Paragraph 68 of the National Planning Policy Framework (‘NPPF’) requires for plan-making, local planning authorities (‘LPAs’) should identify and update a supply of specific deliverable sites sufficient to provide 5 years-worth of housing against their housing requirements with an additional buffer of 20% where there has been a record of persistent under delivery of. Furthermore, specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan need to be clearly set-out.
The site owner of site HHH19 has confirmed that the site continues to remain available, developable and deliverable. Subject to its inclusion in the Local Plan, the site could become available in the first 5 years of the Local Plan period.
The Glossary of the NPPF defines deliverable and developable as follows:
“Deliverable: To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years. In particular:
a) sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).
b) where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within five years”.
“Developable: To be considered developable, sites should be in a suitable location for housing development with a reasonable prospect that they will be available and could be viably developed at the point envisaged”.

Respectfully, the Council’s conclusion that the allocation of HHH19 could lead coalescence between settlements, and which forms a reason for not including it, is misguided. Site HHH19 is located between brownfield sites, that do not form individual settlements and in reality, the allocation of HHH19 as an infill plot has the benefit of enhancing the existing settlement form by better connecting residential and employment uses; whilst also offering biodiversity improvement on the site,
The conclusion drawn by the Council that the site is beyond walking distance to public transport is not agreed with. Indeed, the preapplication response letter from the head of planning and one of his senior planners dated 21 April 2021 identified “This area of land would be an ideal location for such a development given its proximity to the transport network and vehicular connectivity.”; going on to say: “it would be beneficial to now look at a footpath link from Bells Lane along to the proposed business hub site and the nursery.”; whilst a footbridge adjoining the site could also offer potential improved connectivity.
The sustainability appraisal identities that the site has a negative benefit in terms of leisure facilities. However, this conclusion it not considered to be appropriate given that site HHH19 immediately adjoins the Deansgate Leisure centre which is located immediately to the west.

The site proposed for development on Land at Flanders Farm (site HHH19), having already been supported in the Land Allocations Assessments (LAA) document, as a potential site allocation in the Future Medway Local Plan 2040 should be allocated in the forthcoming plan. If not considered to be a residentially led scheme over the whole site, the Council should consider the scheme to be employment led, with the addition on residential development.