Medway Local Plan (Regulation 18, 2023)

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 proposed 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 a site in the rural area to help deliver 14,736 homes as a way, amongst others, that could deliver a sustainable and green future for Medway.

Paragraph 5.41 of the Regulations 18 consultation, sets out that “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”.

This statement is supported and the site provides an opportunity to deliver this strategy.

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 ‘rural extensions’ should also be included in this objective, especially, as the rural development sites are included within the proposed spatial strategy for delivering growth.

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 site could provide an opportunity to deliver this objective, in a development which meets the aspirations of sustainable development, directing development to the most suitable locations.

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 of the consultation that Medway Council 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 housing need 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 of the consultation 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, respectfully, 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 proactive 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.

Flanders Farm (HHH19), could provide a reasonable alternative and an additional site on the outskirts of Hoo for additional housing development.

This representation supports 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) program to deliver improvements to transport and put measures in place to strengthen the local environment in the Hoo area.

Flanders Farm (HHH19)

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.