7.1. The level of housing need required for the Medway area identifies a requirement for 1,667 homes a year in Medway, which provides a total figure of around 28,500 homes to be delivered before the end of 2040. This figure could further be increased, as it is identified in paragraph 5.11 of the consultation that Medway Council are currently considering a request from Gravesham Borough Council to increase capacity by 2000 homes to help meet the housing need of their district.
7.2. In March 2023 Gravesham Borough Council produced its Five Year Housing Land Supply Statement, covering the period 2022-2027. This document sets out that Gravesham only has 2.9 years of deliverable housing supply. In accordance with the Gravesham Local Development Scheme (January 2023) the new Local Plan for Gravesham is not expected until December 2024, and thus, the Borough’s Housing Land Supply (HLS) is not likely to improve in the near future. The high likelihood of Medway having to absorb some of this housing need should not be ignored in the early stages of Local Plan creation for Medway.
7.3. It is understood that Medway Council are still establishing final housing need numbers, due to the Council raising concerns with the Government derived figures, and the basis and calculations on which final numbers are determined. However, it is made clear in paragraph 5.13 of the consultation that the Council will look to find potential site allocations enough to provide for 19,000 dwelling units, the additional 7500 sites being provided through extant supply.
7.4. We wish to raise an objection to this approach advocated by paragraph 5.13 because the acknowledged uncertainty in the number of housing numbers required to be delivered, means that a more proactive approach, by allocating more sites, should be taken.
7.5. The Council should be looking at allocating more sites, to meet a potential increased capacity, in the Local Plan to ensure that there is an appropriate buffer should there be an additional requirement for housing in the Medway area, rather than relying heavily on delivering the target number of 28,500 homes.
7.6. In accordance with paragraph 69 of the NPPF, it is identified that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. It sets out that ‘to promote the development of a good mix of sites local planning authorities should:
“a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare”;
7.7. The site, ‘The Depot’, Ratcliffe Highway, Hoo St Werburgh, Rochester, Medway ME3 8QB, could provide a reasonable alternative and an additional site on the outskirts of Hoo for additional housing development. On this basis, the site should be included for assessment in the Council’s Land Availability Assessment (LAA).