Response to Local Plan consultation

Arches Chatham Neighbourhood Forum (ACNF) has reviewed Medway Council’s draft Local Plan policies and submitted the below comments for consideration.

Policy DM7: Shopfront Design and Security

We strongly support this policy’s intention to prevent the loss of traditional shopfronts, which help to foster a sense of place and civic pride. The protection of traditional shopfronts has been similarly championed through the adopted Arches Chatham Neighbourhood Plan and its Design Code.

In addition to paragraph 5.5.10, we suggest that explicit reference is also made to relevant design codes produced by neighbourhood planning forums that consider shopfront design. We suggest the following wording:

‘Made and emerging Neighbourhood Plans in Medway have also highlighted the value of protecting traditional shopfronts through design codes. Further design guidance and policies are provided in these and must be adhered to where relevant.’

Shopping Parade 16: Luton Road, Chatham

We agree that 142 Luton Road (former Elephant and Castle pub) should be included in the boundary of this Shopping Parade.

However, we disagree with the proposal to include 1-16 Harnan Court. This new-build property is purely residential in use and does not offer any commercial or community functions. It does not meet the assessment criteria and as such should be removed from the boundary.

Policy T8: Houses of Multiple Occupation

In response to question 14, the adopted Arches Chatham Neighbourhood Plan defines the threshold for an over-concentration of HMO as:

‘20% HMO on the road of the planning application, ensuring that only 1 out of a consecutive row of 5 units is converted to C4. Two C4s should not adjoin and no C3 property should be sandwiched between two HMO.’

This threshold was developed by reviewing successful policies of other LPAs, such as Enfield Council and Oxford City Council. We recommend this approach and welcome any criteria that goes further.

Addition of community-led housing policy

We are concerned that there is no mention of community-led housing in the draft Local Plan, despite it extending to a period up to 2041.

Community-led housing development can help boost the supply of housing to meet Medway’s targets, as well as diversifying the type of housing being delivered or in the pipeline. Supporting the scaling up of community-led housing can also help increase the creation of genuinely affordable homes in Medway, providing more people with access to good-quality homes in thriving and connected communities.

Therefore we strongly urge Medway Council to put in place a specific policy that positively supports community-led housing.

A good example can be seen in East Cambridgeshire District Council’s Local Plan, through Policy LP5 (Community-led Development) which reads as follows:

‘The Council is very supportive of community-led development. This may include schemes involving housing, small business units and other appropriate uses. In principle, there will be a presumption in favour of genuine community-led development schemes, even on land not allocated for development and including on land outside of development envelopes, subject to meeting criteria (with further details on these criteria as set out in a Supplementary Planning Document (SPD).’

The above-mentioned SPD outlines the following:

‘The District Council is generally supportive of community-led development…the affordable housing elements may be permitted outside development envelopes as an exception to normal policies of control where:

  • The District Council is satisfied that (i) the scheme was initiated by a legitimate local community group, such as a Parish Council or Community Land Trust and (ii) the scheme has general community support, with evidence of meaningful public engagement.
  • It can be demonstrated that the scheme will be well managed and financially viable over the long term and that any benefits provided by the scheme can be retained by the local community in perpetuity.
  • An element of open market housing on the site will only be acceptable where it is demonstrated that it is essential to enable delivery of the affordable housing or other community benefits on the site’.

Policy T27: Reducing Health Inequalities and Supporting Health and Wellbeing

While we welcome references to the Health Impact Assessment (HIA) tool, we believe that the following steps could be taken to improve HIA implementation for planners, public health officials and developers:

  • An unambiguous trigger for an HIA within policy wording. At present, Policy T27 states that ‘All major development proposals or those that the Council would consider having the potential to have a significant impact on health and wellbeing’ must be accompanied by an HIA. The triggers for the latter are not clearly defined – precise thresholds could include the number of homes, size of floorspace, location and/or type of business. In Medway, we suggest that HIAs could be required for proposals in deprived areas with poor levels of health and/or on certain business types, such as hot food takeaways, betting shops, and off-licence shops.
  • Consider setting out the HIA process to clearly state expectations for what an HIA should include.
  • Consider the outcomes of HIAs and explain how the results of HIAs will be implemented, for example through planning conditions. This could also include details of implementation, ongoing management of issues and/or monitoring.​
  • Include explicit metrics for monitoring HIAs to inform evaluation of the effectiveness in a given location.