It is understood that Medway Council are still establishing final 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 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.

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 cautious approach, by allocating more sites should be taken.

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.

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”;

On this basis, these representations advocate that the Council looks for a larger number of sites to ensure that there are enough sites to meet the housing requirement, including the buffer. The use of smaller sites to meet this demand should be a desired approach, with Site AS15 (Land at Middle Stoke) being an opportunity to assist with the delivery of this.

Further, Paragraph 66 of the NPPF clearly sets out Strategic policy-making authorities should establish a ‘housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period’.

On this basis, these representations also advocate that the Council seeks to provide a larger number of sites to ensure that there are enough sites to meet the housing requirement and include the buffer. All three sites referenced in these representations can assist with ensuring that housing delivery is met.