Inspectors Report on the 10/ See Main Report. SBC Local Plan he suggests that FPC66 be incorporated into paragraph 5.6.8 of the Plan such 11/ The Green Charter should be factually updated. The CHP issue is being progressed by SEEDA outside of the Masterplan process, that financial contributions towards learning, but they have been asked to provide comments on these points. See training and skills are funded. They object that this Main Report. obligation appears to be solely the responsibility of the new housing development. This is clearly unreasonable given the 180 000 sq m of employment planned at Neatscourt where currently no contributions for these facilities are required. They request that at least a 20% contribution is made by new employment to these facilities.
Provision for Existing Displaced Businesses
4/ State that the Inspectors Report says that IC27 be incorporated into the Plan, such that the second criteria of Policy APP6 is amended to read:
‘new employment development (including for existing businesses that are displaced) be provided.’ Believe the Master Plan currently makes no provision and does not identify sufficient land or property to deliver this obligation. They want the Master Plan to ensure that displaced businesses are able to access accommodation on similar low and flexible rental terms as currently available to existing businesses in AAP6.
Site Specific Contributions and Requirements RefNo Fullname Organisation Comment Response
5/ States that although the Master Plan acknowledges that the Project Delivery Strategy cannot identify every site specific matter that may need to be addressed, it refers to items that are likely to be required on most development sites and identifies Remediation of Contaminated Land as a cost associated with the development of that land, separate from any contribution required under this strategy. However, levels of contamination and remediation will vary significantly across AAP6. Klondyke is heavily contaminated, Neatscourt is not. As the Inspector has recommended IC31 be incorporated in paragraph 5.6.14 which states that consideration of ground contamination may have a bearing on uses that can come forward on the site and will need to be further investigated as part of the Master Plan. They believe it is therefore inappropriate not to identify the impact of contamination and remediation as factors affecting the pooled contribution strategy.
Neatscourt and new employment.
6/ States that the Master Plan refers to the estimated quantum of development of £9 per sq m. However at the very heart of AAP6 is an integrated live/work strategy. It is therefore appropriate that new employment contributes fairly towards other social infrastructure such as public open space, libraries, healthcare, education and public art proportionate to the attractiveness of the area and the benefit derived to employees and employers alike. Neatscourt represents around 50% of the land area in AAP6 and a significant enhancement of its original agricultural value.
Klondyke Bridge Links
7/ Believes the Bridge links within the Klondyke site provide a wider community benefit with public access and usage and should therefore be included in the “Pooled Contribution Strategy” or alternatively be provided as a direct provision in lieu of contribution.
Marina
8/ State that they have continually expressed concern over the viability and deliverability of the marina. There is no evidence to suggest that this is viable and SEEDA continue to express uncertainty regarding its delivery as stated in paragraph 4.19 of the Master Plan. As such the Master Plan should suggest an alternative strategy for establishing an important feature within the overall development in the event that the marina cannot be delivered within a reasonable period of the AAP6. My client has suggested an eco-water/ marsh habitat destination centre or a system of canals. RefNo Fullname Organisation Comment Response
Access to Housing Zone C1
9/ State that the Master Plan should acknowledge that access to the Klondyke already exists and has done historically for many years establishing existing unrestricted access rights to this site. They object to the access shown in the Master Plan if this required the closure of the existing access without a legal obligation to ensure that unrestricted access would be available to the Klondyke site across third party land and assurances that the grant of any planning permission for the development of the Klondyke site would entitle any party to deliver the necessary access across third party land without payment, ransom, restriction or delay.
Affordable Housing
10/ Argue that although the Local Plan and Master Plan refers to a 30% affordable housing provision we would wish to ensure that this requirement is directly linked to a Housing Needs Survey carried out on the Isle of Sheppey so that the required affordable housing meets the needs of the community and not used to meet the needs of the Borough as a whole contrary to the overall ethos of the Master Plan.
Sustainable Construction /Green Charter
11/ Believe that the Queenborough and Rushenden CO2 emissions target to 2011 on the Klondyke site should, due to its contamination costs, be CSH level 3 as CSH level 4 would/could prove unviable. They also believe the CHP plant would use gas, the biomass description is misleading and arguably less sustainable than other renewable sources e.g. wind turbine. They have further reservations on CHP plant as there is no in depth study as to how and when the CHP plant would /could be converted to biomass and whether the biomass material would come from a sustainable source. They think that for units not connected to a CHP plant a 10% renewable energy should be on or off site. The “additional requirements” in the Green Charter table for units not connected to the biomass CHP system Code Level 4 should be dated as after 2011 in line with Government targets. RefNo Fullname Organisation Comment Response
QR051 Mr G Mason 1/ Building Heights – Queenborough Creek 1/ Design and exact locations of buildings is too detailed a point for the Masterplan, this is for the planning application stage. In relation States that plan 4.3 shows a small area of 4-5 to building heights see main Report. storey buildings on the South bank of Queenborough Creek and apart from the artist's 2/ The proposals have been subject to both a Strategic Flood Risk impressions on pages 114-115, there is no real Assessment and a site FRA in association with the Environment indication of what these buildings would be like, or Agency. No change agreed. how far they are set back from the existing bank of 3/ See Main Report. the creek. States that this it is a critical issue as the ground at this point has been built up above 4/ Noted. the level of the existing back gardens on the North side. Starting from this level, any new 4-5 storey 5/ More significant dredging would be likely to raise issues of buildings will be even more out of scale with the proximity to the SPA. No change agreed. modest 2-storey houses on the "old" side. 6+7/ Improvements to the all-tide landing need to be undertaken by Believes that the creek is narrower and deeper the current owners, Queenborough Yacht Club, and are not an issue for the Masterplan. than some of the sketches might suggest so high No change agreed. new buildings close on the South side could make it into a deep and dingy ditch which hardly ever 8/ Noted. sees the sun. If the new buildings "face" the creek then they will overlook the existing houses and 9/ See Main Report. gardens. If they face away from the creek the existing residents will be presented with a 10/ The number of dwellings was agreed through the Local Plan depressing wall of utilities which largely blocks out process. See Main Report for 'open space' considerations. the sun.
"In terms of the height of buildings, any development should respect existing heights" – Design Concepts and Principles" – Masterplan Page 73. States that in this particular place, the plan is unacceptable and does not comply with its own guidelines. Building heights must be reduced, or graded so that the closest buildings are lower and the higher ones are further away in the centre of the "Klondyke" section of the development.
2/ Sewage Works
States that the section on flooding (page 37) casts an unacceptable doubt about flood risk to the Sewage Treatment Works just South of Rushenden.
3/ Industrial Railway
Can see no reference in the Masterplan document to the future of the private industrial railway which branches off the Sittingbourne to Sheerness line just South of Queenborough and runs to the "Coal Washer" Wharf. It is shown in an unidentified diagram of existing transport routes on page 28, but not mentioned in the text.
The subsequent diagrams of the proposed development do not show this railway very clearly but the layout of the buildings suggests that it will continue to exist.
Feels it is rather strange to have a ramshackle industrial railway bisecting a high profile new residential development. While it is not always heavily used, there are spates of activity when it RefNo Fullname Organisation Comment Response
can be very noisy (even audible from the "old town") while carrying steel between the Coalwasher and the ISTIL works. Due to the unpredictable wax and wane of industrial activity, and the steady rise in people's environmental expectations, this could suddenly become a significant environmental and safety issue at any time in the future. States that if the railway becomes disused, then the plan shows no satisfactory road access to the Coal Washer, there being only a Tertiary road access along First Avenue shown in Plan 4.3. Spates of intensive trafficking to the wharf by heavy road vehicles in previous years have caused considerable annoyance to the residents and these have led to heavy lobbying of Swale Council to address the problem. They believe that this issue represents a significant risk which needs to be addressed. Continued usage might cause significant environmental nuisance. The Wharf itself will be cut off from the main industrial areas by the new residential development. This might ultimately lead to its demise.
4/ Marina and other Marine Facilities
Welcomes the construction of new leisure boating facilities at Queenborough as it will bring a powerful new focus to the town. It will bring prosperity by attracting more wealthy people and supporting many ancillary businesses. States that in terms of pure geography, Queenborough is the ideal place to build a marina.
However, they believe the following points are essential to ensuring success:
5/ All-Tide Facilities
Unless the entrance channel and lock are dredged out much deeper than currently proposed, access time will be limited to an hour or two each side of high water. Many visiting yachts currently make short overnight stops. Delays associated with entering and leaving the marina will be unwelcome.
States that many existing mooring holders (especially fishermen) who have had the benefit of 24hr access might not use the Marina at all. In order to capture this section of the market, alternative all-tide facilities will be required. At the moment, these demands are partially satisfied by the deep water moorings and all-tide landing. These facilities also need to be expanded and improved, particularly in terms of easier access to the shore. The all-tide facility is not an alternative to the marina. It is a necessary addition rather than a competitor.
6/ Shore Facilities
States that shore-based ancillary facilities RefNo Fullname Organisation Comment Response
(slipways, maintenance, winter storage etc) are very space-hungry and visually not particularly attractive. These facilities are important cash- generators, and most important attractions to the boat owner. It seems unlikely that there will be space to include many of these immediately adjacent to the new marina. Feels more detailed consideration needs to be given to where these facilities will be accommodated, both from the point of view of the space required and their detrimental visual impact if wrongly sited.
7/ Creek Crossings
Notes that the plan shows three new crossings of Queenborough Creek, and quite rightly so to unite a town of physically separate parts. The new crossing shown at the mouth of the creek is particularly important to the marine activity as it enables users of the old landing places to access the shore-side businesses of the new marina. However, this crossing will be the most difficult and costly to construct. States that we must beware that it does not get deleted from the plan on grounds of cost, or just endlessly delayed until the developers have spent all their money and conveniently forgotten about it!
8/ Integrated Plan
States that the proposed marina is of a marginal size and accessibility to be economically viable by itself. In total there is a huge amount of potential trade which could be captured, but this requires an integrated range of facilities. Some of these already exist in part but they will need to be expanded, improved and physically moved to be consistent with the main shore based developments. Believes a separate integrated plan is required to ensure that marine business will be exploited, accommodated and managed in a logical fashion consistent with all of the other Masterplan objectives. The generation of such a plan must involve specialists in the physical, operational and economic aspects of the business.
9/ Too Many Houses in Too Small a Place
Feels that Queenborough seems to be taking more than its fair share of housing. Believe that 2000 houses will increase the population to well over double the existing, using a space which is very much smaller. Relatively little new green space is being provided, most of the obligatory provision being "taken" from our existing.
States that closely packed flats with minimal private ground space leads to serious problems with pets, children's play spaces, storage for bicycles, large toys, DIY activities and hobbies etc. The result may be a lot of untidiness and young people wandering around the public spaces without enough to occupy their minds. RefNo Fullname Organisation Comment Response RefNo Fullname Organisation Comment Response
QR052 Peter Speakman SBC - P Speakman 1/ The respondent is pleased to see that the plan 1/ Noted. provides a connection to, and acknowledgement of Art as a strong focus for the regeneration of 2/ The future of the Arts at the Centre can be addressed outside of Queenborough and Rushenden. They believe the the Masterplan process. introductory items on page 99 provide some useful encouragement to developers that Art will be a 3/ Noted. serious aspect of the developments that take 4/ This would be an inappropriate level of detail. place. 5/ The future of the Arts at the Centre should be addressed outside of 2/ However, they think the Plan should go further the Masterplan process. than it does though given the 3 years of Arts at the Centre and the support that it has generated from local people. The aspirations in the Masterplan are applicable to any large scheme and fail to help create a sense of place that the development will desperately need as it begins to take shape and possibly look and feel much like any other contemporary waterfront mixed development in the Gateway area.
3/ They welcome the commitment in the Masterplan which suggest creative public lighting schemes and planning gains for the provision of public art, whilst suggesting locations where it could be provided.
4/ They state that there is no more detail in the plan and this could prevent the broad ambitions for the Arts described on Page 99 from ever being realised.
5/ They believe it would be very appropriate now to take the experience of Arts at the Centre to the next level and to try to achieve what the project had originally set out to do which was, most importantly, to contribute to the whole Masterplan development. That is, to use the aspects of Arts at the Centre that have worked and to try to sustain and adapt them within the Arts related aspects of the new developments planned.
Arts at the Centre has also led to the establishment of gallery space in the town centre, which has been continuously used for exhibitions of local and regional artists’ work including local interpretations of the developments that could take place in Queenborough and Rushenden and the history of the Town. The Gallery has led to a Queenborough Arts Forum being established by local people, most of whom have specific arts related skills and have ambitions to be at the heart of a growing arts culture and economy in QR. The respondent feels that the Masterplan does nothing to help harness the momentum of this group and the sustainability of the gallery.
They believe there really needs to be ambition to provide creative indoor as well as outdoor space within the development. Provision, for example, of ground-floor Arts studio/gallery space for the Council or Queenborough Arts Forum to manage and help provide further capacity for the arts economy to grow and flourish. This sort of offer RefNo Fullname Organisation Comment Response
should be in the middle of the commercial area and help to influence the eventual character of the area.
They want opportunities for artists to work with those involved in all the facets of the development, in particular with regard to design of public spaces, buildings and even street furniture. They do not get a strong feeling that this whole approach will be encouraged and realised. They would like the Masterplan re-written to build in these elements, especially the gallery. RefNo Fullname Organisation Comment Response
QR053 Sue Young Kent Wildlife Trust 1/ They object to the Masterplan, for the following 1/ See Main Report. An Appropriate Assessment has been reasons: undertaken. ·No Appropriate Assessment of the plan is No change agreed. supplied ·There is likely to be a significant negative impact on the internationally designated sites 2/ The SA/SEA has been revised. See also Main Report. ·There will be significant loss of priority 3/ Theses are being addressed via the AA/SA/SEA and in other Biodiversity Action Plan habitats amendments agreed in this schedule. No change agreed. ·Insufficient information is supplied on the potential impacts of the delivery of the Masterplan on the 4/ The SUDs system is not advocated as a replacement for lost nature conservation interest of the area habitat. The level of habitat surrounding the ditches is a detailed ·Details are not set out in the Masterplan to show matter that can be addressed at the planning application stage. No how these negative impacts on the environment change agreed. should be avoided 5/ These will be assessed at he planning application stage. No State that the Conservation (Natural Habitats, &c.) change agreed. Regulations (as amended in 2007) require Appropriate Assessment of land use plans, where this is likely to have a significant effect on a European site. The Masterplan area is adjacent to the Medway Estuary & Marshes SEEDA are currently acquiring compensatory land and details will SSSI/SPA/Ramsar site and the Swale Estuary have to be provided to SBC before the Masterplan is adopted. SPA/SSSI/Ramsar site, and therefore the No change agreed. Masterplan should be assessed for its impact on these sites.
State that although the Masterplan lists an Appropriate Assessment as a supporting volume, this is not supplied. Kent Wildlife Trust would be pleased to comment on this document when it is SEEDA are re-doing sections of the SEA/SA to incorporate these available. comments. SBC will not adopt the Masterplan until this is done. No change agreed. They urge the Council to seek the advice of Natural England on the scope of the Appropriate Assessment. However, they recommend that issues to be addressed would include: ·Loss of habitats used by the birds of the SPA ·The impact of noise, visual disturbance and Noted. lighting No change agreed. ·Indirect impacts on habitat used by the birds of the SPA from changes in hydrology, and pollution. Noted. SBC will ask SEEDA to investigate the lack of terrestrial State that the Strategic Environmental habitat surrounding the ditches. Assessment and Sustainability Appraisal identify No change agreed. not only the exceptional ecological value of the adjacent European sites but also the considerable ecological value of parts of the development area.
They are extremely concerned about the direct habitat loss of up to 50 ha of grazing marsh. As SBC to ask SEEDA to investigate this and assure the Council that stated in 7.2.23, we have been involved in they will take into account the existing biodiversity of the areas to be consultation with regard to this, but in our opinion, planted. no satisfactory solution to the loss of this important Change agreed. habitat has been reached. Plans for compensation for habitat loss are so far only dealing with that associated with the relief road and Neatscourt Phase I. The buffer zone mentioned in this paragraph is designed to reduce the impacts of disturbance on the SPA, not to compensate the extensive habitat loss, and indeed may involve additional loss of grazing marsh due to the construction of the bund. RefNo Fullname Organisation Comment Response
Believe that there appears to be an assumption that the impacts on biodiversity will be mainly dealt with through compensation. They believe that the Masterplan should first seek to avoid impacts of biodiversity, by including existing valuable habitat within the design. Although 21 ha of open space are proposed, most will be for recreation and amenity, with only a fraction having potential for biodiversity management. They feel that greater emphasis should be placed on the potential for green space to provide habitat for wildlife.
Paragraph 7.2.24 highlights the need to provide compensation habitat; we believe that this may be difficult to achieve. State that to ensure that the Masterplan is deliverable, this compensation habitat needs to be identified and agreed at the outset, and these details should be provided in support of the Masterplan, before it is adopted. If this information is not provided, the Council cannot demonstrate that the proposals would not have a significant impact on the adjacent European Sites and on the Borough’s biodiversity interests, therefore the SPD would be in conflict with Local Plan policies E11 and E12.
2/ Overall, they believe the SEA is incomplete as it fails to address many of the potential impacts of development and consequently does not set out mitigation that would avoid an overall loss of biodiversity. For example it is not clear that the proposal in Paragraph 7.2.28 for the mitigation of negative impacts on biodiversity by enhancement of existing land will be effective. As identified by the SEA, much of the adjacent land is of very high ecological quality, therefore it seems unlikely that it could be enhanced sufficiently to mitigate for the scale of habitat loss proposed.
They recommend that the Council should not adopt the Masterplan as a Supplementary Planning Document, until these issues have been addressed.
3/ They commend the approach to sustainability with regard to energy efficiency, and are also pleased to see that the potential to integrate biodiversity into the SUDs system is recognised. However, they believe that a truly sustainable approach would seek to avoid negative impacts to the existing biodiversity of the site, recognise the areas important for biodiversity and design the scheme to retain these areas.
4/ They are pleased that the planting SUDs system will reflect the biodiversity of the existing wetland environment, but it should not be seen as an acceptable replacement for the habitat to be lost to development. They note that the SUDs system shown in Plan 3.10 is mainly to be part of the Formal Landscape shown in Plan 4.8. Whilst They commend the strategy for creating replacement watercourses set out in the SEA RefNo Fullname Organisation Comment Response
(7.2.29), they are concerned that the lack of terrestrial habitat surrounding these ditches will mean that the biodiversity of these ditches will be impoverished in comparison to that found at present.
5/ Regarding proposals for woodland planting they are concerned that these proposals may not take into account the existing biodiversity of the areas to be planted, which may already support priority habitats. RefNo Fullname Organisation Comment Response
QR054 Michaela Kennard Environment Agency They welcome the scheme’s aspiration to be an 1/ Noted. An Appropriate Assessment is currently being undertaken environmentally exemplar project, but there are by SEEDA and will be subject to consultation with all of the many elements of the submitted document which environmental bodies. they would wish to see improved and so they make the following comments - 2/ Agree. The Masterplan should set out more clearly the mitigation and compensatory measures and how these will be delivered. BIODIVERSITY Change agreed. 3/ Change agreed. 1/ Appropriate Assessment The contents page of “Volume 2 – Project Delivery 4/ Add a sentence outlining the need for native species. Change ” lists an Appropriate Assessment as a supporting agreed. volume, but it was not submitted. As such they would advise SBC against adopting this 5/ Noted. document, as without the AA it is impossible to fully assess the environmental impacts of the 6/ This detailed point should be made at the planning application proposed development. stage. 7/ Noted. The Masterplan area is immediately adjacent to the Medway Estuary and Marshes Special 8/ This apparent contradiction will be checked and amended if Protection Area (SPA) and Ramsar site as well as appropriate. Change agreed. the Swale SPA and Ramsar site. As such, this Masterplan and any future applications must be 9/ These are detailed planning application points. assessed in accordance with the Conservation (Natural Habitats, &c.) Regulations 1994 and 10/ SEEDA will be asked to respond to this point. Natural England must be consulted. 11/ It is apparent from the guiding principals that these synergies are present. However, they could be better highlighted. Change agreed. The modifications to the Habitats Regulations mean that Appropriate Assessment is now 12/ SEEDA will be asked to review the Green Charter and it's targets required for land use plans. This was bought in by prior to adoption. Statutory Instrument 2007 No. 1843 The Conservation (Natural Habitats, &c.) (Amendment) 13/ Noted. Regulations 2007. An Appropriate Assessment is therefore required at this stage to ascertain that 14/ Noted. the regeneration Masterplan shall not adversely affect the integrity of the two SPA’s immediately 15/ These matters can be explored outside of the Masterplan process. adjacent to the Masterplan area. 16/ SEEDA will be asked to review the document to see whether these links and multifunctional benefits can be further highlighted. They would strongly recommend that the views of Change agreed. Natural England, who are the lead organisation for AA, are taken into full consideration on this matter. 17/ Noted.
2/ Mitigation and Compensation 18/ Noted. Considering the international status of the wildlife sites adjacent to the Masterplan area and the SSSI 19/ Outside the AAP area, improvements to the defences would, in effect, be a response to existing problems and not a matter for ’s and UK priority BaP habitats within the development. However, the issue of the defences next to the Masterplan area, they would wish to see the report riverside open space could be explored and SEEDA will be asked to set out more clearly and firmly that ecological make reference to this. Change agreed. mitigation and compensation measures must be identified and delivery processes agreed. This 20/ SEEDA will be asked to provide review of the layout in response should be done before the Masterplan is adopted. to SFRA work and that a response be provided in an updated section in the Masterplan on flood risk, which shall additionally highlight the The Masterplan section does not sufficiently state need for site SFA's. Change agreed and address appropriate the level of status of habitat being lost (e.g. priority sections of the sequential test. habitat, wildlife site designation), nor is adequate 21/ See Main Report. information provided about the designation / condition of the land identified for replacement. 22/ Noted. This section also does not refer to potential indirect impacts of the Masterplan on international 23/ It is agreed the reference to PPS23 should be made. Change wildlife sites. agreed.
In summary, they cannot support a document 24/ Whilst understanding the need for a strategic approach to without the above level of strategic information or contamination, the Council does not consider this to be a matter one that has not been adequately assessed for its directly for the Masterplan. SEEDA will be asked to consider the issue and whether and how it should be addressed. RefNo Fullname Organisation Comment Response
impact on European designated wildlife sites. Similarly, they cannot support the Planning 25/ SEEDA is asked to clarify this point. Obligations Strategy proposed for delivering ‘ Masterplan-scale’ environmental infrastructure 26/ Noted. without AA alongside this process. 27/ These issues are largely matters in the control of SEEDA and as such are best addressed via their own mechanisms as set out in the Water Voles Green Charter. No change agreed. This species receives legal protection through its inclusion in the Wildlife and Countryside Act 1981. 28/ This is done with the Council's own waste collection process. Their places of shelter or protection are protected and it is an offence to intentionally or recklessly 29/ SEEDA have been asked to examine the Green Charter and damage, destroy or obstruct access to any comment on this apparent variance. structure or place which water voles use for shelter or protection, and also to disturb water 30/ Noted. voles while they are using such a place. 31/ The SA uses the scoping report for the adopted Local Plan which was subject to wide consultation. No change agreed. The presence of water voles within a development is a material consideration in the planning 32/ Noted. process. Water voles are present within the Masterplan area, and as the lead organisation for 33/ The SA/SEA is being re-cast and will be the subject of further this species, we would therefore wish to see a consultation. water vole mitigation framework strategy produced alongside the Masterplan that sets out a 34/ The Council is unclear as to the purpose of such a reference. No change agreed. translocation policy and good practice applicable to subsequent planning applications, as well as an overall strategy for mitigation and compensation for water vole habitat loss.
Encroachment The EA would not support encroachment or infilling of the intertidal habitat. Encroachment is defined as any works, which extend riverward of the exiting flood defences. Consistent with their National Encroachment Policy, the EA will resist works on the tidal river that cause encroachment or leads to the loss of or damage to river habitats.
Instead, they would encourage any opportunity to enhance and improve the quality of the surrounding habitat for wildlife and if possible revert land back to its natural state. Foreshore and inter-tidal areas which exist between low and high water mark, represent ecologically rich habitats within tidal river systems and a continuous foreshore is essential to allow fish and invertebrates to move up and downstream in fulfilment of their life cycles.
The marina proposal therefore causes them great concern, both by way of its location and its likely impact. It is their understanding that a new entrance will have to be cut through the mudflats in order to access the marina at reasonable states of the tide. Mudflats are a priority habitat in the Government's UK Biodiversity Action Plan and one of the main objectives of the habitat plan is for there to be no net loss. As such they would be strongly opposed to any significant dredging of the mudflats or saltmarsh in order to gain access to the marina without appropriate mitigation and/or compensation which they believe would be extremely difficult if not impossible. RefNo Fullname Organisation Comment Response
3/ Ecological surveys The document should make it clear to potential developers that ecological surveys will be required prior to the development of detailed plans, to enable an assessment of the level of risk posed by the development. Without such information, it is not possible to judge whether the proposals would meet the requirements of PPS9. The detailed design, construction, mitigation and compensation measures should be based on the results of a survey carried out at an appropriate time of year by a suitably experienced surveyor using recognized survey methodology who is welcome to contact us for detailed requirements.
4/ Open Space & Planting The EA supports the plans to enhance public open space for biodiversity but a species planting plan for the proposed development was not included in the proposal. Due to the sensitivity of the surrounding habitat to the development site the document should make it clear that only native species should be included within any planting plan. This will help to ensure that the ecological diversity of the area is maintained and that no species are introduced that will cause adverse impacts on the existing ecology.
5/ Watercourses State that the EA are opposed to the culverting of watercourses. One of the reasons is because it involves the complete destruction of river and bank side habitat and the interruption of a wildlife corridor thereby acting as a barrier to the movement of wildlife, including fish.
6/ FISHERIES
This development can present a unique opportunity to safeguard and improve eel and elver (juvenile eel) access into the freshwater drains and ditches. The European eel populations has crashed internationally and the species (a fish of significant socio-economic value) is at present bellow safe biological limits for exploitation. Eels are known to extensively utilise ditches and drains and it is therefore important to ensure that the connectivity between the sea and drains is maintained or improved. This will allow for juvenile eels to colonise the freshwater ditches and will also facilitate adult eel escapement to sea during their spawning migration. It would therefore be advisable for surveys to be carried out to establish whether there are significant obstructions to the free movement of eels to and from the freshwater and marine environment. Eel and elver passes should then be fitted to any structures which impede the migration of these fish.
SUSTAINABLE DEVELOPMENT
7/ SUDs RefNo Fullname Organisation Comment Response
It is noted that SUDS are proposed across the site. Whilst they welcome this approach any scheme must be designed with great care on this site as considering the previous potentially contaminative uses of the site, and the likely presence of a perched water table within the alluvium, infiltration SUDS may not be viable.
8/ Unfortunately, the Masterplan would appear to contradict itself regarding the receiving medium. For example, it states that it has been recognised that the underlying soils are impermeable clay, thus removing the option of discharging to the aquifer. In contrast, however, another section of the Masterplan state that SUDS will discharge to the aquifer.
9/ For infiltration SUDs to be acceptable there must be no discharge into made ground, land impacted by contamination or land previously identified as being contaminated. There must also be no direct discharge to groundwater, which is a controlled water.
They also emphasise that they would not wish to see existing habitats and watercourses being used to provide components of the drainage system unless any discharge was properly controlled ,e.g. to ensure no pollutant can enter the ecological system. The drainage system should be a separate network for areas likely to be subject to pollution, and should only be discharged into a receiving watercourse after it has been attenuated and remediated. Water levels on the adjacent site of special scientific interest (SSSI) should be maintained or enhanced by the development.
10/ They would welcome the inclusion of water harvesting within the overall strategy. With the aim to achieve water neutrality within the Thames Gateway, it is imperative that they not only reduce our water consumption but utilise all the measures available to us. There are also benefits of water harvesting in terms of flood risk.
11/ There are natural synergies between the two themes of SUDS and green space strategies and we would also recommend that these linkages are better identified and promoted within the document. The design of such systems at the initial development stages of a project provides the opportunity to incorporate reed bed treatment systems and attenuation ponds. Not only are these fundamental components of a sustainable drainage system, they also contribute to further enhancement of the ecological value of the site.
12/ Green Charter They note that a sustainability framework or ‘green charter’ has been developed for the Masterplan area, which sets targets for the delivery and performance of sustainability initiatives. To set up the framework of targets we note that SEEDA RefNo Fullname Organisation Comment Response
formed a sustainability group with key stakeholders including the Environment Agency.
Although the standards or targets proposed form an adequate baseline for development in the Thames Gateway, this development should meet exemplar design standards to establish the Gateway as a low carbon region and maximise the efficient use of water and waste, as outlined within the 2006 Communities and Local Government Thames Gateway Interim Plan.
As SEEDA is already aware, building to a high level of the Code for Sustainable Homes will assist in the demonstration in the high standards of design and sustainability. Many exemplar developments are now making a commitment to build to Code Level 6. This is achievable on a development of this scale through the use of community heating systems and rainwater harvesting which the master plan states is the intention. Therefore they think that the targets for this development have been set lower than is necessary, being only Code Level 3, or 4 if connected to CHP. They welcome that BREEAM ‘ very good’ or ‘excellent’ standards will be applied for commercial buildings.
13/ It is pleasing to note the commitment to adhere to the Kent Design Guide which outlines a set of targets which are based on regulatory requirement, best practice knowledge and innovative performance.
14/ The document also addresses climate change. They are pleased to see the recommendation that developers and planners consult the document ‘Adapting to Climate Change: a checklist for Developers’ - published by the Three Regions Climate Change Group, which will help to future proof any development.
15/ CCHP They welcome the intention to incorporate decentralised CCHP within the scheme. They have some concerns over the use of biomass as the proposed fuel and it's availability, given the large number of CCHP schemes proposed within the Kent area which plan to run off biomass. They would suggest that other fuel alternatives be considered, such as methane generated from anaerobic sludge digestion, or from offsite gasification or pyrolysis of solid recovered fuel.
16/ Green Grid objectives and multifunctional benefits There is an opportunity in the Masterplan to provide a green infrastructure vision at Masterplan level that sets out a spatial visualisation and provides strategic green infrastructure multifunctional objectives. For example, green infrastructure that can provide flood risk management benefits, sustainable land RefNo Fullname Organisation Comment Response
remediation, opportunities for sustainable drainage, improved water quality, access to green space and riverside.
DRAINAGE
17/ Foul Water Disposal It was their understanding that all foul water from this development will be discharged to the public mains sewer system. The Masterplan however, briefly mentions that sewage effluent is also proposed to discharge to SUDS. Under the terms of the Water Resources Act 1991, written approval of the Environment Agency is required for any discharge of sewage or trade effluent into controlled waters, and may be required for any discharge of sewage or trade effluent from buildings or fixed plant into or onto the ground or into waters which are not controlled waters (Controlled waters include rivers, streams, underground waters, reservoirs, estuaries and coastal waters). Such approval may be withheld so the applicant is advised to contact the Permitting Support Centre (08708 506506) as soon as possible to discuss this matter further.
18/ Surface Water Disposal Only clean uncontaminated water should drain to the surface water system. Roof water may be discharged direct to soakaway but only if via sealed down pipes (capable of preventing accidental/unauthorised discharge of contaminated liquid into the soakaway) without passing through either trapped gullies or interceptors. Open gullies should not be used. Appropriate pollution prevention measures (such as trapped gullies/interceptors) should be used for surface water drainage from access roads, parking areas etc.
19/ FLOOD RISK MANAGEMENT The document has given a fair amount of consideration to flood risk and its management as part of the regeneration. There are, however, certain aspects to the plans which in our view require further work. They draw our attention to the fact that the Agency actively promotes proposals which soften the defences, enhance the river frontage and provide opportunities to increase biodiversity. If the existing defence is to be replaced, more sensitive designs, which include enhancements to improve biodiversity and offer more open spaces alongside the river frontage should be considered.
Promoting Sustainable flood defences Though the plan has accepted the policy aim of the Shoreline Management Plan (that the flood defences will need to be maintained and improved to manage the increasing risks), it has not addressed the possible delivery of these objectives via the Masterplan. It also has not RefNo Fullname Organisation Comment Response
identified the risks to the proposals from any future raising of, or works to, these defences. The Masterplan proposals include riverside open space as well as new development alongside the river frontage. This presents an ideal opportunity to improve the reliability of the defences in this area by having stepped flood defences and a retreated flood defence line that can be integrated into these plans. Such a measure would not only provide a more robust flood defence, but also offer more open space alongside the river frontage. If such measures are not taken now there is a risk that the flood defence walls will need to be continually raised at the river’s edge and the linkages between the town and the river will be lost.
20/ Vulnerability of uses and flood resilience The Masterplan needs to consider the source and nature of risk as well as the variation of risk within the study area. This information should be fed into the planning process of locating of schools, healthcare facilities and community/ educational facilities. Consideration should also be given to the necessary alternate uses a facility could be used for in the event of an emergency, e.g., schools being used as refuges. This information should guide the developers in identifying the most appropriate location for these facilities and any flood resilience measures that would be necessary. As there will always be an element of flood risk even in a defended floodplain, they would also recommend that consideration is given to flood resilience measures for all new developments.
Strategic Flood Risk Assessment It is the Environment Agency’s understanding that Swale BC are planning a revision of its Strategic Flood Risk Assessment to provide most up to date information on flood risk in the area. They would recommend that the Masterplan advises developers to take into consideration this updated information as it becomes available.
Planning Applications Whilst strategic options can be discussed at an early stage, any individual planning application will remain subject to the requirements of Planning Policy Statement 25 (PPS25) the Governments guidance on Development and Flood Risk and as such, would need to be accompanied by a Flood Risk Assessment (FRA) in accordance with Annex E of PPS25.
They would wish to see the document advise developers of this requirement and encourage them to consult our Kent Area Development Control Team at the earliest opportunity. This would be beneficial to both the Local Authority and any potential developers in order to discuss the feasibility of appropriate mitigation methods which could be employed in order to adequately address RefNo Fullname Organisation Comment Response
the flood risk to the area.
21/ For information, all developments with a residential element will be subject to both the Sequential and Exceptions Test. If subject to the Exceptions Test, the Local Authority should also be satisfied the application satisfies the remaining two stages of the Exception Test which are that:
·The site occupies previously developed land; ·The development provides wider sustainable benefits to the community and where possible, contributes to the Core Strategy’s Sustainability Appraisal.
22/ GROUNDWATER PROTECTION
The development area is underlain by deposits of alluvium, which in turn overlie the London Clay formation. This is classified as a minor aquifer overlying a non-aquifer. Any perched groundwater within the alluvium is still classed as a controlled water and thus must be protected from potential contamination.
23/ POTENTIAL LAND CONTAMINATION They would expect brownfield land and land contamination to be a significant issue within Queenborough and Rushenden given its long history of former industrial use and so we are very concerned to note that there is no reference to Planning Policy Statement 23: Planning and Pollution Control (PPS23) within either the Masterplan or any of its associated documents. It must be ensured that the development fully meets the requirements of this policy to ensure that there is no residual risk to controlled waters or human health once the development is completed.
24/ The Sustainability Appraisal states that a more detailed consideration of the environmental effects of specific development areas will be undertaken at the planning application stage but we would expect to see this stated in the SPD itself. The SPD should highlight where and how much brownfield and potential land contamination is present. It should discus options for how this can be brought back into beneficial use. It should also refer to policies and practices, which are capable of being used to address land quality and groundwater protection issues. It should also take account of and include other plans and strategies, including soil vulnerability maps, groundwater protection maps and groundwater source protection zone maps which are available for the area. They would also wish to see references to the English Partnerships National Land Use Database, the National Brownfield Strategy and the Local Brownfield Partnerships initiative to create Local Brownfield Partnerships (LBPs) made up of residents, community, industry and developers. RefNo Fullname Organisation Comment Response
Within the report they would like to see a strategic approach developed to land quality, reflecting what can be done at the master planning level. Areas for regeneration should aim to develop Global Remediation Strategies (GRS). GRS are a set of site wide principles and procedures for taking forward Site Specific Remediation Strategies (SSRS) for the assessment and remediation of contaminated land on individual development zones. For each development area a generic conceptual model for the development area identifying the major potential contamination related source, pathways and receptors should be established.
25/ They note that the areas of groundwater contamination within figure 5.5 of the SA do not correlate with areas of soil contamination highlighted on figures 5.3 and 5.4. They would therefore advise the LPA to seek clarification on this.
26/ It is important to advise potential developers that any works carried out on site must be undertaken in such a manner as to ensure that the quality of the groundwater is not derogated, for example, by mobilising contaminants or causing turbidity etc. This will also be applicable where works such as piling or those associated with the flood defences are proposed.
27/ WASTE MANAGEMENT They support the requirement for developers to produce a comprehensive materials management plan to cover, amongst other things, the storage and use of materials during construction, which should minimise spoilage of materials. They would suggest that the plan should also include a requirement to devise and employ practices which minimise over-ordering of materials on site. Where the phasing of development involves a number of development sites, with one or more principal contractors / developers they would suggest that consideration be given to the establishment of a materials and waste consolidation centre. Such centres, where used on other large scale projects elsewhere have contributed to very high levels of resource efficiency and low levels of wastage through damage or surplus material.
They welcome the regeneration schemes aspiration to be an environmentally exemplar project and would suggest that consideration be given to the use of innovative technologies such as the inclusion of an automated waste collection system. Such systems can be used in residential developments, town centres, and office and commercial premises, and though widely used in Europe are less common in the UK. The system operates using a vacuum and comprises several collection points that are linked together by steel piping to a central collection station. Waste RefNo Fullname Organisation Comment Response
removed to the collection station can then be taken away for recycling or disposal. The system supports source segregated recycling and also reduces the number of vehicle movements required to collect waste.
28/ They would encourage provision for recycling in the wider streetscape as the recycling of waste collected as litter can contribute to sustainability and is a visible symbol of an organisation's commitment to the environment and sustainable living. This approach is being encouraged by the Governments Waste Strategy for England 2007 through 'Recycle on the Go', a voluntary code of practice and associated good practice guide which is currently being consulted on.
29/ They note that in the Green Charter table (p10 of The Green Charter for Q & R) under the materials row, recycled content, states for non residential and residential development that 10% by value will be recycled material. This is lower than normal and contradicts a 20% minimum recycled content for all developments specified in the Materials section on page 4. The EA would expect to see that 20% should be the minimum target adopted.
30/ They welcome the objectives set in the Green charter table for waste, including the provision of recycling facilities for both residential and non residential buildings, and for the target of 25m3 or less of waste arising per home constructed, which represents a 50% reduction in terms of that arising on a typical build. They also welcome the schemes adoption of the materials hierarchy as described on page 14 of the Green Charter, which promotes the use of reclaimed materials and those with high recycled content, and the recognised importance of building design in achieving this.
SA / SEA REPORT
31/ Although they acknowledge that it is not a requirement, due to the sensitivity and complexity of this site we believe that it would have been useful to conduct a scoping report before the SA was produced. This would have allowed statutory organisations to contribute to the scoping process and identify specific issues and SA framework objectives applicable to the Masterplan area.
32/ Regardless of this, they believe the SA/SEA Report is broadly in line with the requirements of the Strategic Environmental Assessment Directive, specifically Article 5 annex 1.
33/ The Report is, however, lacking in a few areas. Firstly, the Report does not show how the environment protection objectives established at member state, community or national level have been taken into account. RefNo Fullname Organisation Comment Response
Secondly, it is not entirely clear whether the appraisal within the SA/SEA process has actually informed the decisions made on the alternatives described. It is also not clear if the alternatives considered have been assessed against the SA/SEA objectives.
Furthermore, they are concerned about the conclusions drawn within the Appraisal matrix. Particularly those for 8.1, 12.2, and 13.2, as well as those for Objective 15 where no conclusions have been drawn at all.
Key Findings N.7 They note that results of an Appropriate Assessment are required at this stage to ascertain that the regeneration Masterplan shall not adversely affect the integrity of the 2 SPAs immediately adjacent to the Masterplan area.
Table 2.1 ‘Enhancement of positive impacts, including the biodiversity value of new development’ – the actions listed in the Masterplan section do not sufficiently state the level of status of habitat being lost (eg. Priority habitat, Wildlife Site designation), nor is adequate information provided about the designation / condition of the land identified for replacement.
This section does not refer to the potential indirect impact of the Masterplan on international wildlife sites. They cannot support the report without this level of strategic information.
5.2.1 Site Description They recommend that the locally designated sites of nature conservation interest – Diggs and Sheppey Court Marshes – and the North Kent Marshes Environmentally Sensitive Area are included in Fig 5.1 ‘ecological designations relevant to the Masterplan’.
7.2.23 This paragraph refers to an indicative cross- section of a proposed bund in a buffer zone between the Masterplan area and the SPA. However the drawing is not included in figure 7.1.
7.2.30 It is not sufficient to consider potential implications on Medway Estuary and Marshes SPA at a subsequent stage of planning process. An Appropriate Assessment is required.
34/ Volume 2 - Project Delivery - Definition of Strategy Area and Zones (page 11) Zone C section makes no reference to being adjacent to the Medway Estuary and Marshes Special Protected Area. RefNo Fullname Organisation Comment Response
QR055 Graeme Tuff SBC - Leisure 1/ Given the regeneration site's location between 1/ The boundaries are shown on the maps contained in the Queenborough and Rushenden what will it actually Masterplan document and the name of the new area will be decided be called when built. Where are the boundaries ? at a later stage. No change agreed. 2/ Disappointed that there is little or no reference to Green Grid principals or Parklands agenda in 2/ Green Grid and the Parklands agenda must be included in the the Masterplan. These are obviously key "Thames Public Open Space Strategy as they are principles we would want included in the development. Gateway" environmental principals and should be Change agreed. included within the Public Open Space Strategy. 3/ There should not be a proposed open space line around 3/ Page 54 - Proposed red open space line around Queenborough cemetery - this should be removed. SEEDA to add in Queenborough Cemetery ? the Rushenden Hill ball court on the plans. There is also an existing play area adj to Change agreed. Rushenden Hill ball court.
4/ Could not find a reference to the Coal Wash 4/ See Main Report. railway running through the housing area and open space. I feel that this is a major constraint as it is either a major health & safety risk (?) or it will totally blight the housing and open space areas with appropriate fencing.
QR056 Charlotte Hudson SBC - Community Safety The respondent has a few general points: 1/ Noted. The Architectural Liaison Officer is always consulted.
1/ That the Architectural Liaison Officer needs to 2/ SEEDA are well aware of this need and are committed to providing be consulted on each of the planning applications a community centre as shown by their provision of The Gateway in and phases (which I know already occurs). Rushenden for the last 3 years. No change agreed.
2/ That community and recreation facilities are 3/ These will be dealt with at the planning application stage. No change agreed. incorporated as soon as possible in the development (They note a temp community centre in the master plan).
3/ They think community safety and Section 17 issues will probably be picked up more at the finer detail level, and with close working with the respondent and the Police Architectural Liaison Officer they should be able to address these issues. RefNo Fullname Organisation Comment Response
QR057 Tom Foxall SBC - Design and Conservation Team 1/ States that the Masterplan is generally very well 1/ A new section to cover listed buildings is required within the considered and presented. However, there are Masterplan. various design and conservation issues arising Change agreed. from the draft Masterplan that they consider need to either be highlighted, resolved or given greater 2/ It is agreed that such a bridge would be more appropriate. If emphasis in the final draft. These issues are: current commercial uses of the creek are to continue they will need to be able to stay operational at the creekside. The 'pretty' leisure creekside activities should be concentrated around the new marina. Some of Queenborough’s historic buildings are Change agreed. mentioned in passing, but there is no reference to listed buildings or to the extent of Queenborough’s 3/ See Main Report. conservation area. These are key factors affecting the future development of this area, and their 4/ It is agreed that a statement clearly establishing the LPA's design existence, the nature of their statutory protection expectations at relevant points of the document should be made.. and the need to recognise their contribution to the Design needs to reflect the setting of listed buildings. skyline should be flagged at this early stage. The Change agreed. listed buildings potentially most affected by the 5/ See Main Report. new development include: Swale House, the No change agreed. Guildhall, Holy Trinity Church and Neats Court.
The special character of Queenborough Creek, a significant portion of which is located in the conservation area, is largely characterised by the light engineering, industrial and storage uses of the quayside and their association with fishing vessels etc. The gentrification and increased use of pleasure boats on the creek are likely to result in the degradation of that special character.
2/ Although it is crucial to achieve connectivity between the new development and existing Queenborough communities, the proposed footbridge over Queenborough Creek (indicatively shown on p.114) should not preclude the tall- masted boats that currently use and help define the character of the creek. An opening bridge would be more appropriate here.
3/ Building heights need to be more clearly defined, particularly on the headland at the western end of the creek, where a building of 5 storeys or more might have a harmful impact on the setting of the Grade II listed Swale House. We have no objection, however, to tall buildings around the marina. It should be noted that the success of tall buildings depends to a great extent on their architectural quality and their relationship with surrounding public areas. Also, the impact of a tall, slender building can be significantly different to a tall building with a much larger footprint.
There seems little justification to 5+ storeys in the middle of Rushenden, which is characterised by two-storey houses.
4/ Except for some short paragraphs on pages 73 and 79 and some aspirational drawings and photographs, there is very little that strongly states our expectations for high-quality architectural design or the need to reinforce local distinctiveness. Rather than leaving this issue to future development briefs, we feel that the requirement for an exemplary quality of design should be much more explicitly stated from the RefNo Fullname Organisation Comment Response
outset of this project.
5/ The proposed location of the new school is very poor in urban design terms, because it is separated from new housing by two major roads and will therefore limit pedestrian movement between the two. Given the volume of traffic that might be expected on these two vehicular routes, it is difficult to imagine how, even with traffic calming measures, the public square would be considered safe enough for children to cross to reach the school on foot. RefNo Fullname Organisation Comment Response
QR058 Mr Paul Marshall Highways Agency 1/ State that the proposed Queenborough and 1/ Noted. Rushenden Regeneration, which includes 2000 No change agreed. homes and 180,000 sqm of employment space, will contribute to the traffic impacts on the A249 2/ The Masterplan is consistent with the adopted Local Plan in terms and M2 junctions 5 and 7. In spatial planning and of dwelling numbers. development control terms the Agency has a duty No change agreed. to safeguard the operation of the motorway and 3/ The 22 dph in Rushenden are existing densities and new Trunk Road Network (TRN) on the Secretary of development would not be at this level. State's behalf as laid down in the DfT Circular No change agreed. 02/2007. In addition they have been asked to work with local planning authorities and 4/ Noted. developers to promote more sustainable transport No change agreed. and therefore look to your Council to promote strategies, policies and land allocations that will 5/ These are matters that can be addressed at the planning reduce the need and distance travelled, application stage and via the SA/SEA. SEEDA is asked to comment particularly by the private car. on this issue. 6/ The point is noted, however with the access proposals shown it is 2/ Policy Context - unlikely that there would be significant differences had the Network Analysis approach been applied. The proposed employment regeneration complies No change agreed. with policies B21, B25 and B2 in the Adopted Swale Local Plan (2000). The proposed 7/ This can be addressed at the planning application stage. residential developments comply with policies H28 No change agreed. and H29. The regeneration is in agreement with policies AAP6, MU6, MU7 and B14 in the Draft 8/ These issues can be addressed at the planning application stage. First Review of the Swale Borough Local Plan No change agreed. (2005) and also is in agreement with the 9/ It is agreed that public transport elements should be included objectives in the Queenborough and Rushenden within Volume 2 pages 33-36. Development framework (2004). However, the Change agreed. Draft First Review (2005) and the Queenborough and Rushenden Development Framework (2004) 10/ This is considered unnecessary as the phasing of infrastructure state that 670 residential units will be developed will lead to employment taking place on Neatscourt ahead of housing. on land south of Queenborough Creek and 65 No change agreed. units north of Queenborough Creek. The Masterplan proposal is for 2000 residential units, 11/ SEEDA are aware of this and are to provide an update on their discussions with the HA. approximately 1265 units more than allocated in the Local Plan. The document does state, 12/It is agreed that a definition of 'large' development should be however, that this estimate may be revised in the provided. It is suggested that the definition used by KCC should be Masterplan. It is not clear whether these are applied. additional (over and above the Plan allocation for Change agreed. Swale) or how the increase will affect other allocated housing sites hence the impact on the 13/ Noted. rest of the highway network). 14/ SEEDA to confirm where this document is. 3/ Housing Density -
The Masterplan states that densities of residential homes will range from 22 dwellings per hectare in Rushenden to 80 dwellings per hectare in Old Queenborough, PPS3 states that 30 dwellings per hectare net should be used as a national indicative minimum to guide policy development and decision-making, until local density policies are in place. Where Local Planning Authorities wish to plan for, or agree to, densities below this minimum, the 22 dwellings per hectare in Rushenden will need to be justified.
4/ Community Facilities -
The proposal includes community facilities, such as modern healthcare facility, primary school and sports hall. The HA would support the RefNo Fullname Organisation Comment Response
development of carefully sited community facilities that may have the potential to reduce the need to travel to larger urban areas and therefore align with PPG13.
5/ Accessibility -
The HA is supportive that the document addresses transportation issues in the formation of the Masterplan. It is critical that local level land- use development strategies take full consideration of opportunities to reduce the need to travel, reduce the distance travelled and encourage travel by sustainable modes in accordance with PPG13.
Accessibility to the wider area by bus, rail, bike and foot will be key to ensuring that the local residential and work-based population can be shifted away from car to public transport, that it was one of the objectives of the Queenborough and Rushenden Development framework (2004). The HA would like to see a Public Transport Accessibility Level (PTAL) assessment to demonstrate that the policy objectives can be achieved.
The Development Framework (2004) states that the employment opportunities will allow for the creation of new jobs for existing and new residents of the area. To meet the policy objectives, the developer needs to demonstrate that new employment opportunities can be filled by the local available skill set. If this is not the case then the development will generate both outward commuting journeys, as residents leave the area to work in other locations, as well as inward commuting journeys, as people arrive from other locations to work in the regeneration area. It is therefore important to get the balance right. A similar outcome can occur if the development of residential and employment sites are not phased out appropriately. This should be demonstrated through the sustainability appraisal.
6/ Plan 3.8 provides the reader with a map showing walking distances from two 'hubs' in the regeneration area. The walking distance has been based 'as-the-crow-flies' distances. Therefore distances based on 'as-the-crow-flies' would not provide reliable estimates of actual distances covered within the 15 minute period. Walking distances should be demonstrated using a GIS network analyst tool (eg Network Analysis). An accessibility assessment should be carried out to demonstrate that the sustainable policy objectives can be met.
7/ The Draft First Review of the Swale Borough Local Plan (2005) states that improvements to bus services, especially in Rushenden, will be addressed. The Masterplan states that the Rushenden Relief Road will provide a 'loop' for RefNo Fullname Organisation Comment Response
buses to enter the regeneration area. No details have been provided as to how the 'loop' bus route would be implemented. It is important that any new bus service or route is an enhancement of the existing provision and does not result in a loss of part or all of the new existing service or a reduction in existing frequency. This will ensure that new development would have sufficient provision of public transport, with existing users not being adversely affected.
The use of buses to connect to the wider network, especially the mainline, should be clearly shown. Provision of bus services and accessibility level should be demonstrated through a PTAL.
8/ Parking Provision -
It is recognised that there is a balance between the need to provide sufficient parking to limit 'overspill' effects on the local network, but at the same time the oversupply of parking is likely to limit the effectiveness of demand management measures that are important in encouraging a reduction in travel and the use of sustainable modes. The HA would suggest that demand associated with specific developments should be carefully managed. Parking provision should then be determined based on the outputs of the overall analysis, including the transport and sustainability appraisal.
Parking standards are often used to set a maximum level of parking, but opportunities to reduce parking below these levels should be sought in each case. This would aid in the shift from car to public transport in supporting the sustainable transport policy objectives.
9/ Phasing -
The HA considers it vital that development does not take place at a faster rate than the provision of any related infrastructure requirements, as this could lead to impacts occurring on the Trunk Road Network (TRN). For example, the Masterplan states that the Rushenden Relief Road will provide a loop circuit for buses to provide a service to the new employment at Neats Court. If the Neats Court employment area is occupied before the completion of the Rushenden Relief Road, then the provision of a bus service using the relief road to 'loop' around the development area will not exist. As a result, those employees at the Neats Court development may use their own vehicles if public transport is not readily accessible. It will be harder to shift these people from car to public transport at a later date.
10/ Similarly, there is a risk that market demand will result in residential development, for example, being completed prior to any complementary employment, resulting in the establishment of long RefNo Fullname Organisation Comment Response
distance commuting. The phasing of residential and employment sites should be considered at this stage so that the development can begin to contribute to its sustainable principles from the start.
11/ Impact on the Trunk Road Network (TRN) -
State that whilst individual smaller housing and employment sites are unlikely to produce many trips, when examined in combination their individual small impacts on the TRN will be compounded. When these sites are then further combined with other development areas or land- uses, their potential accumulated impact could then become materially significant. Bearing this in mind, the Masterplan proposal is likely to impact key junctions on the A249 and M2 Junctions 5 and 7.
Given the size of the proposal and the relative proximity to the TRN, the HA is concerned that this site will have an impact on the TRN, which should be properly assessed and mitigated as appropriate. We would wish to remain involved as further specific details emerge about the proposal and to work with the applicant and Local Planning Authority in helping to support the proposal.
The HA would be happy to discuss and provide guidance to take this forward.
12/ Project Delivery and Green Charter -
Green Travel Plans (TPs) have been identified as a requirement for individual large developments. The definition of a 'large' development should be further clarified to take into consideration the number of employees/residents, skill set as well as size. For example, a 'large' site in terms of size may only be a warehouse employing a small number of staff compared to a relatively 'small' office which employs a large number of staff. Similarly, one large site (eg B8 with low employment density ratio) may employ people locally, thus reducing the number of long distance car trips, compared to another small site (B1 with higher employment density ratio) where employees travel from far away and use their private car to get to and from work.
A TP would need to be agreed with the Local Highway and Planning Authorities and the Agency and approved by the Local Planning Authority . It would also be required as part of the terms of the lease or purchase both to adopt the Framework and produce/resource their own TP accordingly.
13/ The charter identifies the need for increased capacity on public transport, improved bus service that is synchronised with train times, a more regular train service, improved walking and cycling routes and better access to the mainland and RefNo Fullname Organisation Comment Response
London. The HA welcomes these approaches as they will aid in the shift from car to public transport, but would like to.
14/ The Green Charter document states that pathways and cycleways will be promoted throughout the area in line with the Framework Travel Plan for the Regeneration Area. However, the HA is aware that this document currently does not exist, but will be made available to it shortly.