Medway Local Plan (Regulation 18, 2023)

Medway is ranked in the 30% most deprived local authorities nationally in the 2019 Indices of Deprivation and the 93rd most deprived local authority of 317 in England, with fourteen neighbourhoods ranked in the 105 most deprived nationally. Paragraph 4.29 of the Medway Local Housing Need Assessment (LHNA) 2021 states there is an annual need for 621 new affordable homes a year which represents 37% of the overall housing need. There are also 20,651 families in Medway on the social housing waiting list, a jump of 215% from those on the same waiting list in 2005. It is clear that the impacts of not delivering the amount of affordable houses needed in the
authority will exasperate the current deprivation levels and affordability issues Medway faces. Evidence suggests that low-cost, decent quality housing, in a healthy job market could make a substantial contribution to increasing disposable income, preventing material deprivation and maintaining work incentives. It is therefore imperative that the Council allocate a significant quantum of sites in the emerging Local Plan, so that affordable housing need can be met.

Our site that we are submitting as part of these representations is adjacent to the built-up area of Strood and would form a logical extension in a highly sustainable location for future development. The Land North of Rede Court has the potential to deliver market and affordable dwellings, including much needed family housing that can be delivered within the first five years of the Plan period and contribute to the housing needs of the District. Any proposals on the site would emphasise healthy living, contribute play areas and open space on site and provide opportunities to access local amenities, schools and community facilities by foot and cycle, so car use is kept to a minimum.

The latest house price to workplace-based earnings ratios were published in March 2023 by the Office for National Statistics. Affordability ratios are calculated by dividing house prices by gross annual workplace-based earnings. The results show that the median house price to median gross annual workplace based earnings in Medway is 8.65, meaning on average, working people in Medway could expect to pay over 8 times their annual earnings on purchasing a home in the District. While this is below the average in the South East (10.75), it is above the national average of 8.28. Given this, significant housing development is needed to address the demands of the unitary authority and deliver the homes the people of Medway need.

It is clear that the impacts of not delivering the amount of affordable houses needed in the authority will exasperate the current deprivation levels and affordability issues Medway faces. Evidence suggests that low-cost, decent quality housing, in a healthy job market could make a substantial contribution to increasing disposable income, preventing material deprivation and maintaining work incentives. It is therefore imperative that the Council allocate a significant quantum of sites in the emerging Local Plan, so that affordable housing need can be met.

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.

The current housing land supply and housing delivery position points to a significant need for housing within the borough. The Council can only demonstrate a housing land supply position of 3.64 years. Further to this the published housing delivery test result for 2021 was 67% when compared to the objectively assessed need under the Standard Method calculation (1,675 dwellings per annum (dpa)). This points to a persistent undersupply and under delivery of housing in Medway. In addition to the above, there is also a real problem with the delivery of affordable housing in the unitary authority. In 2021/22 only 17% of all gross housing completions were affordable. In the last
two years this has amounted to 408 affordable homes out of 2,264 gross completions. This is below the Council’s current target of at least 25% of homes being affordable. The cumulative shortfall over the 10 years from 2010/11 has been 3,649 dwellings. The issue may also be exasperated when the ‘right to acquire’ and ‘rent to buy’ sales of affordable homes is taken into consideration, which reduces
the amount of affordable housing stock in Medway and leads to a rise in supressed households.

Given the current housing crisis, despite the government not yet responding to the consultation on the revisions to the National Planning Policy Framework (NPPF) and lack of direction given to the future use of the Standard Method formula, it is imperative to meet the needs of the current and future residents of Medway who desperately need the right homes in the right places, with many residents currently living in sub-standard conditions.

Medway have indicated that the Local Plan would need to deliver 29,000 homes over the plan period plus an additional 2,000 homes to help meet Gravesham’s housing needs equating to a need to deliver 31,000 homes.

The Council contend that approximately 10,500 homes have been assessed as coming forward through the existing ‘pipeline’ of sites and an allowance for ‘windfall’ sites. The Reg.18 Plan states that there is an existing ‘pipeline’ of sites with planning permission which could contribute towards meeting the total need of the Plan, for approximately 7,500 homes. It is unclear at present which permissions the Council is relying on to deliver this existing ‘pipeline’ and therefore it is recommended that this is set out in the next iteration of the Plan to enable scrutiny and ensure the starting point for determine the housing allocations in the Plan is accurate and to avoid any double counting.
With respect to windfall sites, the Regulation 18 Plan states that an allowance of 3,000 homes will be provided over the Plan period which is a high allowance which is not currently evidenced in the Plan. ‘Windfall’ sites have formed an important component of housing land supply in Medway in recent years which have reflected the age of the current Local Plan. It is noted historically that the
Council has had larger sites come through as windfall. However,

Our assessment has indicated that Medway are only likely to be able to achieve approximately 21,000 homes from available sites in the District.

Medway states that it is committed to urban regeneration and is identifying underused sites that could make better use of brownfield land for development. While this should form an important part of Medway’s strategy, it would not deliver the visions and goals of the Plan when relied upon singularly. The cases of Chatham Dockyard and Strood Waterfront highlight the difficulties in delivering such
brownfield land in set timeframes. These ultimately fail to contribute to the Council’s pressing need for market and affordable homes. Land contamination, heritage, demolition and higher cost all act as constraints on the redevelopment of these sites which can affect viability and often lead to the slow delivery of schemes, or indeed never being completed. Medway’s recently awarded £4m from
government for unlocking unused brownfield land (for approximately 372 dwellings) highlights the significant investment required to deliver homes on brownfield land.

The Reg.18 document itself acknowledges that some of the urban regeneration sites have not been put forward by landowners and may not be available or deliverable. Indeed, the Medway Land Availability Assessment Interim Report (October 2023) provides a map that shows that quite a few of the brownfield sites identified in the Regulation 18 Plan are not available. Availability is a key tenant of deliverability identified within the National Planning Policy Framework (NPPF) and therefore any sites not available, should not be relied upon to meet the Council’s housing need.

Based on an understanding of the constraints in the District and the review of the availability of sites identified in the LAA Interim Report (October 2023), it is considered that the Council can only realistically delivery approximately 6,000 dwellings from urban regeneration schemes, which is 5,151 homes less than identified in the Reg. 18 Plan.

Suburban expansion is another category Medway is considering for potential growth. The Reg.18 Local Plan states that there is the potential for 9,691 homes for suburban expansion. Our assessment has indicated that this spatial strategy has the highest likelihood of achieving closer to the homes indicated. However, those sites between Grange and Lower Rainham have a number of issues to overcome, including impact on the character and appearance of the surrounding area including Gillingham Riverside Area of Local Landscape Importance, loss of high-grade quality agricultural land and overall impact on the local highway network. An appeal decision for the Land off Pump Lane confirms this, where an application for up to 1,250 units, local centre, village green, primary school, care facility and care home were dismissed by the Secretary of State on these grounds.

Furthermore, a number of these sites represent large scale strategic delivery, which could push the majority of housing from this form of growth past the first five years of the Plan period. It is therefore considered that a more realistic headline of 7,600 dwellings can be achieved through suburban expansion, which is 2,080 homes less than identified in the Reg. 18 Plan.

The Reg.18 document states there is the potential for development in the rural areas to provide capacity for 14,621 homes. The majority of the potential rural sites are located on the Hoo Peninsula. The recent decision by Homes England and the Department for Levelling Up, Housing and Communities (DLUHC) to stop the £170m programme of Housing Infrastructure Fund support greatly impacts the ability to deliver sustainable homes on the Hoo Peninsula. This funding was aimed at unlocking homes by funding the construction of new roads and a new railway station and passenger service that would have connected the wider Medway and Gravesend areas.

A high-level review has revealed that those sites identified in the North of the Hoo Peninsula, which were assessed in the 2019 Medway Strategic Land Availability Assessment (SLAA), were reliant on HIF support, with a particular reliance on the delivery of sustainable transport measures and unlocking capacity on the surrounding road network. Without this support, the sites remain isolated without access to services and are considered unsustainable and therefore unsuitable for development. We understand that without the new railway station any development would be dependent on an improved bus service, however, a bus service would not be enough to unlock the residential sites required to meet the Council’s housing requirements and would put further strain on the local road network.

We also understand that National Highways are concerned the strategic highway network and the number of trips at Junction 1 of the M2, and that further development in the rural areas of Medway would be reliant on delivering a solution to the Strategic Road Network. This further emphasises that the sites identified in the further reaches of the Peninsula are currently unsuitable.

While it is recognised that to meet the Council’s housing requirements, development on the Hoo Peninsula may be necessary, the loss of HIF support undoubtedly impacts the ability to deliver a significant quantum of housing in parts of the Peninsula that are isolated and lack the services, infrastructure and public transport that are necessary to achieve sustainable development that meet the economic, social and environmental objectives, as set out in Paragraph 8 of the NPPF (2023).

Development of the Hoo Peninsula requires careful planning and considerable wider investment which is likely to take years to develop and implement. In this respect, the Hoo Peninsula represents a possible opportunity for longer term growth, but not an effective solution to delivering housing in the short term.

The Reg.18 Plan states that there is a potential capacity for 2,824 homes in the Green Belt. The Reg.18 Plan rightly states that the Metropolitan Green Belt aims to stop the outward growth of Greater London into the surrounding countryside, towns and villages. Alterations to the Green Belt require exceptional circumstances.

The subject site, Land North of Rede Court (Site ID: SNF1) is identified as part of Green Belt release. The site specific Landscape, Visual and Green Belt Appraisal submitted with these representations provide the details of why exceptional circumstances exist to release this site from the Green Belt. More broadly, the Green Belt sites further south in the District, as identified in the Reg.18 Plan, can be argued to greater serve the Green Belt’s purposes. These include; to check the unrestricted sprawl of large built-up areas; preventing neighbouring towns merging into one another; and assist in safeguarding the countryside from encroachment. In addition, most of this land
is in the vicinity of the Kent Downs Area of Outstanding Natural Beauty which has the highest status of protection under the NPPF. Some of these sites are also highlighted as not suitable for housing in the Council’s Land Availability Assessment (2023).