Future Hoo Consultation 2021 – Second Round

Response by Medway Labour and Cooperative Group

January 2022

1. Introduction

In our response to the first round of consultation on Future Hoo in 2021 we stated:

“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 went on to say that:

“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.”

The analysis of the first round of consultation on the HIF proposals published by the Council (HIF Email and Representations Analysis, August 2021), echoed our concerns with 227 respondents covering three common themes:

• Objections to the HIF proposals
• Concerns about overdevelopment
• Environmental Impacts

More specific comments of significance included pollution, concerns about Phase 1 of the road infrastructure, and the consultation process itself was brought into question.

Our concerns around the consultation process fall into two categories. Firstly, the problems of COVID meant that much of the consultation was and continues to be carried out online via Teams/Zoom meetings and online questionnaires. Secondly, and more significantly, there is a general feeling that we are being given no alternatives. The first round of consultation, “Hoo New Routes to Good Growth” document, did not offer any alternatives ideas or solutions to the infrastructure issues created by building so many houses on the peninsula. It came across as document spelling out what was going to happen and any consultation may result is some minor “tweaking” of the schemes being proposed.

The second round of consultation has included a much greater level of one-to-one engagement both online and in person and this is welcomed. The Labour and Cooperative Group believe it is vital that the views and opinions of all are heard even if this extends the consultation period.

This document makes it clear that the second round consultation is focused upon environmental and transport issues. All other infrastructure issues are to be dealt with separately. In our view this has led to a confused and piecemeal approach to the proposals with no indication as to how we can achieve sustainable development in environmental, economic or community terms. The key infrastructure requirements for such a huge population growth are linked directly to the emerging Local Plan which is now stalled.

 

The future of the community of Hoo and the surrounding settlements will be fundamentally changed forever by the scale of the proposed developments. Not only because of the huge increase in the local population but also by the need for more services at all levels, from education and health to transport and open space. There is every possibility that Hoo will become another extension to the conurbation of the Medway Towns. It is essential that the transport infrastructure delivered by the HIF matches the scale of change that is taking place.

It is our view that the HIF infrastructure proposals only go so far in addressing this fundamental change to the area. The Council should have a much more comprehensive plan for this area, linked directly to the emerging Local Plan. This comprehensive plan would be based upon the needs of the local community and not the imposed housing targets of the Government.

2. Strategic Environmental Management Scheme (SEMS)

In principle the Labour and Cooperative Group are happy with the SEMS. Whilst it does not compensate for the loss of greenfield land and the environmental impacts caused by the new housing estates, it does go some way to addressing the concerns around biodiversity and access to greenspace.

• Reference is made to the SEMS Vision Document which is currently in production. We are a little surprised that this has not already been produced. Can this be consulted on before publication?
• As outlined in the first-round HIF ‘Consultation Brochure’ the SEMS will be informed by the findings of the Cumulative Ecological Impact Assessment and the Natural Character Area study. These documents will inform the Local Plan and the road and rail proposals.

Presumably the SEMs cannot go ahead without these? Have these documents been published?

• We know that the RSPB have grave misgivings about the Local Plan proposals for the Hoo peninsula. What is the view of the RSPB on the SEMS proposals?
• The idea of a shared-use bridge across the A228 is welcomed. Is the cost of the feasibility study and the construction of the bridge itself within the existing HIF or will new money be needed? If new money is needed where will this come from?
• We welcome the new initiative to increase wildlife areas through landowner participation in a voluntary planting scheme by working with landowners, environmental charities and the local community. Is the cost of this within the existing HIF or will we need to find new money? If so, where will this new money come from?
• The land between Frindsbury and Hoo is currently not included within any proposals for new housing. Can we be reassured that it will be secured from development within the emerging Local Plan?

 

3. Rail Infrastructure

In general, we welcome the changes made based upon the first round of consultation.

There are some specific points we would like to make:

• Can we have reassurance that there will be appropriate EV charging at the station, including private cars, taxis and buses.
• We have concerns about access to the station from Cliffe, Cliffe Woods, Grain and Allhallows and surrounding villages, particularly, following the discounting of the station proposals at Cliffe and Church Road. How is this to be addressed to best serve the needs of the community?
• Are there any further details on the alternatives for the discounting of DC electrification provision? Does the rolling stock exist for this line or will it have to be built from scratch and how will this be paid for? The use of diesel would fly in the face of our climate change actions!
• We appreciate that the various options for providing a service are complex and restricted by cost. In the hope of further funding for rail becoming available the most flexible and future proofed options should be chosen at this stage. Ideally, however, we would want to see the reinstatement of the “curve” to Strood.
• Can we also have details on how the solutions on offer fit in with timetabling of services to London, Maidstone and the coast? It is clear that the service will be reliant upon platform capacity at other stations, such as Gravesend. Do we know if this is currently available, if not when and how will it be paid for?
• We welcome the use of alternatives to HGVs for the movement of materials for construction. However, can we be assured that all materials used in construction will be from sustainable sources and that the overall development of the rail infrastructure will be carbon neutral.

 

4. Road Infrastructure

The road schemes for the new housing estates are designed simply to try and relieve local pressure. They do not address the fundamental issue of how many more cars can we fit onto a network that is already over capacity. As the opening paragraph of this section of the consultation says, “there only being one road on and one road from Hoo”.  These “improvements” do not solve this basic problem and adding another 12,000+ cars to the situation will only make things a lot worse. To suggest otherwise is disingenuous.

Missing from all the road schemes is any mention of a dedicated electric bus network, feeding into Strood, relieving the volume of traffic coming down Four Elms Hill and providing travel to the local schools.

Since there is no rail or bus proposals for access to Strood it is safe to assume that the majority of trips will be by car. This will add to an already badly congested and polluted situation and the consultation fails to mention this. In addition, this huge influx of new traffic into Strood and the other areas of Medway will require parking. Has there been any thought given to this and where and how will it be provided?

The public rights of way improvements are welcomed but these will not address the issue of unsustainable levels of car numbers.

We also have grave concerns about the timescale for delivery. An additional year has already been added to the programme. How confident are we that the road schemes can be delivered by 2025? The most important phases are 5 and 6; will they be delivered first?

We also have the following comments on the road works:

Phase 2 – Alignment A results in the fragmentation and greater loss of habitat than Alignment B so we consider the latter more acceptable. However, it is unclear on Figure 24, why there is a need for a new roundabout. The text says this is to “facilitate a change in the road alignment.” Can we have a more detailed explanation as to why this roundabout is necessary.

In addition, Figure 23 shows a small junction branching off to the northeast of the proposed road. Can we have an explanation as to why this junction would be necessary if Alignment A were to go ahead.

Phase 4 – Ropers Lane Roundabout has an extra spur. Can we have an explanation as to why this additional spur on the roundabout is necessary.

Phase 5 – Four Elms Hill and it associated roundabout are the only main route to and from the new housing estates that are to be built around Hoo. This junction is already very busy and pollution levels here are extremely high. It is hoped that the proposals set out in this consultation are going to be sufficient to cope with the expected volumes of traffic moving through here daily over the coming decades.

The Labour and Cooperative Group is asking for three things in relation to this junction.

• Firstly, a detailed consultation meeting around traffic management for Four Elms Hill, the roundabout, Wulfere Way and the Sans Pareil Roundabout.
• Secondly, the setting up of a comprehensive air pollution monitoring system, including gaseous pollutants and particulates, as soon as possible, along the Four Elms Hill, the four Elms Hill Roundabout, Wulfere Way and the Sans Pareil Roundabout. The aim of this would be to provide clear baseline data on how the air quality of this area of Medway will be affected by traffic levels going forward, especially in relation to the Maritime Academy at the Sans Pareil Roundabout.
• Thirdly, a dedicated electric bus lane, linking with any proposed bus lanes in the new housing estates, running down Four Elms Hill and ending at the Maritime Academy at the Sans Pareil Roundabout.

Phase 6 – The Sans Pareil Roundabout proposals are of real concern. On close inspection the number of lanes leading into the roundabout total 19. On the west side of the roundabout there are in fact 11 lanes leading in at one point.

The complexity of this junction was increased by the approval of the new Maritime Academy, but even before then it was always going to be problematic. Traffic in and out of Strood is heavily congested on a regular basis and the increased traffic volumes caused by the new housing estates will only add to this problem, especially as there is no dedicated bus lane and no rail link into Strood from Sharnell Street.

As requested above there is a need for a separate meeting to discuss the traffic on this junction, and the associated Four Elms Hill Roundabout, Wulfere Way and Four Elms Hill. As part of the consultation on the HIF we need to understand how the increased traffic around this area will be managed in a sustainable way.

This meeting will also have to address the issues around access to the school and the timing of works in relation to the opening of the school. In particular, how are pedestrians, especially school children, supposed to cope with such a complex junction?

There are many conflicting interests around these junctions and it is not clear who has overall responsibility and how these conflicts will be resolved

Construction

The consultation document makes specific reference to the construction of the road infrastructure. No mention is made as to how this will be made carbon neutral.

Environmental impact

The consultation document states that:

“Environmental Impact Assessments (EIA), resulting in Environmental Statements, will be undertaken for the rail works and the highways works to assess the potential for significant environmental impacts to arise as a result of the proposed improvements.”

In respect of these it is surprising that this work has not already begun. The Habitats Regulations Assessments will take a considerable amount of time, especially as they will include monitoring of impacts on overwintering birds. Bearing in mind the very tight timetable for the implementation of the HIF when can we expect the HRA and the EIAs to begin?

A more fundamental issue is the mitigation of environmental impacts of the road works and the ongoing housing developments. The consultation document states that:

“Where the potential for significant environmental impacts is identified through the EIA and HRA processes, the assessments will identify measures to avoid or mitigate those impacts.”

The HIF proposals, the consequent new housing estates and huge population increase in the area do constitute significant environmental impacts. The SEMS proposals will mitigate these impacts to a certain extent but there is no mention of:

• The Government’s or Medway Council’s Climate Change Action Plans.
• The mitigation of air pollution
• The need to make the HIF proposals at both construction and implementation stages carbon neutral.

When can we see the full assessment of the mitigation of environmental impacts of the road and rail schemes?

5. Sustainability Appraisal

Following on from our comments regarding the environmental impacts of the HIF proposals we are surprised that there is no mention of an overall Sustainability Appraisal. This would incorporate the social/community, economic and environmental impacts of the HIF proposals and measures for mitigation and compensation, especially in relation to the impacts on the local communities that will be affected.

Normally we could rely upon the Local Plan to deliver sustainability appraisals and assessments, but as we know this seriously stalled. Without these in place the HIF proposals are going ahead in a vacuum, without us having a clear understanding of the consequences for the exiting communities in the Hoo area. A Sustainability Appraisal for the HIF proposals would give clarity to this problem and would also feed back to the Local Plan once the problems with this have been resolved.

As part of any Sustainability Appraisal key issues, such as the housing waiting list, access to affordable housing, preventing the development of poor quality rented housing, need to be included. For example, the inherent problems of private landlords buying up housing on a large scale and limiting access to local people, as has happened in Ashford, must be avoided.

In addition, this Sustainability Appraisal would incorporate the concept of “20 minute” communities. Where the design of the housing estates would build in the ability for local people to access all their immediate services, such as schools, shops and health centres, within a twenty-minute round trip walk from their home. This principle lies at the heart of most current thinking around planning and development.

Mention has been made that this Sustainability Appraisal would be carried out alongside the emerging Local Plan. However, the Local Plan is now significantly behind schedule and the deadline for the HIF proposals is now fixed for 2025 and is unlikely to be extended any further. Having a Sustainability Appraisal in place is essential to the future of the HIF proposals and we feel needs to be done as a matter of urgency.

6. Conclusions and Questions

General Points

As explained in our introductory statement above the HIF proposals do not, and are not expected to, address the full infrastructure requirements for the new developments around Hoo. These should be seen in the wider context of the emerging Local Plan. However, the Local Plan is not able to deliver this for the foreseeable future, and certainly not in line with the very tight timescale of the HIF proposal up to 2025.

The Labour and Cooperative Group appreciate the efforts made to make this second round of consultation more inclusive. However, the continuing problems with COVID and the complexity of the issues involved means that there has not been sufficient time for the whole community to respond as they would wish. In this respect we would propose that the consultation period is extended for an additional month and half to the end of February 2022.

As we all realise, if the full scale of these developments goes ahead with around 12,000 new homes the population increase for the Hoo area is going to be in excess of 25,000 people. To suggest that £170m for infrastructure projects on this scale is sufficient is not being realistic. We should be planning for much greater and more fundamental infrastructure projects that cover all the needs of the community.

There is an urgent need for a Sustainability Appraisal for the Hoo developments at the earliest opportunity. This should be coupled with a strategy for the implementation of the HIF proposals that takes into consideration all the wider needs of the local community and how these are to be delivered.

Proposal 1: Extend the HIF consultation period to February 28^th 2022.

Proposal 2: Carry out a Sustainability Appraisal for the Hoo developments and produce a strategic document covering the delivery of all infrastructure requirements, not just those covered by the HIF, for the existing and new communities. This appraisal will include the delivery of the principle of “twenty-minute” communities for new developments.

Specific Questions

SEMS

• Have the Cumulative Ecological Impact Assessment and the Natural Character Area study documents been published?
• What is the view of the RSPB on the SEMS proposals?
• Reference is made to the SEMS Vision Document. Can this be consulted on before publication?
• How are the costs for the new shared bridge on the A228 being met?
• How are the proposals for landowner participation to increase wildlife areas being met?
• Will the land between Frindsbury and Hoo be protected from development?

Rail proposals

1. Sharnell Street Station

• Will there be sufficient EV charging points for cars, taxis and electric buses?
• What access arrangements are being made for the communities around Cliffe, Grain and Allhallows. For example, will there be an electric bus service that fits into the rail timetable?

 

2. DC Electrification

• Can we have reassurance that the trains provided will not run on diesel.

 

3. The “Curve”

• Can we have reassurance that Medway Council will actively pursue the provision of the “curve” and link to Strood station as soon as possible.

 

4. Timetabling of services

• Can we have details on how the solutions on offer fit in with timetabling of services to London, Maidstone and the coast?

 

5. Construction and operation

• Can we be assured that all materials used in construction will be from sustainable sources and that the overall development of the rail infrastructure will be carbon neutral.
• Bearing in mind the service is reliant on capacity at stations outside Medway, do we know if this is currently available, if not when and how will it be paid for?
• How confident are we that the rail infrastructure will be delivered by 2025?

Road Proposals

1. Electric Buses

• Can we have details of any proposals for an Electric Bus Service operating between the new housing estates and Strood. If this is not being proposed can we have an explanation as to why.

 

2. Phased Road Works

• Phase 2 – Why is there a need for a roundabout in the Alignment B proposals? Why is there a need for a junction leading northeast from the road in Alignment A?
• Phase 4 – What is the purpose of the additional spur from the roundabout at Ropers Lane?
• Phase 5 and 6 – Can we have a special consultation meeting to discuss the proposals for Four Elms Hill, Four Elms Hill Roundabout, Wulfere Way and the Sans Pareil Roundabout? Issues for discussion include: how are pedestrians, especially school children, supposed to cope with such a complex junction?

 

3. General road issues

• Can we see the setting up of a comprehensive air pollution monitoring system between Four Elms Hill and the new Maritime Academy.
• What are the arrangements for a bus service of any kind between the new housing estates and the Maritime Academy?
• Bearing in mind the very tight timetable for the implementation of the HIF when can we expect the Habitats Regulations Assessment to begin?
• When can we see the full assessment of the mitigation of environmental impacts of the road schemes?
• Has there been any thought given to additional parking in Strood and other parts of Medway for the increased numbers of cars? Where and how will this be provided?
• How confident are we that the road schemes can be delivered by 2025?
• The most important phases are 5 and 6; will they be delivered first?

Thank you for giving us the Labour and Cooperative Group the opportunity to comment on the HIF proposals.

We look forward to your response.