Medway Local Plan (Regulation 18, 2023)

It is noted that the “Vision” seeks to provide more sustainable and resilient development, strengthen and enhance the character of Medway including supporting green infrastructure, creating a healthy place in which to live and work, and providing decent places to live for all sectors and ages of the community. It further highlights Medway as a leading economic player in the region where it can support the business space attracting new investment. Alongside development, there should also be the provision of improved travel choices and infrastructure provision.

However, the “Vision” is silent on its intention to meet its identified housing needs. It is similarly silent on its intention of addressing economic/employment needs. Indeed, the overarching principles for the “Vision” fails to identify housing at all (para 3.1) as forming an important component of the Plan.

Whilst the “Vision” talks in general terms about how development is to be provided, central to the “Vision” must be “how much development is provided” as a matter that is fundamental to the framework for growth and spatial strategy as a determinative matter. This is a significant failing, considering the “Context” identifies “the supply of new homes is central to the Local Plan” (para 2.7).
NPPF (para 15) states that:

The planning system should be genuinely plan-led. Succinct and up-to-date plans should provide a positive vision for the future of each area; a framework for addressing housing needs and other economic, social and environmental priorities; and a platform for local people to shape their surroundings.

In the absence of the “Vision” setting out its intention of how much development is to be delivered, specifically housing development, it does not provide a positive framework for addressing housing need contrary to the NPPF (para 15). This failing is further perpetrated by the “Strategic Objectives” (see Section 3 of this Statement), which also does not address the scale of housing provision that should be delivered, also contrary to the NPPF (para 20). This underlines the importance of the” Vision” setting out the intentions for growth.
The “Vision” as set out at para 3.1 must be amended as follows (new test in red):

The policies and growth strategy in the new Plan will deliver the vision for what we want to achieve for Medway by 2040. Our thoughts for what this vision could look like are set out below. The vision encompasses all aspects of policies in the new Local Plan, including housing, transport, environment, retail, employment and waste and minerals.

Allied to this, a new paragraph must be added, or existing paragraphs amended as part of the “Vision” clearly setting out the intention of the Local Plan to meet identified housing and employment needs. The 7th paragraph (un-numbered) could be amended as follows:
The Plan will seek to deliver 28,500 new homes to ensure the needs of all sections and ages of the community can find decent places to live. The quality of new development has enhanced Medway’s profile, and driven up environmental standards in construction, and older properties have been retro-fitted to improve sustainability. Custom and self-build housing has provided new living opportunities for residents. Investment in new services and infrastructure, such as transport, schools, healthcare and open spaces, has supported house building to provide a good quality of life for residents.

The proposed change aligns with the “Development Needs” (para 5.4), which as set out in Section 4 of this statement the Plan must seek to deliver on.

The outlined changes are essential to ensure the Plan is “Positively Prepared”, “Consistent with National Policy” and therefore “Sound” (NPPF, para 35).