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Michael Birch From: Skinner, Helen <[email protected]> Sent: 19 February 2021 08:26 To: Michael Birch; Duncan Parr; Canavan, Peter; planningappeals Subject: FW: Planning Inquiry - 3259868 – Pump Lane, Rainham For information Kind regards Helen Helen Skinner Inquiries & Major Casework Team The Planning Inspectorate https://www.gov.uk/government/organisations/planning-inspectorate Twitter: @PINSgov Email: [email protected] Telephone: 0303 444 5531 From: Save The Hoo Peninsula <[email protected]> Sent: 18 February 2021 19:01 To: Salter, Tim <[email protected]>; Skinner, Helen <[email protected]> Subject: Planning Inquiry - 3259868 – Pump Lane, Rainham Dear Planning Inspectors, We would like to provide a representation to the planning inquiry 3259868 (Pump Lane, Rainham, Kent) from the Save The Hoo Peninsula Campaign. Our representation intends to provide some information with regards to the wider context and development plan/Local Plan being proposed by Medway Council. In particular, the building of 12,000 new homes and the associated infrastructure, which we believe is inadequate, via the £170m Housing Infrastructure Fund (HIF) award. We feel that there are many contradictions with Medway Council's case for refusing to grant planning permission at the Pump Lane, Rainham site in comparison with their plans for the Hoo Peninsula of which we strongly oppose. We have listed Medway Council's reasons for refusal below and our feedback. Reason 1. Medway Council has concerns regarding the impact from the proposed development (Pump Lane, Rainham) on the Medway Estuary & Marshes SSSI, SPA and Ramsar. In contradiction, Medway Council's proposals for the Hoo Peninsula will be surrounded by, and will potentially negatively impact, many more protected sites including the Medway Estuary & Marshes SSSI, Tower Hill to Cockham Wood SSSI, Chattenden Woods And Lodge Hill SSSI, Northward Hill SSSI and the Dalham Farm SSSI. 1 Reason 3. Medway Council has concerns that the proposed development (Pump Lane, Rainham) will negatively impact the Gillingham Riverside Area of Local Landscape Importance (ALLI). In contradiction, Medway Council's proposals for the Hoo Peninsula will negatively impact many more ALLI's including the Hoo Flats ALLI, Northward Hill ALLI, Hoo Peninsula Farmland ALLI, Lower Stoke Farmland ALLI, Chattenden Ridge ALLI, Deangate Ridge ALLI, Hoo Farmland ALLI, Cockham Farm Ridge ALLI, Hogmarsh Valley ALLI, Bald Top Hill ALLI and Tower Hill ALLI. Reason 8. Medway Council has concerns that the proposed development (Pump Lane, Rainham) will result in the irreversible loss of the best and most versatile (BMV) agricultural land. In contradiction, Medway Council's proposals for the Hoo Peninsula will result in the wholesale loss of hundreds and hundreds of hectares and the greatest concentration of the best and most versatile (BMV) agricultural land, all being top grade/Grade 1, within the Medway Towns and Hoo Peninsula. Medway Council also states that the proposed development (Pump Lane, Rainham) conflicts with their development strategy/Local Plan of building 12,000 new homes on the Hoo Peninsula with associated infrastructure. However, Medway Council's Highways Business Case for its Housing Infrastructure Fund (HIF) project states, in conclusive data tables, that there will be an overall negative outcome once you take into account the dependent development for the highways scheme. Medway Council has also stated "to develop housing of such a scale it is inevitable that there will be impacts on the wider (road) network". The railway scheme, to reintroduce a branch line passenger railway, has been reviewed by transport consultants Robert Skene Consulting Ltd. They have stated that they "would be pleasantly surprised if the proposed railway scheme were to be anywhere remotely close to either financial or economic viability". They also go on to say that the railway scheme is at considerable risk of escalating over bu dget whereby Medway Council and local taxpayers would have to pay for any financial overruns. The implementation time of being in excess of five years, not three years or before 2024, is more likely. Save The Hoo Peninsula does not believe that Medway Council's infrastructure proposals are viable, sustainable or deliverable for the development of 12,000 homes on the Hoo Peninsula. This is important to take into account when you consider that the Pump Lane, Rainham site is situated right next to an existing main line railway. Also, the Pump Lane, Rainham site is closer to significant roads such as the M2 motorway and the A2 (both running through Kent). In the very likely event that the Independent Examiner rejects Medway Council's Local Plan (for a third time), because of their unsound and unjustified proposals for the Hoo Peninsula, Medway Council or the Government (if the process is taken away from them) would need to identify other suitable sites for development. Pump Lane, Rainham would certainly be one of these sites considered for development. 2 With the absence of an up-to-date Local Plan and at this present moment in time, the Pump Lane, Rainham site has to be considered a sustainable and suitable site for development when compared with other and lesser suitable and sustainable sites across the Medway Towns and the Hoo Peninsula. Medway Council's proposals and development plan/local plan, particularly for the Hoo Peninsula, may never come to fruition and therefore Medway Council cannot use this basis and argument to refuse the Pump Lane, Rainham development site. Save The Hoo Peninsula does not take pleasure in arguing for development to take place in other parts of the Medway Towns, on sites that we see are more suitable and sustainable, particularly as development affects local residents in those areas. However, we believe that Medway Council's proposals for the Hoo Peninsula are unjustified and are unsound and there is a reasonable and better alternative to their current proposals. The Pump Lane, Rainham development must be allowed. Kind regards, Save The Hoo Peninsula Campaign Facebook.com/SaveThe.HooPeninsula/ To help protect your privacy, Micro soft Office prevented automatic download of this picture from the In ternet. Coronavirus advice image with text say ing Hands, Fac Please note that the contents of this email and any attachments are privileged and/or confidential and intended solely for the use of the intended recipient. If you are not the intended recipient of this email and its attachments, you must take no action based upon them, nor must you copy or show them to anyone. Please contact the sender if you believe you have received this email in error and then delete this email from your system. Recipients should note that e-mail traffic on Planning Inspectorate systems is subject to monitoring, recording and auditing to secure the effective operation of the system and for other lawful purposes. The Planning Inspectorate has taken steps to keep this e-mail and any attachments free from viruses. It accepts no liability for any loss or damage caused as a result of any virus being passed on. It is the responsibility of the recipient to perform all necessary checks. The statements expressed in this e-mail are personal and do not necessarily reflect the opinions or policies of the Inspectorate. DPC:76616c646f72 To help protect your privacy, Micro soft Office prevented automatic download of this picture from the In ternet. Environment al advice image with text saying p lease 3.
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