This approach is starting the process from a negative starting point. It fails to reflect the need to plan positively and risks indicating an endemic aversion to increased housing that is so vital to addressing housing need. Whilst the standard method may indicate a greater number of homes being required than have been achieved in Medway over the last 30 years, caution is advised. Supply and delivery are not inherently linked to need. It is not considered useful to suggest an overall shortfall or failure in delivery should be used as a justification for this pattern to continue. Instead, it is suggested that this Local Plan process should focus at an early stage on how the Plan can help improve rates of delivery to ensure whatever final housing need is determined can be achieved with clear certainty, such as specifically referencing the latest local housing needs assessment. This would better reflect the points raised in 5.4, which do clearly acknowledge the housing crisis and issues already faced by existing residents.
Furthermore, it is not a national requirement to use the standard method. Instead it is expected to be used unless exceptional circumstances indicate an alternative should be used instead. This Regulation 18 consultation criticises the standard method but at no point indicates any exceptional circumstances to justify an alternative method, nor clarifies the content of any such alternative. Indeed, the Council’s 2021 Local Housing Needs Assessment appears to refer to the standard method and confirms ‘there was no evidence that an alternative approach should be considered for Medway’ (pg97). It is suggested that clarity on housing need should be a priority at an early stage in plan production to ensure the necessary tests are met through the process and a positive plan results that can be found sound and an asset to the community which it serves.