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.

Paragraph 66 of the NPPF clearly sets out that 66. 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, the client advocates that the Council looks for a larger number of sites to ensure that there are enough sites to meet the housing requirement and include the buffer.