Medway Council Planning Services Gun Wharf Dock Road Chatham Kent ME4 4TR Date: 18 April 2017 Our ref: 06715/NG/BE/13437964v1 Your ref: Dear Sir/Madam Representations to Medway Local Plan: Regulation 18, Development Options Consultation This letter has been prepared by Lichfields on behalf of our client, the Peel Group, including ‘Peel Holdings (Land and Property) Limited (“Peel”). Peel is a private real estate, media, transport and infrastructure investment company who is a major landowner in Medway. Lichfields (formerly trading as NLP) has previously submitted representations on behalf of Peel in relation to their landholdings at Chatham Docks (SLAA Ref: 0824), Wooley’s Orchard (SLAA Ref. 0749) and Land East of Seymour Road (SLAA Ref. 1047) – appended to this letter. Lichfields has attended on behalf of Peel Local Plan workshops relating to East of Rainham. This letter comprises formal representations to the Development Options Consultation in respect of the emerging Medway Local Plan. Peel welcomes the opportunity to be involved in the creation of policies that will form part of the emerging Local Plan. These representations provide comment in relation to the various options proposed within the consultation document relating to sustainable development options and housing strategy. Section 3: Delivering Sustainable Development - Options Scenario 1 - Maximising the Potential of Urban Regeneration This scenario seeks to continue the regeneration of waterfront sites, including building at higher densities in appropriate locations. This approach would deliver much of the housing in the form of apartments, but will not on its own meet the needs of all the different sectors of the population. The Council also recognises that high-density riverside development will not support the housing requirements of everyone. In addition to this approach the Local Plan will need to support the incremental expansion of suburban and rural areas as suitable locations for new development, in order to achieve a balanced development strategy. In order to meet the OAN in the short, medium and long term, a combination of housing approaches is required. Registered in England No. 2778116 Regulated by the RICS Notwithstanding the need for alternative approaches, Peel supports this urban regeneration scenario as it will form part of a broad range of sites in terms of the location and types of dwellings provided. This will ensure the needs of the different sectors of the population are met. The Housing White Paper – Fixing our Broken Housing Market (2017), suggests that national policy will be amended to indicate that great weight should be attached to the value of using suitable brownfield land within settlements for homes. In addition, the Housing White Paper places a focus on increasing density in urban locations which are well served by public transport. This scenario would therefore support the aspirations of the Housing White Paper. Peel considers its landholdings at Chatham Docks are well placed to accommodate growth in line with Scenario 1. This scenario will allow for high density flats and important family housing to be provided. High density development provides an opportunity to rejuvenate underused brownfield sites to create sustainable communities and make a meaningful contribution towards the identified housing need. The Medway Strategic Housing Market Assessment (SHMA) (November 2015) identifies that the number of households in the 15-24 and 25-34 age groups will increase by 5% and 13% respectively from 2013-2033. High density town centre and riverside developments predominantly comprise smaller housing units, typically 1 to 2 beds, and as such will help to meet this identified future need. An example of the positive contribution this development option can make is the Chatham Waters Development which has outline approval for 950 residential units on a 14.6ha site (Ref. MC/11/2756), which by itself will provide 74.2% of Medway Council’s annual OAN. The acknowledged need to supplement urban regeneration with development elsewhere in Medway is supported by Peel. Peel also supports the incremental expansion of suburban and rural areas (see below) as this has the potential to utilise sustainable and well connected infill plots on the edge of existing settlements to meet the housing requirements for families. This type of land is often available for development in a timely manner and as such can help to contribute towards the Council’s immediate housing need. Peel’s landholdings in Rainham (Wooley’s Orchard and Land East of Seymour Road) provide potential to assist in the incremental expansion of Rainham and contribute meaningfully towards meeting Medway’s housing need. Scenario 2 – Suburban Expansion In this scenario, consideration would be given to the development of sustainable urban extensions around Rainham, Capstone and Strood, and the Council acknowledges that development could be located on greenfield sites “that may be quicker to develop than large brownfield sites”. Peel considers that the first priority should be development on non-green belt land, in particular brownfield land, under-utilised land and appropriate suburban incremental development. Brownfield sites offer sustainable regeneration opportunities and the National Planning Policy Framework (NPPF, 2012) encourages the effective use of land by reusing land that has been previously developed (para. 17). Chatham Docks is a brownfield site which, as outlined previously, offers substantial regeneration opportunities to accommodate future development needs in Medway. In line with national policy, Peel believes priority should be given to development on existing brownfield sites; and then appropriate edge of suburban / rural locations. This is also supported by the Housing White Paper which places a continued endorsement on Green Belt policies. Peel’s landholdings at Wooley’s Orchard and Land East of Seymour Road are capable of being developed to meet housing need in the short term and can address the current shortfall in the five year land supply. It is important that deliverable sites such as these are included in the Local Plan strategy, alongside sustainable urban extensions, which will take much longer to come to fruition. Pg 2/4 13437964v1 Scenario 3: Hoo Peninsula This scenario commits to the continuation of urban regeneration of brownfield sites. A key strand of this scenario is also the expansion of Hoo St Werburgh into a small rural town. The focus is on developing a sustainable rural town, and concentrating development around larger villages to avoid sprawl into the wider countryside. As discussed above, Peel supports the principle of the urban regeneration approach, including at its land holdings at Chatham Docks. Peel considers that the priority should be to focus development on existing brownfield sites along with incremental development of appropriate suburban locations. Scenario 4: Urban Regeneration and a Rural Town This scenario brings together components of the previous three scenarios. It includes elements of developing at higher densities in waterfront and urban centre sites in Chatham and Strood, and seeking opportunities to consolidate development sites in these urban areas. As outlined above, high-density riverside development and incremental suburban development provides a significant opportunity to achieve a balanced development strategy and Peel considers that this should be a priority. Peel does not accept that land at Chatham Docks should not be identified for housing development due to the complexity of the site. The Council has not adopted a consistent or sound approach to all potential major development sites. No reasoning is provided by the Council as to why the potential complexity of the site should prevent development here and no commentary is provided on other potential development sites. Peel continues to consider the site well placed to accommodate residential development. As outlined above, high density development in this location would provide an opportunity to rejuvenate an underused brownfield site, to create a sustainable community and make a meaningful contribution towards the identified housing need as in accordance with the principles of the NPPF. In addition, the updated Strategic Land Availability Assessment (January 2017), identifies Chatham Docks as both available and suitable for up to 2,577 dwellings. As discussed above, a previous example of a positive redevelopment of a brownfield site is the Chatham Waters Development which has outline approval for 950 residential units on 14.6ha (Ref. MC/11/2756), which by itself will provide 74.2% of Medway Council’s annual OAN. Summary In summary, in line with national policy, Peels considers that priority should be given to the development of existing brownfield sites and also appropriate incremental suburban/rural development. These priorities will ensure a broad range of sites in terms of the location and types of dwelling are provided, ensuring the needs of the different sectors of the population are met.High-density riverside development, on brownfield sites and incremental suburban development provides a significant opportunity to achieve a balanced development strategy and Peel therefore considers that this should be a priority. Section 4- Housing Policy Approach: Affordable Housing and Starter Homes The appropriate requirement for affordable housing needs to be kept under review and is inextricably linked to the OAN, the range of housing sites allocated, the appropriate density