Medway Local Plan (Regulation 18, 2023)

1. It is considered that the terminology used in this vision is potentially misleading. The use of the term ‘regional city’ has extremely loose connotations with no established academic definition. In essence, it could be read or interpreted differently by different readers and so fails to provide a clear intent or direction for Medway. It seems likely that Medway are seeking to become established as a ‘city region’, although such terms are typically more suited to academic circles. To ensure this Local Plan has a clear vision for all residents to understand, it is suggested that ambiguous terms should be avoided.

2. 'By 2040, Medway is responding and adapting to climate change, providing for more sustainable and resilient development'.
The above timescale is not considered suitable for a ‘vision’ as stating ‘by 2040'’ provides little if any ambition. Climate change is an immediate concern and so the Vision should be phrased accordingly. For instance, ‘Medway is responding and adapting to climate change to ensure more sustainable and resilient development during the plan period and beyond’. Using ‘by 2040’ effectively means the Council has almost 20 years to begin to ‘respond and adapt’ and so a simple phrasing change addresses this point.

3. 'All sectors and ages of the community can find decent places to live'
Given this is part of the ‘Vision’ for Medway, it is considered that the phrasing should be more aspirational. The supporting text of this consultation acknowledges the need for the Plan to ‘plan positively’, which is also set out in the NPPF. For instance, para 15 of the NPPF states ‘Succinct and up-to-date plans should provide a positive vision for the future of each area’. It is suggested that the Medway Vision should not utilise terms such as ‘decent’ but should seek to provide greater aspirations for the area such as offering residents ‘a choice of high quality homes that meet a wide range of needs’. The use of the word ‘find’ implies a degree of difficulty or need to search. A Vision should not expect or allow for such a challenge. Choice is fundamental and the supply and quality of homes should seek to achieve this goal.

This strategic objective includes the need ‘to provide for high quality energy efficient homes that meet the housing needs of Medway's communities’. It should be noted that this is somewhat premature and potentially misleading as currently written. Medway falls within the same Housing Market Area as Gravesham and it is understood that Medway may take on some of Gravesham’s need. That being the case, the objective would be clearer if it read as follows ‘to provide for high quality energy efficient homes that meet the housing needs of the community’.

This strategic objective includes the need ‘to deliver sustainable development, meeting the needs of Medway's communities’. It should be noted that this is somewhat premature and potentially misleading as currently written. Medway falls within the same Housing Market Area as Gravesham and it is understood that Medway may take on some of Gravesham’s need. That being the case, the objective would be clearer if it read as follows ‘to deliver sustainable development, meeting the needs of the community…’

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.

It would be useful to understand the approach or method Medway will be using to decide whether there is capacity to assist Gravesham with their housing need under the duty to cooperate. The earlier such information can be published in the public domain the better. This would aid transparency, promote early input and thus help minimise dispute on such matters at Examination.

As Gravesham has already put in a formal request for Medway to consider capacity to address shortfall, it would be prudent for this early stage in the plan process to more actively acknowledge this request. Gravesham has raised this issue at an early stage in the Medway plan making process and so there is clear opportunity to consider this as part of the early exploratory exercise rather than simply considering the needs of Medway. Open acknowledgement and thorough consideration of this request as an inherent part of the plan making exercise would better reflect the duty to cooperate.

The table supplied is considered a useful way to identify the potential housing capacity within the LAA. However, the description of ‘rural development’ is not considered particularly reflective of the sites available. It is suggested that this category would be better subdivided into ‘village expansion’ and ‘new settlements’. Given the nature of such sites and that the relevant factors to assess the pros and cons differ significantly, a distinction between the two would be a noteworthy benefit. For instance, such a distinction helps to highlight the role that expansion to existing villages can play in supporting existing communities. St John’s College is promoting site SR4 at Cliffe Woods for development and support Medway Council progressing the assessment of this site to Stage 2 within the LAA process. Site SR4 would provide a logical next phase of development to the existing village and facilitate prompt delivery of homes with further information supplied within the Vision Document prepared and submitted alongside the Call for Sites, as well as these representations. St John’s College would be very happy to liaise with officers to discuss the deliverability of Site SR4 as soon as convenient. Further supporting evidence has and continues to be prepared and can be made available as part of those discussions.

It is questioned the extent that town centre regeneration does in fact have potential to meet the needs of older people and families. There are two fundamental points associated with development on previously developed land, namely 1. the cost of remediation and 2. the typically urban environment justifying higher densities. Both of these facts inevitably lead to brownfield development predominantly containing a high proportion of flats or smaller units that may not be suited or as desirable for certain households, namely families. Such densities are often required to provide the returns necessary to offset the remediation costs and given the market led nature of the development industry and the need to use land efficiently, it is somewhat inevitable that higher densities will be used where the context would promote such character.
In terms of the assumption that the elderly and families may find accessibility to town centres desirable is questioned. There does not appear to be any detailed evidence to support this. Indeed a counter argument could be the assumption that those households quite often prefer the quality of life attributed to a village setting. Of course this in itself is also an assumption but is highlighted to indicate that if such statements are to be made, they need to be based on clear evidence. It is contended that an argument for sustainability should not simply be used to justify focus on growth towards urban areas. Indeed, a balance with growth in more rural settings can be beneficial, subject to ensuring the relevant infrastructure is put in place to support the selected spatial strategy.
It is reiterated that the role of brownfield sites is of course noted and an important focus for development. However, the role and benefits of greenfield sites should not be downplayed to ensure a range of needs are met. A balanced approach not only helps meet a variety of needs that arise within the community but also helps facilitate a continuous delivery.

It is suggested that the ‘opportunities’ should include greater focus on the speed of delivery that greenfield sites can produce. As part of this, greenfield sites can have a major role to play in delivery as the sites are not restricted by the regeneration and remediation timescales and costs all too often linked to brownfield sites.
A further opportunity to highlight is the role that new homes in more rural settlements and villages can play in supporting and sustaining those villages and associated services. For instance, bus services, schools, village shops, pubs and local community groups.

It is considered that this is a somewhat negative starting point and instead could refer to the need for further assessment of the potential implications of the LTC at this relatively early stage in the plan making process.