Richborough supports the use of the Standard Method figure for calculating local housing need and forming the basis for determining the housing requirement for the Local Plan. For Medway this is 1,667 dwellings per annum and equates to 28,500 dwellings over the Plan Period to 2040.
The NPPF was updated in July 2018, February 2019, July 2021 and again in September 2023 in order to introduce several new concepts, one of which related to the calculation of housing need. Whilst the objective of significantly boosting the supply of homes was retained, the way of calculating housing need was to be altered with the introduction of the ‘standard method’. Although details of the specifics of the calculation are provided in the Planning Practice Guidance (PPG), paragraph 61 of the NPPF confirms that the standard method should comprise the ‘minimum’ figure, and states:
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.”
It is clear therefore that there are circumstances whereby a higher figure could be adopted over and above the standard method. The PPG provides further clarification on when it might be appropriate to plan for a higher housing need figure and states (Paragraph ID: 2a-010-20201216):
“The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.”
The guidance explains that circumstances where an uplift will be appropriate include, but are not limited to, where growth strategies are in place; strategic level infrastructure improvements are planned; and where an authority agrees to take on unmet need from neighbouring authorities.
It is important therefore to recognise that the need figure generated by the standard methodology should be considered as the minimum starting point in establishing a requirement for the purposes of plan production.
The calculation currently relies on household projections which focus solely on past growth trends and do not include a specific uplift to account for factors that could affect those trends in the future. Where it is likely that additional growth (above historic trends identified by household projections) will occur over the plan period, an appropriate uplift may be applied to produce a higher need figure that reflects the anticipated level of growth. Richborough consider that an uplift to the need figure may be required to allow for the additional employment generated as a result of projects highlighted elsewhere in the Consultation Document.
The third Strategic Objective included in the Consultation Document for example states that Medway Council wish to realise the economic and place-making opportunities associated with the cluster of universities and colleges in Medway and “Build on existing strengths and expertise, such as engineering, energy and creative industries, and raise the profile of key sectors, to attract and develop the jobs of the future”.
Further consideration should also be given to whether there may also be an uplift required to address the historic under delivery in affordable housing, which is covered elsewhere in these representations.
In regard to the timeframes for development plans, Paragraph 22 of the NPPF makes specific reference to this and states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure.”
According to the latest LDS approved by Medway in October 2022, adoption of the Plan is likely to occur in autumn 2025 (leaving limited time for a Main Modifications consultation), which is well into the monitoring year, 2025/2026.
This scenario wouldn’t allow for a full fifteen-year plan period at the point of adoption and the timetable is considered very optimistic in any case.
In light of this, Richborough is of the view that the Plan should look ahead to at least 2040/2041 in order to ensure that the Plan meets the requirements of NPPF paragraph 22.