Chapter 5 – Developing a Spatial Strategy

‘Development needs’
15. Catesby Estates agrees that a ‘Local Plan should be positively prepared for sustainable development. It should not be used to stop development that is needed for our growing and changing communities’ (paragraph 5.2). Alongside this Catesby Estates supports the Council’s growth ambitions and advocates an unconstrained and holistic view of development across Medway, in order to achieve this.

16. The LP2040 correctly identifies that the Government directs Local Planning Authorities to use its Standard Method when determining the scale of housing required over the plan period. As the LP2040 sets out the standard method identifies a minimum need of 28,500 homes over the plan period to 2040 (1,667 dpa). The LP2040 further states that this is higher than the rates of housing building seen in Medway for 30 years (paragraph 5.3). Catesby Estates is clear that Government policy should be followed when preparing a Local Plan to ensure it is positively prepared, compliant with national policy and thus able to be found sound. At the time of writing it remains that the Standard Method is the starting point for calculating the minimum housing need and it is this calculation that the Council should therefore use when preparing the Plan.

17. Moreover, as the Planning Practice Guidance (PPG) refers, unconstrained housing need could exceed the standard method minimum:

‘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…
…Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;…’ (our emphasis)
(Paragraph: 010 Reference ID: 2a-010-20201216)

18. Catesby Estates therefore considers it counter-productive, given the Council’s own vision and strategic objectives which seek to transform the economic performance and prosperity of Medway, to immediately limit housing needs based on past trends – clearly the future of Medway cannot be assessed on past trends given the ambition of the Council and LP2040 into the future: to exceed the past delivery and economic performance of Medway.

19. Whilst Catesby Estates recognises the concerns of the Council regarding existing infrastructure and future capacities, the preparation of a Local Plan is the correct tool with which to address these issues. It is vital therefore that the LP2040 plans for the correct level of development, in particular housing, so the correct level of supporting infrastructure can be planned alongside.

20. Notwithstanding the above comments, Catesby Estates also notes the request from Gravesham Borough Council to provide an additional 2,000 homes to help it meets its needs. This further increases the requirement within Medway and highlights the need to plan for housing that can be delivered at all stages of the plan period.

21. Paragraph 5.12 of the LP2040 states the housing needs for Medway over the plan period pf 2022-2040 to be 28,339. Paragraph 5.3 and 5.11 subsequently note the need to be 28,500. Furthermore, paragraph 5.3 also refers to the need as 1,667 homes a year, which when taken across the 18 year plan period (2022-2040), results in a total need of 30,006 homes. With three different figures in the LP2040, it is imperative the Council are clear on the housing needs of Medway and if it has applied any reductions to the standard method figure. Notably however, a buffer will need to be applied to the correct figure as the Council confirms at paragraph 5.12 and Gravesham’s unmet need will also need to be accounted for. Catesby Estates therefore considers that the plan period need for Medway will be closer to 34,000 homes (1,888 dpa).

22. At Figure 2 of the LP2040 the Council sets out how many sites are considered to be in the pipeline (with planning permission), those it expects to come forward as windfall sites and thus the remainder it will need to allocate within the LP2040 in order to meet its needs.

23. Regarding pipeline sites, Catesby Estates notes this figure to be 7,583, which is 27% of the need across the plan period (using the Council’s figure of 28,500). This is considered significant and the Council should assess these sites to ensure they are deliverable before relying on them in a new Plan. Any planning permissions which have lapsed should indicate that a Site is not coming forward in the short term.

24. Regarding windfall sites, Catesby Estates notes this figure to be 3,000, which is 10.5% of the need across the plan period (using the Council’s figure of 28,500). The National Planning Policy Framework 2023 (NPPF) is clear that where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply (Paragraph 71). Catesby Estates therefore requests that the Council provide robust evidence that demonstrates 3,000 homes are capable of being delivered via windfall sites across the plan period.

25. Regarding the number of homes needing to be allocated within the LP2040, it is noted that this is likely to rise following the correct calculation of need across the plan period. Nevertheless, Catesby Estates suggests the Council should consider allocating more sites within the LP2040 in order to require less unplanned development to meet its needs across the plan period.

26. Paragraph 5.15 of the LP2040 notes that the Land Availability Assessment (LAA) has revealed land with a potential capacity for circa 38,200. Catesby Estates suggests that sites contained within the LAA are therefore assessed robustly and objectively to enable the Council to plan and allocate sites for the majority of its housing need.

27. Table 1 of the LP2040 demonstrates the potential housing capacity for each of the category areas, according to the LAA. It shows that a potential capacity of 11,151 homes exists within urban areas, which is considered a high level of growth. Catesby Estates considers that caution should be applied when considering whether this this level of urban growth is feasible, and whether it will deliver the right choice of homes. Complexities exist with urban redevelopment that often impact the speed and viability of delivery. In addition, such development also delivers a greater proportion of smaller sized units and the Council need to consider this carefully against the aim of the LP2040 and needs of the existing a future population of Medway.

28. Table 1 of the LP2040 also confirms that circa 40% of the potential sites fall within the rural development areas of Medway. This reflects a need for the Council to consider its growth locations and corridors holistically and not miss opportunities to allocate sites that would contribute to the vision for Medway, and provide links to different areas. The expansion of existing settlements such as Allhallows can deliver family homes with policy compliant affordable housing. Any environmental impacts can be mitigated through careful layout and design that ensures future development respects and enhances its surrounding context.

29. Paragraph 5.36 of the LP2040 discusses sites with the potential for development in the rural areas and focusses heavily on those sites put forward on the Hoo Peninsula. The LP2040 does not discuss other rural areas where sites have been put forward such as Allhallows – at this stage the LP2040 should be considering all options and assessing them against the vision for Medway. Whilst it is noted that the Hoo Peninsula can accommodate some new development, it is a notable constraint that HIF funding has been removed, and the Council comments at paragraph 5.45 that the capacity of infrastructure to support major growth on the Hoo Peninsula is a strategic consideration.

30. Notwithstanding, Catesby Estates considers that Allhallows forms part of the wider area which the Council has spent much time developing proposals for and therefore complements the development prospects on the Hoo Peninsula when viewed holistically, particularly those related to industry. Indeed, Catesby Estates recognises that such urban growth may take a long time to come to fruition, as seen elsewhere in the country with strategic development locations. Consequently, Allhallows represents an opportunity for early delivery without the need for significant infrastructure, within a wider area which has long term growth potential, helping achieve the desired long term aim of increased prosperity in the region, alongside maintaining an annual supply of homes.