Representation by The Church Commissioners for England (The Church Commissioners for England )
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
The Church Commissioners for England (CCE) manage the historic property assets of the Church of England. Their Strategic Land Portfolio currently comprises circa 6,000 acres, with sites located nationwide. CCE seeks to promote their landholding, where suitable, for development through the Local Plan process and work closely with Local Planning Authorities to demonstrate site deliverability. Medway Council is preparing a new Local Plan. Work on the Local Plan to date has indicated that the spatial strategy will include large scale development on the Hoo Peninsula, having the potential to grow by circa 10,000 new homes over the next thirty years to provide a new rural town. The proposals were most recently published in the Council’s Hoo Development Framework (November 2022). CCE has significant landholdings on the Hoo Peninsula including land to the east of Hoo St Werburgh (east and west of Ropers Lane), and Kingsnorth, to facilitate c. 3,500 homes, employment land and associated supporting infrastructure. In order to facilitate growth on the Hoo Peninsula, Medway Council has secured £170m from the Government’s Housing Infrastructure Fund to invest in improving transport and environmental infrastructure on the Hoo Peninsula. From an initial review of the documentation associated with the Lower Thames Crossing planning application it would appear that the housing and other development proposed for the Hoo Peninsula has not been considered as part of the assessment. Document ‘5.4.4.10 Statement of Common Ground between (1) National Highways and (2) Medway Council’ Section 2.17 notes that the Planning Inspectorate’s Scoping Opinion (2017) required the Environmental Statement to consider Medway Council’s Emerging Local Plan. The ‘Traffic Modelling Update’ prepared by National Highways (dated 2020) states that only growth associated with planning consents have been considered as part of the modelling and no speculative sites have been included within the assessment. Subsequently a high growth scenario was undertaken by National Highways and reported within the ‘Transport Forecasting Package (Appendix C of the Combined Modelling and Appraisal Report (ComMA).’ This latest iteration of modelling does not appear to include any consideration of development at the Hoo Peninsula. It is acknowledged due to its current planning status (draft allocation) that the proposed development at the Hoo Peninsula does not necessitate inclusion in the modelling. However, given the scale of the Council’s plans in this location, and that this is supported by c.170m of government HIF funding, CCE consider that a sensitivity test should be undertaken to ensure that the potential for Medway to deliver housing stock and associated development at the Hoo Peninsula is not impacted by the Lower Thames Crossing proposals. This is particularly important given the changes that are proposed as part of the Lower Thames Crossing to M2 J1. Given the above information, CCE question the soundness of the modelling undertaken by National Highways and consider it ought to include greater sensitivity testing. CCE wishes to take part in the Examination process and would like to be included in any future consultations.