Medway Local Plan (Regulation 18, 2023)

We are writing on behalf of our client, Mr Richard Castle and family, of Dagenham Farm, Ratcliffe Highway, St Mary Hoo, Rochester, Kent, ME3 8RN in respect of the Medway Council Local Plan Regulation 18 Consultation Report – Setting the Direction for Medway 2040.

Mr Castle and family remain committed to the promotion of the sites at Grain Road Middle & Lower Stoke for residential development in the future Local Plan. This representation is made in this context and demonstrates a justification for designation of these sites as part of a sustainable rural expansion to meaningfully contribute to the Council’s substantial housing requirements within the District.

These sites have been promoted for housing development through the Medway Council Call for Sites 2022 in February 2023. Following the publication of the Medway Land Availability Assessment (LAA) on the 16th October 2023, the three sites at Middle & Lower Stoke (See Figure 1) have been given the reference numbers as follows:
• AS15 - Land at Middle Stoke, Grain Road, Rochester – 0.86 hectares
• AS14 – Land to the North of the A228, Grain Road, Rochester – 2.71 hectares
• AS17 – Land to the East of the A228, Grain Road, Rochester – 7.82 hectares

During the Stage 1: Identification of Sites and Initial Survey, the assessment of these sites concludes that they should all subsequently proceed to Stage 2, where the Council will carry out a more detailed assessment. The LAA confirms that work is underway on Stage 2, involving estimating the development potential and an assessment of the suitability, availability, and achievability of each site, before considering whether constraints are capable of being mitigated.

These representations confirm that the three sites could be delivered in the first 5 years of the Local Plan period, and are available now.

The production of the Medway Local Plan has involved a number of key stages. With three stages already having been completed, the ‘issues and options’ (Regulation 18) completed in 2016, the ‘development options’ (Regulation 18) completed in 2017, and the ‘development strategy’ (Regulation 18) completed in 2018. This consultation, ‘setting the direction for Medway 2040’ (Regulation 18) consultation, marks the fourth consultation phase and the final regulation 18 consultation before the publishing of the Regulation 19 draft plan.

The current consultation considers why the Council needs to plan for Medway's growth. It refers to aspects of Medway that need to be safeguarded for the future, such as beautiful landscapes and historic buildings. The consultation document also outlines potential options for building new homes, workplaces and services, such as schools and surgeries.

It is understood that this consultation does not detail policies or identify those sites preferred by the Council for new development. However, this representation builds on previous submissions by Mr Richard Castle and family, who continue to promote the three sites at Middle and Lower Stoke for residential development, in the context of the current open consultation.
Context

This representation seeks to continue the promotion of the three sites at Middle and Lower Stoke, Grain Road, Rochester, which have previously been promoted for residential development through the Call for Sites 2022 undertaken by Medway Council, and which have now been through an initial Stage 1 Assessment (MC Ref: AS14, AS15 & AS17) as part of the Land Availability Assessment (October 2023).

Prior to the Call for Sites 2022, there has been some previous promotion, as summarised below, albeit it is noted that Sites AS14 & AS17 have not been previously promoted through any earlier representations.
AS15 – Land at Middle Stoke, Grain Road, Rochester
This site was promoted through representations made in respect of the Medway Strategic Land Availability Assessment (SHLAA) 2017 under site reference 0794 and in
response to the subsequent Medway Local Plan 2012-2035 Development Options Consultation.

Most recently, site AS15 has been subject to an outline application for up to 9 dwellinghouses as part of application MC/23/0106. On 27 September the Committee voted for a resolution to approve the scheme, following the Council’s recommendation to approve subject to clarification from HSE. Such clarification has at the time of writing been received by HSE and the principle of residential development on site AS15 is considered acceptable. Respectfully, this position should be carried forward by the Council in terms of site allocation; albeit, it is accepted that the development is likely to come forward prior to any approval of a new Local Plan.

It is supported that during this Regulation 18 consultation that these three sites on land at Middle & Lower Stoke are now included as part of the defined area being promoted by Medway Council as Rural Development Sites, as shown on Map 3 within the Regulation 18 – Setting the Direction for Medway 2040 (September 2023) consultation document a having potential for providing capacity for 14,736 homes.

This representation confirms that the location of the sites on the edge of an existing settlement are considered to be sufficiently sustainable and suitable for a mixture of small-scale residential development (AS15 – Land at Middle Stoke) and for high-quality, landscape-led, low density residential development (AS14 & AS17 – Land to the North and Land to the East of Grain Road). Site AS14, by virtue of its location, could also be developed, not only in isolation, but more strategically with neighbouring sites to the north, as also being assessed through the LAA.

The NPPF (paragraph 20), sets out that strategic policies should ‘set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for [amongst others]:
a) housing (including affordable housing), employment, retail, leisure and other commercial development’;

Furthermore, the National Planning Policy Framework (‘NPPF’) requires that in order to boost housing supply, local planning authorities (‘LPAs’) should identify 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 housing.

The consultation report highlights at paragraph 5.4 that “It has to be recognised 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 and the requirements for those desperately needing a good quality home”. It goes on to acknowledge that many existing residents are living in over-crowded and / or sub-standard housing conditions.

It is important that the protection of the intrinsic character and qualities of a site or an area are considered, but these qualities can be protected when new housing development is delivered, through good design and by improving the sustainable networks and access to places and services. Rather than seen as negative, new housing development should be seen as an opportunity to improve the area for the current and future residents delivering the types and quantity of homes that are desperately needed. On this basis, respectfully, reference to ‘housing delivery’ should be made in the vision.

The NPPF sets out in paragraph 22 that it is important that ‘where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’.

It is submitted that the residential development of these three sites at Middle & Lower Stoke would be able to contribute positively to the existing elements of the vision for Medway, but would also be able to deliver important housing numbers early on in the Local Plan period. The sites are all available, and their development considered to be achievable.

Paragraph 119 of the NPPF sets out that ‘planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions’.

It is set out in the current consultation that “The role of the Local Plan is to plan positively for the development and infrastructure that the area needs, whilst conserving and enhancing the natural, built and historic environment”.

In order to deliver the Local Plan, it is proposing that the plan is set around strategic objectives. “The objectives will feed into the wording of policies and how sites and different locations are assessed for potential development. The objectives are presented around broad themes for the environment, communities, economy, and investment in infrastructure and design that is fit for the future”.

This representation supports the use of objectives to deliver the strategic aims of the plan, but wishes to raise the following comments regarding the individual objectives:

Objective: Prepared for a sustainable and green future
The objective to support action against climate change and a sustainable future for Medway is supported. This actively meets the aspirations of paragraph 153 of the NPPF which sets out that ‘Plans should take a proactive approach to mitigating and adapting to climate change’.

This representation promotes the delivery of sites in the rural area to help deliver 14,736 homes, amongst others, as a way that could deliver a sustainable and green future for Medway.

Paragraph 5.41 of the Regulation 18 consultation sets out that “large scale development around Hoo St Werburgh and neighbouring villages could provide for planning growth, where new housing is supported by new and improved services and infrastructure. Such development could also help to meet the Council’s ambitions for greener growth, with higher environmental standards in construction, communities better connected for walking and cycling, and within easy reach of local services”.

This representation supports the rural development option, amongst others, including the suburban expansion option, as a way of delivering a sustainable and green future for Medway. They will bring forward opportunities to support sustainable communities and incorporate future sustainable transport network. It will also enable the wider and strategic aim of supporting a green and blue framework for better connectivity for wildlife and improve the quality of lives for residents within.

Section 8 of the NPPF provides guidance on ‘Promoting Healthy and Safe Communities’. The proposed objective in the Medway Local Plan actively meets this objective and is therefore supported. But, respectfully it is considered that there is an omission in how the objective is drafted.

The intentions of the third bullet point, proposes to strengthen the role of Medway's "urban, neighbourhood and village centres…” This position is supported, but it is considered that ‘urban and rural extensions’ should also be included in this objective, especially, as the inclusion of urban and rural extensions are included within the proposed spatial strategy for delivering growth.

It is considered that the provision of such extensions will help to develop and strengthen transport networks and encourage for safe and sustainable travel as advocated elsewhere through the plan.

This representation supports the provision of quality and resilient development in Medway and we support the Council’s recognition that growth does not mean losing character of an area.

The second bullet point sets out that sustainable development should be directed to the “most suitable locations that can enhance Medway’s economic, social and environmental characteristics”. This stance is supported, as it acknowledges that development of both brownfield and greenfield sites can come forward to meet the housing requirement. The most suitable locations that can enhance Medway's economic, social and environmental characteristics should be utilised to deliver the housing requirement of the area.

An allocation for development of the sites at Middle & Lower Stoke would provide an opportunity to deliver this objective, in a development which meets the aspirations of sustainable development, directing development to the most suitable location

The level of housing need required for the Medway area identifies a requirement for 1,667 homes a year in Medway, which provides a total figure of around 28,500 homes to be delivered before the end of 2040. This figure could further be increased, as it is identified in paragraph 5.11 that Medway are currently considering a request from Gravesham Borough Council to increase capacity by 2000 homes to help meet the housing need of their district.

In March 2023 Gravesham Borough Council produced its Five Year Housing Land Supply Statement, covering the period 2022-2027. This document sets out that Gravesham only has 2.9 years of deliverable housing supply. In accordance with the Gravesham Local Development Scheme (January 2023) the new Local Plan for Gravesham is not expected until December 2024, and thus, the Borough’s Housing Land Supply (HLS) is not likely to improve in the near future. The high likelihood of Medway having to absorb some of this housing need should not be ignored in the early stages of Local Plan creation for Medway.

It is understood that Medway Council are still establishing final numbers, due to the Council raising concerns with the Government derived figures, and the basis and calculations on which final numbers are determined. However, it is made clear in paragraph 5.13 that the Council will look to find potential site allocations enough to provide for 19,000 dwelling units, the additional 7500 sites being provided through extant supply.

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.

In accordance with paragraph 69 of the NPPF, it is identified that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. It sets out that ‘to promote the development of a good mix of sites local planning authorities should:
“a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare”;

On this basis, these representations advocate that the Council looks for a larger number of sites to ensure that there are enough sites to meet the housing requirement, including the buffer. The use of smaller sites to meet this demand should be a desired approach, with Site AS15 (Land at Middle Stoke) being an opportunity to assist with the delivery of this.

Further, Paragraph 66 of the NPPF clearly sets out 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, these representations also advocate that the Council seeks to provide a larger number of sites to ensure that there are enough sites to meet the housing requirement and include the buffer. All three sites referenced in these representations can assist with ensuring that housing delivery is met.

It is noted in paragraph 5.15 that the LAA have identified land with the potential capacity for c 38,200 homes. These sites will be taken forward to the next stage of detailed site assessment. It is important that these sites are not discounted early-on before any final housing numbers are decided.

These representations support paragraph 5.40 of the consultation, which sets out that the Hoo Peninsula provides a significant opportunity for the “development for homes, jobs and services”.

This representation supports the approach to utilise The Housing Infrastructure Fund (HIF) programme to deliver improvements to transport and put measures in place to strengthen the local environment in the Hoo area.

In accordance with Paragraph 5.41 of the Local Plan, large scale development around Hoo St Werburgh and neighbouring villages could provide for planned growth, where new housing is supported by new and improved services and infrastructure. Such development could also help to meet the Council's ambitions for greener growth, with higher environmental standards in construction, communities better connected for walking and cycling, and within easy reach of local services.