Medway Local Plan (Regulation 18, 2023)

Similar to the Vision, the Objectives also fail to include reference to the strategic requirement to meet local housing needs. Objective 2 refers to homes and meeting the housing needs of Medway’s communities. Richborough is of the view that the text should be altered to acknowledge the need to meet the development needs in full, rather than limiting this to meeting the needs of existing communities. Richborough is also of the view that the requirement to meet housing needs should be the subject of a standalone objective.
Paragraph 60 of the NPPF not only establishes that housing needs should be met but also sets out the Government’s objective of significantly boosting the supply of homes. In light of the historic failure to meet the housing targets in Medway, the inclusion of a housing specific objective would stress the importance of the issue and ensure the efficiency of the Local Plan.
Richborough is of the view that the inclusion of Objective 2 alone is not fit for purpose and a new Objective should be provided to explicitly state that the full range of need for new housing should be met and integrate a focus on deliverability.

The Council’s Vision, whilst comprehensive, is overly long, and fails to adequately communicate the Vision for the delivery of new homes over the Plan Period.
The only reference to homes or housing within the Vision relate to sustainable methods of construction or retrofitting existing buildings, as well as making provision for custom and self-build homes. Whilst these are important technical matters, the critical strategic issue of delivering the number of homes to meet housing needs in full has been ignored.
Paragraph 11a of the NPPF is clear that plans should “promote a sustainable pattern of development that seeks to: meet the development needs of their area” and 11b states that “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas”.
Paragraph 60 of the NPPF also requires that “a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed”.
Richborough is therefore of the view that the ‘Vision’ should be altered to acknowledge the need to meet development needs in full, particularly for housing.
In the 19 years since the Medway Local Plan was adopted in 2003, completions have only exceeded the housing requirement figure that was in place at the time in only three years, and the three most recent monitoring years have seen the highest deficits. A Vision Document was submitted by Richborough during the 2023 Call for Sites consultation which included a section titled ‘Historic Housing Delivery’. This identifies that the cumulative under supply of housing since 2003 is 4,955 dwellings. This lower level of delivery has only exacerbated issues in regard to affordability through the lack of supply and lower levels of affordable housing delivery.
In respect of affordable housing completions, the annual need figure has not been met once since 2006 (the highest year was in 2008 and still saw a deficit of 305 dwellings) and the cumulative deficit in affordable housing over the 19 year period (2003-2021) is 10,012. This figure is also evidenced in the Vison Document submitted on behalf of Richborough in February 2023.
There is evidence of the negative social impact of the failure to deliver sufficient housing in Medway, with the house price to income ratio in the Borough deteriorating from 5.73 in 2014 to 8.65 in 2022 (House price to residence-based earnings ratio, ONS (2023)). The under-delivery of housing has contributed to worsening affordability in the Borough. Affordability is a critical social component of sustainable development that acts as a barrier to local people being able to access housing. The research paper published by LPDF titled ‘The Housing Emergency’, highlights that 1 in 5 adults regard housing issues as negatively impacting their mental health, according to another paper prepared by Shelter in 2017, titled ‘The impact of housing problems on mental health’. It should be accepted that there is an urgent need to boost housing delivery within Medway.
A step change in both delivery and approach is required if housing needs are to be met going forward. This requires the spatial vision for the new Plan to evolve and acknowledge where the lack of an up to date Local Plan has failed.

Richborough supports and agrees with the statement that greenfield suburban sites can be developed quickly and respond to market demand, particularly where landowners have confirmed the land is available and being promoted for development. Typically, greenfield sites are not restricted by viability and are capable of meeting the aims and policies of Local Plans in respect of contributions to infrastructure, the delivery of affordable housing and meeting technical requirements in respect of sustainable construction and dwelling standards.