5.3

We all know what Tunbridge and Maidstone wish to do on the borders of Medway. Is these councils going to also pay to improve Medway hospital and supply transport and schools to the area?

The if it is not fit for purpose we should openly and clearly oppose it and refuse to use it. If we know it is wrong it is wrong to use it to destroy our natural resources. We should lead the way in fighting it and getting a system in place that is attuned to local knowledge and needs.

Can you imagine 28.500 more families in Medway. Our gridlocked roads will be impassable, nobody will ever get a doctor's appt. or a bed in a hospital. The children won't be able to go to school and nobody will ever be able to enjoy themselves as everything will be full up immediately, either with the elite few or those on benefits. The hardworking low paid people (who aren't entitled to anything) will be shut out again.
When will the point of small our country is - and how overpopulated ever be taken into account? I always thought the world would advance, not sink back into struggling to survive.

This is of course, absolutely undeliverable in the geography of Medway without riding roughshod over all of the greenspace and healthy living agenda.
It is a pint pot and no matter how much you soft soap the public, it will not take a quart.

While it is noted that housing is required, Chatham Docks is not the place for this and has already lost around 1/3 of it's land 10 years ago to housing developers. Please note that within this 10 year period there has been less than 800 units built, just 80 per year as average. The ongoing success of Chatham Docks as an industrial port is critical to ensure jobs are maintained.

The lie of the land, the capacity to improve current infrastructure and the fact that Medway is already an area with a high number of people already struggling needs taking into account before any more building gets underway.
Medway police are underfunded and low level crime is rife, especially antisocial behaviour and burglaries.
These things need tackling first.

There needs to be an understanding of what any new targets may look like in the event that we have a Labour Government. I STRONGLY oppose Medway Council to stand up for Medway and object to this figures which DO NOT reflect the local need for Medway. It is "our" local plan and it should reflect what we need and want not what the volume house builders or central governement are pushing.

And in 50 years Medway will be full and healthcare and education completely disfunctional - what then? The time to push back is now before it’s really too late.

Because developers don't want to spend money on infrastructure! If Medway is serious about fulfilling these ridiculous housing targets why on earth did it withdraw its funding application for the Hoo Peninsula? That would have improved infrastructure and enabled people moving to a remote part of Medway access to public transport and subsequently been a viable option for developers

We need more housing, its a fact that we cannot ignore, but we can ignore short term, narrow minded, manufactured anger at house building which is perpetuated in tabloid newspapers.

Are you sure that using the Standard Method formula is the best way to assess need? Doesn't this method play into the hands of volume house builders which is not always going to be best for Medway?

It should also be open to change based on other trends/patterns that emerge. It seems there has been a drop in birth rates in Medway over the last couple of years. If this continues as a longer term trend then potentially the need for houses in the future may be less

As previously suggested.

CHR3 and was the subject of a Planning Inquiry in March 2023.
The Planning Inquiry Inspector identified elements of the landscape and visual effects that are key issues that would prevent the site being considered for development and refused the appeal.
The National Planning Framework accords the highest status of protection to AONB and policy BNE32 of Medway Local Plan 2003 requires that any development should conserve the beauty, wildlife and cultural heritage of the area.
I believe this site is one of “those aspects of Medway that we want to safeguard for the future” .

Medway politicians at Committee have been reactive to development over the years. The housing numbers have revealed this to be the case. Officers recommendations have been thwarted many times at Committee only for Planning Inspectors to overturn objections and have given costs against Medway. A mentoring regime for new Members is required. The Government will change like the wind. However local plan policies needed to get it right in the first instance. Young families need homes.

CHR3 and was the subject of a Planning Inquiry in March 2023. 
SilverHands Winery, Bush RoadCuxton
The Planning Inquiry Inspector identified elements of the landscape and visual effects that are key issues that would prevent the site being considered for development and refused the appeal.  
The National Planning Framework accords the highest status of protection to AONB and policy BNE32 of Medway Local Plan 2003 requires that any development should conserve the beauty, wildlife and cultural heritage of the area.
I believe this site is one of “those aspects of Medway that we want to safeguard for the future” .

The Standard Method is part of the Volume House Builders Agenda to have extensive areas of land allocated for Housing, thus reducing land values while they cherry-pick sites for their sub-standard, inappropriate, expensive developments.

This approach is starting the process from a negative starting point. It fails to reflect the need to plan positively and risks indicating an endemic aversion to increased housing that is so vital to addressing housing need. Whilst the standard method may indicate a greater number of homes being required than have been achieved in Medway over the last 30 years, caution is advised. Supply and delivery are not inherently linked to need. It is not considered useful to suggest an overall shortfall or failure in delivery should be used as a justification for this pattern to continue. Instead, it is suggested that this Local Plan process should focus at an early stage on how the Plan can help improve rates of delivery to ensure whatever final housing need is determined can be achieved with clear certainty, such as specifically referencing the latest local housing needs assessment. This would better reflect the points raised in 5.4, which do clearly acknowledge the housing crisis and issues already faced by existing residents.
Furthermore, it is not a national requirement to use the standard method. Instead it is expected to be used unless exceptional circumstances indicate an alternative should be used instead. This Regulation 18 consultation criticises the standard method but at no point indicates any exceptional circumstances to justify an alternative method, nor clarifies the content of any such alternative. Indeed, the Council’s 2021 Local Housing Needs Assessment appears to refer to the standard method and confirms ‘there was no evidence that an alternative approach should be considered for Medway’ (pg97). It is suggested that clarity on housing need should be a priority at an early stage in plan production to ensure the necessary tests are met through the process and a positive plan results that can be found sound and an asset to the community which it serves.

The authority IS NOT directed to use the Standard Method; this is a local choice as has frequently been made clear in writing by government ministers. However, it is accepted that proving a true local need requires far more time and effort. This authority should only put forward a plan which is right for Medway, not one which just ticks boxes.

We support the target of delivering around 28,500 homes over the plan period to 2040. The housing target should be achieved within the Borough to meet local development needs.

I think that the Local Plan should be written using the government's current housing targets to avoid delaying the plan. There should be a "buffer" amount of new housing provision above this amount in case the government changes its guidance and asks Medway to have more housing than the 1667 per annum currently planned.

We should strongly oppose these numbers. Not only are they not achievable in the current market, but they are over what is needed for the current population in the area and how that population is growing. Otherwise we are just overdeveloping the area unnecessarily, and negatively impacting the quality of life for existing and new residents.

BDW welcomes the unitary authority’s use of the ‘Standard Method’ in determining the scale of housing needed over the plan period. However, paragraph 5.4 of the consultation document notes that the Council has raised concerns about ‘Standard Methods’ use. The need for 28,500 dwellings in Medway, or 1,667 dwellings per annum (dpa) cannot be understated. While it is recognised that this is greatly higher than the rates of housebuilding previously seen over the last 30 years, past under delivery of housing have meant that this is entirely necessary to meet the demands of the future, drive up quantum as well as quality and support wider investment in services, businesses and
infrastructure.

As suggested we need to wait for the governments response to the consultation that include consideration of the "Standard Method Formula".

The consultation document refers to the Government’s standard methodology for housing need formula which identifies a need for 1,667 homes a year in Medway, or around 28,500 homes over the plan period to 2040. The National Planning Policy Framework (NPPF) requires the use of the standard method for calculating housing needs and Planning Practise Guidance (PPG) requires use of the Office of National Statistics (ONS) Household Growth Projection data from 2014. The government made it clear in its recent consultation on proposed changes to the NPPF that it will not be amending the standard methodology to utilise 2018 data. Medway should therefore continue to base its housing need calculations using the established methodology, until such time as any updated or amended methodology is published by the government.

CCE support the recognition in the consultation document that there is a housing crisis, particularly regarding affordability and there is an absolute need to provide the right homes in the right places to meet Medway’s growing needs. CCE support paragraph 5.11 and 5.12 of the document which align with the NPPF and recognise the need to (a) consider if there is capacity to provide homes to help meet Gravesham’s unmet needs and (b) adding a buffer to supply, equating to a need to plan for 29,000 homes over the plan period.

Planning to meet full housing needs will also provide growth benefits for existing communities in Medway. This is acknowledged within NPPF paragraph 79 which states that to support sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Medway must push back on such external political targets which are driven by the lobbying of volume developers rather than a firm understanding of local housing needs. I expected Medway council to have a firm understanding of our actual local needs and to deliver a framework which matches that need.

Commerical entities may then compete to meet that need, but should never be allowed to dictate they need.

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.

The National Planning Policy Framework is widely blamed for the Housing Crisis together with the Right to Buy policy which has destroyed the essential Council Housing social provision . 3,4 and 5 bedroom “Executive” Housing is irrelevant to people who have been driven into homelessness by the policies of the government.

Clearly there is far too great a number proposed and the standard methodology is flawed. It does not take local considerations into account. Some areas such as Ashford and Maidstone to talk locally, are easily able to take far larger numbers of housing. Medway not so. Let the local authorities, the developers and the local people all have a say but the flawed methodology depends on the starting point in time and various assumptions and does not seem to take nuances such as geography, congestion and ecological concerns into consideration

Medway needs to deliver this amount of housing to meet the needs of the future (the definition of sustainability!). Density around transport hubs!
The figures are achievable if town centre masterplans are created. There're many under utilised spaces. There are many surface carparks. Chatham dockside retail park- could be 100s of homes with the parking managed in MSCPs. Alternatively, look at Rainham which has multiple car dealerships on the highstreet.
These businesses should be on industrial parks in Medway. The sites can then be filled with 3-4 storey homes/ apartment blocks in the local vernacular.