Medway Local Plan (Regulation 18, 2023)

Q1. Do you have any comments about the proposed vision?

Homes England are supportive in principle of the proposed Vision, which appears to consider a wide range of matters that will be essential to ensure Medway is a successful, attractive and high-quality place for residents, businesses and visitors in the future.

As the Government’s Housing and Regeneration Agency, Homes England are supportive of the aspiration that “all sectors and ages of the community can find decent places to live.” This aligns with the objectives outlined in our Strategic Plan to create high-quality homes in well-designed places that respond to local priorities.

The Vision appears to focus employment development on “brownfield” land, such as “derelict sites at Grain and Kingsnorth”. However, Medway should also acknowledge in the Vision that “vacant brownfield land” will be utilised for delivering residential growth.

Given the scale of proposed housing growth in Medway, Homes England consider that the Vision should also reflect the fact that Medway will be delivering significant increases in housing during the Plan period, and therefore, should include a reference to the level of sustainable housing growth envisaged.

The Vision sets a framework for the area’s growth to 2040. We note that the plan period used in this Regulation 18 document is from 2022-2040 (paragraph 5.12). The National Planning Policy Framework (September 2023, paragraph 22) states that:

“Strategic policies should look ahead over a minimum 15-year period from adoption… Where larger scale development 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.”

We consider that the Vision is not consistent with national policy if it only looks ahead to the year 2040. We note that the Council’s Local Development Scheme (October 2022) states that Adoption is anticipated in Autumn 2025. To allow for any slippage in the Local Plan programme, and to align with monitoring years, it is considered that 2041 should be the minimum Plan period. However, given the potential to incorporate large scale development to meet the Council’s housing needs over the Plan period, it would be more appropriate to include a vision that looks 30 years ahead to the year 2056 to be consistent with national policy.


Q2. Do you have any comments about the proposed strategic objectives?

Homes England acknowledge that the strategic objectives will underpin the emerging Vision. Similar to the response to Question 1, the Agency is supportive in principle of the proposed strategic objectives, particularly in relation to:

• The aim to “meet the housing needs of Medway’s communities reflecting the range of sizes, types and affordability the area needs,", under the objective “Supporting people to lead healthy lives and strengthening our communities.” It is recommended that any policy in relation to housing mix incorporates some flexibility to ensure it is effective and can allow for consideration of additional or updated evidence as demand may change over time to reflect market conditions and the economic climate. Not only is this essential to create a successful place that responds to the needs of the local community, it is critical if the Plan is to be positively prepared to comply with the National Planning Policy Framework (NPPF) (2023) paragraph 35a. Homes England’s proposed development at Lodge Hill will support these objectives through the delivery of new homes across a range of sizes, types and tenures, offering increased choice within the local area.

• The regeneration of Medway and “making the best use of brownfield land” under the objective to “Boost pride in Medway through quality and resilient development.” Homes England supports the aspiration to encourage development on brownfield land, which is a key aspect of NPPF paragraphs 119 and 120. The Agency would like to highlight that brownfield sites are not exclusive to the urban cores or waterfront of Medway, and so suggest the wording is updated to reflect that brownfield development outside these locations will also make an important contribution to the future place. Homes England considers that land at Lodge Hill is a suitable and sustainable location for housing and mixed-use development.

• The aim “to lift the standards of sustainability and quality in all new developments” and “to deliver on the Council’s commitment to addressing the Climate Emergency”. There is a positive synergy between these and the objectives outlined in Homes England’s Strategic Plan, for example, around placemaking, quality and sustainability.

• The objective “to secure jobs and develop skills for a competitive economy.” The significant housing growth requirements in Medway will also result in boosting the local economy providing further job opportunities. Housing and employment growth will need to be considered collectively to ensure sustainable future patterns of growth.

Q3. Do you have any comments about the considerations in developing a spatial strategy?
Developing a Spatial Strategy
Development Needs

Housing Numbers
The Council calculate Local Housing Need to be 1,667 homes per annum. Avison Young have cross referenced this and confirm this is an appropriate annual figure based on the standard method calculation using the 2014 Household projection figures (from 2023 and 2033) and the 2022 affordability ratio figure (published in 2023), which results in a requirement of 1,667 dwellings per annum, which is comparable with the Council’s figure. Use of the Standard Method figure to determine the minimum number of homes in the emerging Medway Local Plan is consistent with the NPPF, Paragraph 61.

The Council indicates that the housing needs for Medway over the Plan period of 2022-2040 is 28,339 homes and providing for a buffer would lift the total need to over 29,000 homes. Whilst the inclusion of a buffer is supportive as it would ensure flexibility in supply should sites not come forward, this should be 20% to reflect the Council’s record of under delivery in recent years. This is discussed in further detail below. However, the Plan period identified (2022 – 2040), covers 18 years which would actually result in 30,006 dwellings if the 1,667 dwellings per annum figure is applied. As stated in our comments made in response to Question 1 on the Plan period, we would suggest the Council consider adopting extending this to at least 2041, which would indicate a housing need of at least 36,000 homes (including our recommended 20% buffer) in the period 2022-2041.

Medway Council should adopt a strategy which, as a minimum, seeks to meet the areas Objectively Assessed Need (OAN) and is informed by agreements with other authorities so that unmet need from neighbouring authorities (such as the 2,000 homes identified by Gravesham) is accommodated in Medway “where it is practical to do so and is consistent with achieving sustainable development” (NPPF paragraph 35a). Whilst the proposed Levelling-up and Regeneration Bill reforms to the NPPF could amend it, the Duty to Cooperate is still a legal requirement at present and the reforms propose something similar, albeit currently referred to as an “alignment” policy. Therefore, it is important for the Council to consider how it could increase its own housing requirement and supply to address some of these unmet needs, otherwise the Plan may be considered not legally compliant or positively prepared.

In addition to the above, and the approach to meeting OAN as an absolute minimum, Homes England considers that it will also be important to assess the level of homes required to support economic growth. In order to be consistent with paragraph 82 of the NPPF, policies should seek to address potential barriers to investment such as inadequate housing.

Land Supply
We note that Medway Council has identified 7,583 homes in the ‘pipeline’ and a further 3,000 homes as windfall development in the Plan period. Evidence is required to support and justify these supply figures. It is important that the data underpinning these figures is signposted and available to ensure the residual number regarding the allocations of housing sites is robust and deliverable. This will ensure both the targets and overall Vision of the emerging Local Plan are achievable.

If there is insufficient evidence to support the pipeline and windfall numbers adopted, additional housing allocations should be considered to ensure Medway’s Housing need.

The Council is proposing a buffer of 661 homes for the Plan period, which represents an uplift between need and supply of less than 5%. The NPPF (Paragraph 74) suggests that a larger buffer is required. This is particularly the case given the recent undersupply demonstrated by the Housing Delivery Test (2022). A buffer of 20% would comply with the NPPF and would ensure choice and competition in the market for land. A 20% buffer would provide the clarity and certainty needed to demonstrate that the Local Plan has been prepared positively and would deliver the new homes needed.

Strategic Level Comments:
We note that Medway Council have identified 5 broad locations for growth (option 1 – urban; option 2 – sub-urban; option 3 – rural; option 4 – green belt and option 5 – employment). In relation to these broad categories, we note the following:
• The emerging Local Plan identifies that a minimum of 19,173 homes will need to be allocated, albeit for the reasons outlined above it is considered this will be higher.

• To meet this requirement, Medway Council will need to pursue a mix of the growth options proposed to ensure a robust development strategy that meets the test of soundness, ensures a resilient housing trajectory over the Plan period and provides a mix of housing to respond to differing local demand. It is also important to highlight that a minimum of 19,173 homes could not be delivered in any one individual location for growth assuming all sites pass the Council’s Site Assessment process (i.e. ‘Rural Development’, the highest category at 14,736 potential homes, wouldn’t be sufficient to meet Medway’s housing needs alone).

• All potential housing allocations and employment allocations will be tested in more detail as the Plan progresses alongside the Council’s Sustainability Appraisal and site selection process. The Council need to review all the sites assessed to ensure that the housing and employment supply proposed in the emerging Local Plan is robust and deliverable. In relation to sites submitted, the Council must be assured that they are available, suitable and deliverable in the Plan period, particularly if they are to be allocated for early delivery.

• The Regulation 18 Consultation document recognises National Highways’ concerns that capacity and safety at M2 Junction 1 will stymie development of jobs and homes across north and mid-Kent, unless a clear scheme to address the issues is put in place. It is understood that Medway Council and neighbouring authorities are working collaboratively with National Highways to identify how impacts of Local Plan growth could be mitigated, and improvements delivered, in order for the Council to ‘plan positively’ for growth in meeting their OAN and addressing any infrastructure constraints. The Council’s transport evidence base, developed in consultation with National Highways, will need to demonstrate how this can be achieved.

• Existing planning applications are being held in abeyance until an acceptable scheme to address the M2 Junction 1 traffic capacity and road safety concerns of National Highways is devised, which is a serious consideration for the emerging Local Plan. The work being undertaken by transport consultants appointed by Medway Council to carry out traffic impact appraisals and mitigation work on M2 Junction 1 by the end of 2023 needs to consider the longer-term growth to be delivered through the draft Local Plan, as well as addressing any immediate concerns around local network capacity.

• The Vision and strategic objectives in the draft Local Plan articulate an aspiration to deliver sustainable development that will minimise traffic growth, address the culture of dependency on private cars and will promote containment of trips and enable sustainable transport choices. This needs to be demonstrated through a robust transport evidence base that considers the strategic and local transport network, as well as bus service and active travel improvements and opportunities.

• Homes England also advocates an approach that considers locations of employment alongside housing growth to ensure sustainable development outcomes. Economic Growth envisaged in the urban areas and on the Hoo Peninsula should therefore be coupled with future housing development, otherwise there is a risk the Plan could have unsustainable patterns of development.

• The Council states that many of the growth locations are subject to constraints including environmental considerations, infrastructure requirements and viability. It is imperative that the Council’s evidence base is robust to ensure sustainable outcomes are achieved in the emerging Local Plan.

Broad Category Comments

The following provides Homes England’s response to the proposed housing growth options:

Urban Regeneration
Urban regeneration can be transformational for existing places and communities, therefore, is likely to play a role in shaping the future of Medway. Nonetheless, this type of development can face a number of challenges and site constraints, for example around existing uses, occupiers, multiple-landownerships and abnormal costs impacting viability. This could mean urban regeneration schemes are more likely to be delivered over the medium-longer term. Accordingly, it will be important for Medway Council to demonstrate that these sites are deliverable over the Local Plan period.

Suburban Growth
Suburban regeneration can also make a contribution to growth in Medway coupled with other scenarios. The Regulation 18 consultation material does however identify a number of constraints to development in this location, such as the potential loss of Best and Most Versatile agricultural land and impacts on the Medway Estuary Special Protection Area (SPA). The Council’s site assessment of this growth option should be mindful of the cumulative impacts on these constraints to ensure that the overall strategy is appropriate.

Rural development
The reference to a “Rural” approach to accommodate growth is potentially misleading as it implies there is a limited range of existing development, services and/or facilities in this location. Based on the Regulation 18 consultation material, this growth option appears to be largely focused on the Hoo Peninsula and so moving forward it may be better described as the “Peninsula” approach to accommodate growth.

Homes England recognises that this growth option will be required to ensure a clear and varied strategy for accommodating Medway’s OAN in full. Homes England support the Council’s view that there is significant land for potential development of homes, jobs and services on the Hoo Peninsula. The delivery of multiple uses in this location will provide a range of benefits and therefore aligns with NPPF paragraph 120 (a).

A significant amount of work has been undertaken to date to explore development on the Hoo Peninsula. For example, the Hoo Development Framework (2022) outlines “there is potential for development on the Hoo Peninsula as part of the wider growth strategy for Medway” and that “proposals for housing and economic development on the Hoo Peninsula have been included as options at different stages of consultation on the emerging Local Plan over recent years”. This evidence base should not be ignored and already forms a basis by which to consider a realistic proposition for growth on the Hoo Peninsula.

A benefit to delivering development through the “rural”/Peninsula approach is that it will provide additional services and facilities, which meet the needs of both future and existing residents. This is therefore likely to reduce the need for residents to travel and so will encourage more sustainable lifestyle choices.

The Regulation 18 consultation document identifies the need for sustainable transport improvements within the “rural”/Peninsula area as a means to mitigate capacity issues on the road network. The need to upgrade the transport network alongside increasing sustainable transport choices should be informed by a robust assessment to ensure a sound approach to plan-making.

Consideration also needs to be given to the opportunity for containment of trips within the Hoo Peninsula to avoid impacts on the strategic road network. This could be achieved, in part, through the delivery of a mix of development types and it is noted that the two major employment sites are identified on the Hoo Peninsula.

The Regulation 18 consultation document recognises the need to consider potential impacts of development on different aspects of the natural environment. This aligns with the objectives in Homes England’s Strategic Plan that seek to enable sustainable homes and places, maximising their positive contribution to the natural environment whilst minimising their environmental impact. Given the presence of a number of significant nature designations on the Peninsula and within the wider “rural”/Peninsula growth option, Medway Council should consider the preparation of a strategic vision for enhancing ecological networks within the wider landscape. This would enable a holistic approach to managing sensitive ecological designations, whilst unlocking development opportunities. Whilst site specific assessments would be necessary to support any development site, the wider strategic ecological vision could include proposals for:
• Standoff buffers between proposed development footprints and the nature designations (i.e. SSSI).
• Improvements to the existing boundary treatments around sensitive ecological areas.
• Vegetative screening to mitigate potential visual and noise disturbance.
• Opportunities to deliver Biodiversity Net Gain, in order to provide new natural habitats that could also help to screen sensitive ecological areas from development.
• Proposed access management improvements taking account of protected habitats to ensure that future public access is managed sensitively.
• In the context of significant housing coming forward, there may be a requirement to balance this with delivery of high value habitat creation proposals, which could provide an important contribution to the emerging Kent and Medway Local Nature Recovery Strategy on the Hoo Peninsula, providing enhanced landscape connectivity, bolstering habitats and species associated with the SSSIs and ultimately improving the long-term resilience of SSSIs in the context of wider development pressures.

Green Belt release
Paragraph 140 of the NPPF states that “once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans”. Paragraph 141 only allows for Green Belt boundary amendments where it can be demonstrated that as much use as possible has been made of brownfield and underutilised land, densities have been optimised and where it has not been possible to accommodate need elsewhere. Therefore, if Medway Council intends to release Green Belt land for development there is a requirement for a robust evidence base, including a detailed Green Belt Assessment and an exhaustive site selection process, particularly given there currently appears sufficient sites elsewhere to meet the Council’s housing and employment needs.

Only a small proportion of Medway’s administrative area is Green Belt, which is related to the adjoining authority of Gravesham. It would therefore seem appropriate for any Green Belt Assessment to be conducted with adjoining authorities to ensure any wider Green Belt impacts can be understood, particularly in the context of any unmet need arising from these adjoining authorities.

Employment Sites
The Regulation 18 consultation material identifies opportunities for strategic employment allocation at Grain and Kingsnorth on the Hoo Peninsula. To ensure sustainable patterns of growth it will be essential to ensure that housing/employment are considered in tandem, which should therefore strengthen the role that the "rural"/Peninsula approach plays in accommodating Medway's future housing.

Q4. Do you have any comments about the interim Land Availability Assessment?
Land Availability Assessment (LAA)
The Land Availability Assessment (LAA) identifies circa 447 sites, of which 146 valid submissions were received through the Call for Sites exercise in early 2023. It is important that these sites are thoroughly assessed to determine those that are available, suitable and deliverable for allocation in the Plan period.

There is also the need to follow correct process in selecting sites and taking account of reasonable alternatives to ensure the Plan is justified. The Council’s Sustainability Appraisal and other evidence that informs the wider site selection process should incorporate a robust approach in the consideration of alternatives to assist the Council in putting forward a sound Local Plan.

It is important to highlight that a number of the sites included in the LAA have been assessed by Medway Council previously and were found to be appropriate for allocation. This includes the proposed allocation of Chattenden Barracks, which has been included in the withdrawn Local Plan (October 2021) and draft Hoo Development Framework (September 2022). A lot of the analysis carried out by Medway Council will not have changed and, if sites continue to be available, they are likely to remain suitable for allocation to be consistent in assessment.

It should also be acknowledged that the scale of sites play an important role in enabling housing development to come forward. The ability to deliver housing at pace on small to medium sized sites will ensure that the housing delivery can come forward earlier in the proposed Plan period compared to longer-term strategic proposals (potentially those involving greenfield sites).

Land at Lodge Hill

As part of this Regulation 18 consultation, Homes England are promoting two sites within the Lodge Hill estate for development:
• Land at Chattenden Barracks is promoted for residential development of up to 500 homes alongside the former recreation ground which is identified for associated greenspace; and
• Lodge Hill Camp is promoted for redevelopment to provide a mix of uses that could include employment, residential, education and community uses.

These sites were promoted previously to the Call for Sites Submission in February 2023. The Council’s subsequent Land Availability Assessment (October 2023) identifies the sites separately: Lodge Hill Camp incorporating the former Recreation Ground (HHH1) and Chattenden Barracks (HHH3). Homes England are pleased that the LAA identifies sites HHH1 (Lodge Hill Camp) and HHH3 (Chattenden Barracks) will both be considered in more detail for potential allocation at the next stage of the emerging Local Plan.

To support the Council in their future assessment, a Vision Document has been prepared and submitted alongside this written response. This sets out the development aspirations for Lodge Hill Camp and Chattenden Barracks (including the recreation ground) alongside technical information, which demonstrates that both sites are suitable, available and achievable for the proposed development.

The remainder of this section provide a high-level summary of the justification for the allocation of these two sites; however, Medway Council are asked to review the Vision Document for the detail of the proposals.

The redevelopment of these sites offers the opportunity to deliver high-quality, well-designed places that contribute to the vibrancy and vitality of the wider Hoo Peninsula, including Chattenden. It will also deliver sustainable homes and places, maximising their positive contribution to the natural environment and minimising the environmental impact.

The NPPF requires local authorities to prepare local planning policies that are aspirational but deliverable. In relation to ”identifying land for homes”, NPPF paragraph 68 states that:

“Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.”

We note that for a site to be considered deliverable for housing it:

“Should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years…” (NPPF Page 67).

The above criteria have been used to consider the proposals for Chattenden Barracks and Lodge Hill Camp. These are outlined below:

Available now:

Homes England is the sole landowner of both development sites. It is the Agency’s intention that they will be bought forward for development in the short term to meet local development needs, including the delivery of much-needed homes and associated community infrastructure.

Suitable for development:

In determining that both sites are suitable for redevelopment a number of factors have been considered, including Medway’s growth strategy, the mix of uses proposed and site-specific influences.

Medway Council has recognised that there is significant land for the potential development of homes, jobs and services on the Hoo Peninsula in both the Regulation 18 consultation material (September 2023) and Hoo Development Framework consultation document (dated 22 September 2022). Moreover, the latter identifies Chattenden Barracks as a residential-led development opportunity.

Regarding uses, Chattenden Barracks is being promoted for up to 500 new homes. Not only does this align with the emerging planning policy, but the principle of the proposed use in the locality is considered acceptable given the nature of the surrounding area with existing housing to the north and south-east.

In respect of Lodge Hill Camp, key to the successful reuse of this previously developed land is ensuring flexibility in the planning policies to ensure it is brought back into effective use. This land is suitable for a range of uses including, but not limited to, employment, residential, education and community use. It is also worth noting that possible retention of the buildings on site could meet the requirements of a niche operator, the planning use of which might not fall neatly within the existing use classes.

In terms of site-specific considerations, both sites form part of the former MoD Chattenden site. This wider site has historically been developed and operated by the MoD for military use and provided accommodation for some employees stationed on the site. In line with the NPPF paragraphs 119 and 120, the brownfield nature of both sites significantly contributes to their suitability for redevelopment.

Furthermore, Homes England has undertaken a significant amount of technical work that informs the suitability of the sites for development. This work is comprehensive covering, ground conditions, ecology, transport, heritage, and a level of initial assessment of contamination (in particular unexploded ordnance (UXO)). Alongside this consideration has also been given to the local property market. The Vision Document demonstrates that whilst some of these matters will influence the design of future development proposals, they do not impact the suitability, as such both sites are considered suitable for the proposed development.

Achievable:
The accompanying Vision Document is underpinned by a suite of comprehensive technical assessments that demonstrate that the delivery of new homes and other uses (such as employment, education etc) is achievable. Homes England supports and accelerates the delivery of housing led projects. The Agency has expertise and a track record in unlocking and delivering complex development sites, delivering infrastructure early and accelerating the provision of new homes. Whilst Homes England do not actually build homes directly, the Agency contracts with a variety of delivery partners from PLCs to SMEs under a Building Lease. This provides greater control on pace of delivery, quality of new homes and innovative building technologies such as Modern Methods of Construction.

Homes England is uniquely placed to bring forward sustainable development at Lodge Hill and can deliver much needed housing in Medway. To further illustrate this, the following factors should be noted:
• Medway is a Council that faces challenging housing delivery targets. Planning policy requires that there is a step change in delivery and the emerging Local Plan will be the principal vehicle to deliver this radical change. Homes England, as the Government’s Housing and Regeneration Agency, are seeking to develop up to 500 homes on Chattenden Barracks and a mix of uses, potentially including residential on Lodge Hill Camp. The delivery of these sites, including much needed affordable homes, could therefore make a material contribution to meeting the local housing need.
• Homes England has acquired Lodge Hill to ensure that, in line with historic planning policy, it is regenerated. Government policy is to make effective use of land in meeting the need for homes and other uses in line with Section 11 of the NPPF.
• Lodge Hill has been identified as a significant brownfield development opportunity for a number of years. The emerging vision and masterplan demonstrate that there is considerable opportunity to provide a well-designed, high-quality and sustainable development that minimises the impact on the local environment. The emerging Medway Local Plan, if it is to be “positively prepared” (NPPF paragraph 35), should provide a clear vision and strategy (supported by policy) for the regeneration of Lodge Hill.

Conclusions

Homes England is generally supportive of the Council's Vision, strategic objectives and overarching spatial strategy. It is supportive of an approach that incorporates the “Rural”/Peninsula option and in particular agrees that there is significant land for potential development for homes, jobs and services on the Hoo Peninsula, making as much use as possible of brownfield sites.

The supporting Vision document and high-level summary demonstrates that both Lodge Hill Camp and Chattenden Barracks provide excellent opportunities to deliver high-quality and sustainable growth that will have a positive impact on the wider place, particularly Chattenden. These sites are available, suitable and deliverable for development and could make an important contribution to Medway’s growth strategy.