Medway Labour and Cooperative Group
Response to the Housing Infrastructure Fund Consultation
Future Hoo – New Routes to Good Growth
Following the successful Housing Infrastructure Fund bid the Council has now begun a period of consultation with communities in Medway over the infrastructure projects that are needed to support the delivery of the new housing proposals for Hoo as laid out in the document Hoo: New Routes to Good Growth.
This is the Medway Labour and Cooperative Group response to this consultation.
The delivery of the infrastructure is divided into three parts, although we understand that they are linked:
- Rail – £63m of rail improvements, including a new station at Sharnal Street
- Road – £86m on a series of road improvements to be completed by 2024
- Environment – £14.35m on projects to protect and enhance the biodiversity and landscape of the area.
Firstly we would like to comment upon the principles of development in the Hoo area. We will then follow this with comments addressing each of these three issues.
Secondly, we would like to point out that these are only three elements of a much more complex picture of community infrastructure needed for the area, incorporating health, education, social, leisure and employment, none of which are addressed properly within the Hoo: New Routes to Good Growth document.
An underlying principle in our response is that the development on the Hoo Peninsula should become a model of sustainability, economic, social and environmental, and act as a guide for all future developments of a similar nature.
- The Principle of the Development on the Hoo Peninsula
The Medway Labour and Cooperative Group supports the development of new housing in relation to the HIF, however, there are some points that need to be considered;
Is the proposal to build 10,600 homes sustainable?
The Government has imposed targets for new houses across the country with a large proportion in the south east. This has obvious knock on effects for Medway, where we are struggling to produce a new Local Plan, which is now many years behind schedule, and where we are even struggling to achieve our annual housing targets. The newly emerging Local Plan is based around the understanding that we have to build close to 30,000 in Medway, of which around a third are included in the Hoo Peninsula proposals.
The purpose of the planning system is to contribute to the achievement of sustainable development. By this we mean that we aim to meet the needs of the present without compromising the ability of the future generations to meet their own needs. This purpose is based upon three overarching objectives; economic, social and environmental. Within any Local Plan these three objectives need to be carefully balanced.
In relation to Medway as a whole and the development around Hoo we believe these objectives are not being met under the current proposals. The current proposals appear to satisfy an economic objective of housing supply for the country as whole without consideration for the local needs of Medway and in particular of the Hoo area.
The social objective is aimed at supporting strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations. There is no credible data included to support the proposals for Hoo that 10,600 homes are needed in the local community or indeed that the overall figure for Medway of close to 30,000 is needed either. Nor does the document consider how to prioritise the type of housing mix required to secure the desired social resilience of communities.
In fact, the Hoo: New Routes to Good Growth document states that:
“Decisions as to whether it is appropriate to allocate land for the development of new homes, (totalling) 10,600 or any other number of homes or other development will be made in the Local Plan process, and the decision to award HIF funding does not predetermine the outcome of the planning process.”
From the conversations we have had to date the Hoo infrastructure is to be developed alongside the Local Plan which is not expected to be adopted until at least late in 2022.
Since there is no clear idea as to whether this number of new homes is needed for Medway or Hoo, this then, potentially, throws the whole process of determining how much infrastructure is required into question as well.
With regard to the environmental objective for sustainable development there are some equally worrying implications regarding sustainable transport and air pollution. The fundamental changes made to the proposals for the rail infrastructure undermine this sustainability in environmental terms. The Hoo: New Routes to Good Growth document states:
“The HIF proposals are intended to address the challenge of getting on and off the peninsula by providing three ways on and three ways off of the peninsula (the new road linking the A289 to A228, the existing but improved Four Elms Hill junction and the new rail passenger service). This is in addition to the improvements being planned for Bell’s Lane, Ropers Lane and Main Road junctions.”
The loss of the rail link between Sharnal Street and Strood and the sheer scale of development being proposed at the moment does not give us confidence that the measures now provided for both road and rail infrastructure improvements will be effective.
Would a lower figure for new homes be sustainable?
There is no doubt that Medway is in urgent need for new homes. As clearly stated in the Hoo: New Routes to Good Growth document, these can be and should be delivered through the emerging Local Plan. As explained above, however, under the current situation they are instead being imposed by the Government.
It is the position of the Medway Labour and Cooperative Group that a lower figure would be more realistic and that a sustainable figure for the development around Hoo should be proposed based on a more in depth analysis of the condition of existing housing across Medway, population trends and the current housing waiting list.
There is also a need to take the impact of the Covid pandemic into account because data on infection and deaths shows that health inequalities impair the ability of more deprived local communities to thrive. Poor housing is one of the key determinants of health inequality and the current plans do not address this issue, choosing to focus instead on communities of the future. The HIF would have a much greater chance of achieving its aims if the proposals contained plans to ensure that clear links are made between the established communities and those to come. This would allow us to make these new communities merge more seamlessly with the existing ones and allow us to bring about real improvements for both.
In summary, our position is predicated on the belief that:
- In sustainability terms development in general and housing in particular is an environmental and social and not just an economic issue.
- Fundamentally important decisions need to be made on the links between existing and new communities
- The changes to the rail system makes the current delivery of a sustainable development on the scale proposed impossible.
- The impact of the COVID-19 crisis has fundamentally changed the housing market not just in the south-east but across the whole country.
This suggests that a new Strategic Housing Land Availability Assessment is required to review the viability and deliverability of sites being proposed for the Hoo housing development. The HIF proposals would then have a much greater chance of achieving the aims for providing some of the infrastructure required for the new communities which are being created. There would also be the opportunity to make these new communities merge more seamlessly with the existing ones and allow us to bring about real improvements for both.
The rail infrastructure is the most expensive part of the overall scheme and there has already been a fundamental change from the way this was initially envisioned with the loss of the direct link to Strood from Sharnal Street. Consequently there are a number of questions that need to be answered.
The implication from recent discussions and presentations is that the loss of the “curve” link to Strood is only temporary and will be reinstated if there is a clear demand for this as part of the rail service in the future.
- How realistic is this and is there going to be a proper and open process by which this can be measured?
- Is the basic work on issues such as land ownership being done to facilitate a speedy outcome if the “curve” is found to be a viable option?
- Will we then have a clear idea as to when a rail link to Strood will be delivered?
With regards to the new station there are a number of key points we would like to make:
- We need to minimise the number of cars travelling to the station each day. This can be achieved by providing an electric bus service from the surrounding housing estates that operates throughout the day, and especially at peak times for both school and work commuting.
- There needs to be car free, green routes to the station, that make walking or cycling the preferred way of getting there. This would be in line with the principles of a “20 minute town” (see reference below).
- The station itself should be carbon neutral both in its construction and operation.
The loss of the rail link to Strood essentially means that anyone travelling into Medway from the new development will use their cars. The suggestion that people will choose to travel to Gravesend and then back to Strood is not realistic.
- Are there alternative sustainable forms of transport being planned such trackless trams and dedicated bus lanes and/or provision of ultra-low emission buses connecting the Peninsula with the rest of Medway?
The redevelopment of the road network around the area for the new housing is designed to reduce congestion at key points along the routes off the Peninsula. Effectively, the improvements to the road infrastructure are simply road widening schemes and additional link roads to spread the load of the huge volumes of extra traffic that are expected as the new housing is developed.
The development proposal with an emphasis on the car as the main mode of transport will inevitably lead to increases in traffic related air pollution. In particular, the Four Elms Hill, as an AQMA, is notorious for this. The new housing developments will generate a huge amount of traffic and, in addition, there are already major development proposals for Kingsnorth, Cliffe Woods and the centre of Strood itself, all of which will be generating traffic.
- How much confidence is there that the road improvements are sufficient to cope with the expected volume of traffic, including the traffic generated from developments close by?
Is the modelling used robust enough and can we have access to the figures?
- Can the amount of infrastructure being proposed be delivered on time?
- If the infrastructure is not being delivered on time will there need for compromises as we approach the deadline for delivery of 2024. Will the Council at that time have further negotiations with Government around delivery and possible repayment of the HIF?
- How do the six phases of road infrastructure improvements help to mitigate the inevitable rise in traffic related air pollution caused by the Hoo development and other nearby developments?
The Town and Country Planning Association recently launched its Guide to the 20 Minute Neighbourhood (https://www.tcpa.org.uk/the-20-minute-neighbourhood). This is a concept which ensures that all the immediate needs for the residents in new communities can be found within a 20 minute walk or cycle. These include:
- Local Shops
- Local Schools
- Local greenspaces
- Local public transport
- Community facilities – libraries, churches, medical centres, etc.
We feel strongly that walking or cycling should become the preferred way of travelling for most people in the community and where this is not possible then there should be provision of affordable and carbon neutral public transport. This would lead to a community of minimal car ownership and minimal car usage. Consequently, as the targets for EV vehicles are achieved vehicle related pollution will quickly drop to virtually zero.
These principles are also embodied in the Governments guidance on planning and sustainable development. They are also reflected in Government guidance on healthy living, obesity, mental and physical wellbeing.
- In what way does the HIF scheme with the curren emphasis on the car as the main means of transport fulfil these ideals?
The main part of the environmental objectives of the HIF scheme revolve around the delivery of the Strategic Environmental Management Scheme. In principle, we support the SEMS as it will deliver the biodiversity, access and landscape improvements and mitigation required. We would like to emphasise the need to deliver a net gain of 10% of the biodiversity for the area.
However, on the wider environmental issues, especially around air pollution, there are some questions that need answering.
Within a planning context we understand that the HIF projects should contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.
- In what way does the HIF scheme deliver this?
We are seeking reassurances that going forward the principles of sustainable transport will be incorporated into every aspect of the infrastructure development.
This would include;
- Minimising the reliance upon cars
- Ensuring that all works on the infrastructure, including materials, vehicle movements, etc. are mitigated to ensure a low or zero carbon delivery of the HIF scheme
- That there is a net gain (as defined in the Government guidance) for biodiversity of at least 10% across the life of the project
The Medway Labour and Cooperative Group want this and all future developments to be sustainable in social, economic and environmental terms. The HIF scheme must address needs in all of these areas. We do not want isolated communities that are totally reliant on car travel to access services and amenities.
- There needs to be a fundamental reassessment of the housing needs in the Hoo area which should be informed by and be a part of the Local Plan
- With the disappointing changes that have been made to the rail infrastructure we are asking for a guarantee that an alternative sustainable transport infrastructure will be put in place.
- We are also asking that the principle of a 20 minute neighbourhood lies at the heart of all the planning for the new community.
The HIF scheme is key to the future of the Hoo Peninsula and its role within the wider challenges for communities in Medway.
As the Medway Labour and Co-operative Group we recognise that we are not starting from a blank sheet of paper. Without the benefit of a Local Plan there has been a piecemeal approach in recent years to development on the Hoo Peninsula with residents rightfully saying where is the infrastructure to accompany the new homes which have already been built. This is before the consideration of over 10,000 more homes.
The infrastructure which many residents are looking for is not just transport, although important, but must include health, education, social, leisure and employment; none of which is covered by the HIF.
In our response we have laid out a number of questions which we believe need answering for both us as elected representatives but more importantly for the communities on the Hoo Peninsula who will be impacted by the proposals in the consultation.
We look forward to the final outcomes being agreed and will continue to play our part in the processes which we have engaged in positively and constructively to date.
Thank you for taking our views into consideration and we will encourage all our members to respond through the online consultation as well.