Medway Local Plan (Regulation 18, 2024)

6.1 Introduction

6.1.1 Medway experiences many of the same housing issues seen across the country, with rising costs of housing placing significant pressures on people. House prices have risen by over 23% in the last five years. Many people cannot afford to gain access to the 'housing ladder' and also face issues of availability and rising costs in the private rented sector. There has been a marked increase in homelessness requests in the last three years and greater use of Temporary Accommodation to support people. Increasing cost of rents in the private sector are exacerbating the problem. We also have areas of poor housing, where standards are low, and do not provide for a safe and healthy home. Poor quality housing impacts on people's health, such as worsening respiratory illnesses in damp homes. Some of these poor-quality homes have been provided through conversions under Permitted Development Rights, where they do not have to meet the normal requirements of a planning application for housing.

6.1.2 A primary purpose of the new Local Plan is to meet the needs of Medway's communities for housing. The Council is using the government's Standard Method for calculating Local Housing Need. As of March 2024, this is defined as 1,658 homes a year. We are using this as a basis to identify the land needed for housing over the plan period, to understand the scale of growth anticipated in Medway. The Strategic Growth Options set out in section 3 of this document seek to meet that scale of housing growth in Medway by 2041. The Council continues to update its evidence base and assessment work to inform the final content of the Local Plan. The next stage of the Local Plan (the Pre-Submission Draft Plan) will include specific policy on the scale, distribution, mix, and phasing of housing. The policies presented here for consultation provide an indication of the preferred approach and the current evidence base.

6.2 Housing mix

6.2.1 Accommodation standards and affordability impact on the quality of life of Medway's residents including their health and wellbeing. As Medway's population grows and changes, we need to ensure that we plan for the right mix of housing, reflecting the size of households and the demographics of our communities. Provision must be made to encourage socially mixed, sustainable communities with a sufficient choice and mix in the size, type and location of housing. The wide range of different households includes single households, families with children and older people. Our evidence base for the Local Plan includes a Local Housing Needs Assessment (2021) (LHNA) that considers the make-up of Medway's communities, projected forward over the plan period.^[51] The Council will update this evidence before finalising the plan to accurately reflect needs in our planning policies for housing.

6.2.2 A key strategic objective of this Local Plan is to provide for the range of housing needs of Medway's communities. The needs of specific groups are reflected in our proposed policies. This is in line with national planning policy. The proposed policies below reflect our current thinking and evidence base, and we welcome comments through this consultation.

6.2.3 Research on Medway's housing market shows that there is a need in Medway for all types and sizes of new homes. Dwelling mix analysis linked to demographic/household change in the 2021 LHNA supports a housing mix as set out below:

• Tenure mix - An overall tenure split of around three-quarters of units offered as market housing is required, with the remainder split between affordable/social rented and affordable home ownership, including First homes.
• Dwelling type mix – Analysis indicates a need for houses to provide around two thirds of new housing supply across all tenures, with flats and bungalow/level access accommodation to make up the remainder.
• Dwelling size mix - demographic analysis suggests a requirement range for between forty and forty-five percent of dwellings as two bed units, twenty-five to thirty percent of units as three-bed, fifteen to eighteen percent of units as four bed and between fifteen and twenty percent of units as one beds.

6.3 Affordable housing

6.3.1 As well as supplying a sufficient number of homes, Local Plans are required by national planning policy to make provision for affordable housing. With the cost of living pressures on our communities and escalating housing prices, there are many people in Medway who are priced out of the housing market.

6.3.2 Affordable housing in this policy refers to housing for rent or sale for households whose housing need is not met by the open market. It encompasses a range of options: affordable housing for rent, starter homes, discounted market sales housing and other affordable routes to home ownership.

6.3.3 The Government's First Homes scheme ensures that First Homes – unlike starter homes – will be sold with a minimum discount of 30 per cent off the market price. They are available via conventional mortgage products and when sold on the discount will be passed on to the new owner with the discount applied to the new value following an independent valuation. Homes will always be sold below market price and local communities will benefit for generations to come, with local authorities continuing to allocate these homes to first-time buyers and able to prioritise households with a local connection. First Homes are not allowed to be used as holiday homes or as buy to let properties.^[52] The Council has set out guidance in a First Home Position Statement.^[53]

6.3.4 The One Medway Council Plan, 2024 identifies Living in Good-Quality, Affordable Homes as a key priority.^[54] The implementation of the Local Plan contributes to this priority, with a plan that reflects the needs of the communities in Medway, supporting a transition to a low- carbon future promoting affordable, energy efficient and sustainable homes. To meet this priority, a range of homes should be made available across a range of budgets.

6.3.5 National planning policy states that affordable housing should not be sought for residential developments that are not major developments.^[55] Our proposed policy therefore states that all sites of 10 or more units shall be required to provide affordable housing.

6.3.6 To understand the need and appropriate levels of affordable housing required the authority has developed a significant evidence base to support the Local Plan and this policy. Two documents are key to this work - the Local Housing Need Assessment (LHNA) and the Local Plan Viability Assessment.^[56] The Viability Assessment considers the level of affordable housing that can be provided, ensuring that development is deliverable and meeting policy requirements. Both documents have been prepared on an iterative basis to support the preparation of the Local Plan and will be further updated to inform the content of the next version of the plan as the Pre-Submission Draft Plan. The last Viability Assessment was produced in January 2022. The Council recognises that there have been some changes in the development market since that time, and the range of specific strategic sites and locations tested in the document may not reflect the Council's latest position on a preferred indicative spatial strategy. However, the assessment provides a basis against which to consider the proposed policies that we have set out for consultation. The Council welcomes comments on the Viability Assessment and how its findings have been used to inform emerging policies.

6.3.7 The LHNA sets out the level of demographic need for housing amongst key groups, one of which is those seeking affordable housing. The Viability Assessment tests the economic impact of policies within the local plan and financial viability of proposed development in Medway. These documents are used in conjunction to set an appropriate affordable housing requirement.

6.3.8 In Medway there is a significant need for affordable housing. The LHNA, 2021 identified a need of 55% of housing to be delivered as affordable units. However, such a requirement needs to be deliverable by demonstrating the viability of such a policy. Evidence from the Viability Assessment was applied to identify an achievable policy requirement.

6.3.9 The affordable housing element of the housing supply can be split further into the following tenures. 39% to be social rented, 21% to be affordable rented, with the remaining 40% as affordable home ownership, split as 25% First Homes and 15% 'other' affordable home ownership.

6.3.10 The Council has commissioned viability assessment work as part of the evidence base for the new Local Plan. This work has included consideration of the level of affordable housing that could be supported across different types of development and locations. The assessment showed that different rates of affordable housing contributions could be made between the higher value areas, such as greenfield sites, and lower value areas, such on inner brownfield sites.

6.3.11 In the areas where viability was challenged, such as urban brownfield sites, a 10% affordable housing rate could be supported. In the stronger market areas, such as the Hoo Peninsula and suburban locations, this rose to 30%. The difference was based on the different land values, house prices and build costs. The 2022 Viability Assessment has informed the content of this draft policy for consultation. The Council notes that there may have been changes in the development market since the preparation of this assessment, and variations in proposed development sites considered in the assessment. The Council will consider comments in relation to viability from this consultation, and address these in updating the evidence base and policy response for the Regulation 19 Pre-Submission Draft Plan.

6.3.12 The delivery of affordable housing should be on site in the first instance. National planning policy outlines this preference.^[57] However off-site provision and financial contributions are allowed, but this should be tightly controlled to ensure that affordable housing is delivered to meet the needs of the local population.

6.3.13 The policy follows a cascade principle, where the preference is for on-site delivery. If this cannot be delivered, then consideration is given to off-site provision can be made through delivery on another site, or in the last resort a financial contribution. However, this should be justified and supported by evidence as to why it cannot be met via the Council's standard approach of on-site delivery.

6.3.14 If the development proposes no contribution towards affordable housing this needs to be justified. The Council will expect justification via a viability assessment undertaken and submitted by the applicant. This will then be verified by the Council's independent viability consultant with the cost for the work for the independent verification being paid for by the applicant.

6.3.15 It is noted that currently developers in Kent are having problems getting registered providers to take on affordable housing secured as part of a section 106 agreement. The Council will continue to work collaboratively to address this issue. National policy expects developments to foster social interactions between groups who 'might not otherwise come in to contact', and to be designed to be inclusive. Affordable housing needs to be well-integrated into a mixed tenure development.^[58]

6.4 Supported housing, nursing homes and older persons accommodation

6.4.1 Policy T4 considers the need for housing specially designed for sectors of the community, such as older people, people with disabilities and vulnerable people with specific housing needs, who may, for a variety of reasons, face barriers to finding accommodation to meet their personal needs.

6.4.2 The NPPF promotes the need to supply homes where they are needed that meets the needs of groups with specific housing requirements. This is essential if the objective of creating mixed and balanced communities is to be achieved. The provision of appropriate housing needed for different groups in the community should be assessed and reflected in planning policies including older people and people with disabilities.^[59] This translates into a need for all types of housing including retirement housing, children's homes, housing-with-care and care homes.

6.4.3 The Care Act 2014 includes the explicit need to consider accommodation suitability as part of the assessment and delivery of services.

6.4.4 The Medway Council Plan and Housing Strategy identify priorities for a supply of accommodation to enable residents who have additional needs to live independently in their own home. There is a commitment to ensure there is sufficient housing for specific vulnerable groups to provide equal access to housing for all residents in Medway.^[60]

Housing need

6.4.5 The health and lifestyles of older people will differ greatly, as will their housing needs, which can range from accessible and adaptable general needs housing to specialist housing with high levels of care and support.

6.4.6 Similarly, people with disabilities can include, but are not limited to, people with ambulatory difficulties, blindness, learning difficulties, autism and mental health needs, which may generate a range of housing requirements which can change over time.

6.4.7 Medway's population is predicted to grow over the Local Plan period to 2041, with over 65's accounting for a significant proportion of this growth as people are living longer. The official population and household projections indicate a significant increase in older persons and older person's households.^[61],[62] With the ageing population, a range of health needs are projected across the population. These include an increase in people living with dementia. Medway's Joint Strategic Needs Assessment, 2024 for Adult and Social Care identifies key issues and gaps in services, and makes recommendations for commissioning.^[63] These include working with the Planning Service to ensure the availability of suitable housing, and supporting adaptations to keep people living in their own homes.

6.4.8 Older people living on their own may be expected to have greater care needs than those living with a partner or family members, who may be more likely to receive unpaid informal care.

6.4.9 The household projections indicate a notable increase in older persons living alone, with over 65's single person households increasing by just over one quarter over the course of the Local Plan period.

6.4.10 Medway is also seeing an increase in looked after children, and a need for additional specialist accommodation for children and young people.

6.4.11 A number of different models exist to meet the housing needs of those with specific needs including older persons and people of all ages with physical or learning disabilities or the homeless.

6.4.12 Housing with care can include extra care, sheltered housing and assisted living. This is normally delivered in the form of self-contained accommodation that is provided within a purpose-built block or small estate where all residents have similar support needs. Care is provided for those who cannot live completely on their own, or would like the comfort of knowing assistance is available, but do not need significant levels of personal care. This type of accommodation can also serve the wider needs of: young people at risk of, or who are homeless; young people leaving care; people with learning disabilities; those with clinical mental ill-health issues; people with added vulnerabilities who are or become homeless; and people experiencing domestic abuse. In planning for the mix of housing to meet our communities' needs, consideration will be given to specialist accommodation, including dementia care homes and children's homes.

6.4.13 Care or nursing homes provide a higher degree of personal care and / or long-term medical treatment for those who cannot live independently.

6.4.14 Modelled projections based on the official projections indicate a significant increase in the need for housing and schemes that offer an element of care for older persons and others with these specific needs.

6.4.15 Projected figures indicate an increase in older residents unable to complete at least one domestic activity on their own increasing by almost one third to 2040.

_{Source: Projecting Older People Population Information}
Figure 3: Older Persons Need

6.4.16 The Council's housing register indicates that there are 487 applicants who have indicated a preference for sheltered housing.

6.4.17 Many people with learning disabilities will have been cared for by their parents. However, as the parents approach old age, they may no longer be able to care for them and therefore an alternative care arrangement maybe suitable for this group. However provision of alternative accommodation may be limited.

Supply

6.4.18 Medway's supply of housing needs to account for the above growing demands, to provide suitable accommodation for a wide range of requirements. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems.

Figure 4: Care Homes and Supported Living

6.4.19 In Medway there are around twenty-nine supported residential facilities for older persons and one hundred and thirty-nine facilities for working-age residents, as detailed in the map above. In addition, there are a number of children's homes, and a growing demand to support looked after children.

6.4.20 Medway had 8.1 care home beds per 100 people aged 75+ in 2021, which is fewer than the South East average of 10.1 and England average of 9.4. The number has been decreasing in the last ten years from a high of 10.1 in 2012.^[64]

6.4.21 Good housing design is vital in promoting well-being and improving quality of life, both in general housing and in sheltered and supported housing or housing with care.

6.4.22 Housing design policy supports the need for flexible and adaptable accommodation to suit a wide range of needs to contribute to housing choice, long-term occupancy and lifelong homes.

6.4.23 Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. This is a key objective of the One Medway Plan and the Joint Health and Wellbeing Strategy.

6.4.24 The provision of appropriate housing for looked after children, people with disabilities, including specialist and supported housing, is crucial in maintaining safe and independent lives. Unsuitable housing can have a negative impact on disabled people and their carers. It can lead to mobility problems inside and outside the home, poorer mental health and a lack of employment opportunities. Providing suitable housing can enable disabled people to live more independently and safely, with greater choice and control over their lives.

6.4.25 There is a continued and growing need for specialist accommodation in Medway which is clearly indicated by the population projections.

6.4.26 Over the past five years there has been a small net gain of twenty-three bedrooms in older persons accommodation (C2). Looking forward over the next five years, extant permissions have been given for around 138 bedrooms, the majority of which is being delivered in Gillingham. Further opportunities will be coming forward over the Local Plan period.

6.5 Student accommodation

6.5.1 Promoting learning is a key ambition for Medway, and capitalising on a skilled workforce and the student economy. The Council needs to consider the needs of students as a sector of Medway's communities, in line with the NPPF in planning for specific housing requirements.^[65]

6.5.2 Positive planning for students can contribute to Medway's regeneration objectives and potentially boost the vibrancy and vitality of town centres, and secure benefits for the growth of the local economy.

6.5.3 Medway's student population has continued to grow across the further and higher education sectors, largely clustered in the Learning Quarter at Chatham Maritime.

6.5.4 However, it is important to ensure that the expansion of the sector does not adversely affect established neighbourhoods by an over concentration of students and that existing privately rented accommodation is not 'lost' to tenants with otherwise limited housing options.

6.5.5 The highest concentrations of students are seen in Gillingham North ward, representing approximately 19.9% of the resident population as this area is within close proximity to the universities and colleges.^[66] According to Medway Council tax exemptions (i.e. class N at March 2019), more than half of the student households in Medway which qualify for a student Council Tax discount are located in Gillingham.

6.5.6 Unlike some traditional student cities, evidence points to a 'not insignificant' section of students remaining living at home while studying in Medway, some commuting in from London, for example, as well as students at the Canterbury campuses being bused in from Medway, due to accommodation shortages there. The Universities, such as the University of Greenwich, are exploring the reasons why students choose to commute to Medway and are seeking to expand the accommodation and wider offer for students in Medway.

6.5.7 Students represent approximately 6.5% of the Medway population, however student households represent less than three percent of the private rented stock in Medway, suggesting the contribution of purpose-built student accommodation. The wider housing market pressures, including increased costs and demand for private sector rented accommodation impact on student households.

6.5.8 Growth in student numbers does not easily translate into a direct accommodation need for the reasons mentioned above. Evidence shows that private rental sector accommodation in Medway does not fully meet the housing requirements of students, and purpose-built student developments may be required to address these shortcomings.^[67] This could also contribute to wider regeneration ambitions, particularly for town centre renewal.

6.5.9 The policy approach ensures a sufficient supply of accommodation to meet the needs of students and support the success of the universities and colleges in Medway.

6.5.10 The proposed policy approach seeks to balance the proximity of students to their places of study and avoid over concentration of student households, where this could impact negatively on amenity or access to family housing.

6.5.11 Opportunities to increase the supply of student accommodation as part of redevelopment/regeneration schemes in town centres, particularly Gillingham and Chatham, are welcomed.

6.5.12 National policy promotes the need to supply homes where they are needed that meets the needs of groups with specific housing requirements such as students.

6.5.13 Responses to previous consultations on the emerging Local Plan have been supportive of the need to provide accommodation for students.

6.6 Mobile home parks

6.6.1 Mobile home refers to a variety of accommodation units, such as 'caravan', 'park home' or 'lodge' and can be transported from place to place. Mobile home parks refer to sites developed for the placement of mobile homes. Mobile or park homes account for around one percent of the overall housing stock in Medway, this is around twice the national average. This policy does not consider free standing individual mobile homes or caravans, such as those provided for specialist workers in the land-based sectors, or specialist accommodation for gypsy and traveller communities or travelling showpeople. Nor does it consider where provision is made in the form of temporary accommodation such as during the construction of a new or replacement dwelling.

6.6.2 Two main residential park homes estates at Hoo Marina Park and the Kingsmead Park at Allhallows account for the majority of occupied mobile homes in Medway. These are in rural coastal locations on the Hoo Peninsula, in proximity to the estuarine habitats. These park homes are a popular form of housing, particularly in some age groups, and the Council recognises that they help to provide for a choice of housing in Medway.

6.6.3 Previous consultation on this topic has generally found that there is support for this form of housing, to provide wider choice in Medway. Mobile homes are an attractive housing option for a number of households in Medway. Some cater for specific market sectors, such as people aged over 55 years. The Council supports the retention of mobile homes in these parks, to assist in the supply of a mix of accommodation.

6.7 Houseboats

6.7.1 There are approximately 462 houseboats in Medway. These are located in six marinas on the River Medway located at: Hoo, Port Werburgh, Chatham Maritime, Medway Bridge, Port Medway and Cuxton. Over the past five years the number of houseboats on the River Medway has increased by a little over thirteen percent, up from 400 in 2019.

6.7.2 Regeneration plans for waterfront development could impact on some sites. However, redevelopment plans could lead to improvements to the local environment around the areas where houseboats are located. This could lead to better access to key services for residents, in conjunction with better clustering of houseboats on the River Medway. There are wider environmental considerations, given the ecological sensitivity and importance of the river and estuary. The provision of adequate services to protect the health of the estuary is a key consideration, as well as providing for the needs of this sector of the community for good amenity and wellbeing.

Figure 5: Residential Marinas

6.7.3 Comments from earlier consultations on the emerging Local Plan have supported the proposed houseboat policy with strengthened provision for managing environmental impacts.

6.7.4 Houseboats are part of the River Medway's character, providing a distinctive housing option. It is however important to ensure that the natural environment of the river is conserved and enhanced, and residents have good living conditions.

6.7.5 Development can have a positive or negative impact on the appearance of the area and on residential amenity. It is important that houseboats do not have a negative impact upon the natural environment and should respect the unique habitat with which they are situated.

6.7.6 Medway's river and estuary are designated for their environmental importance. This policy supports opportunities to upgrade facilities and amenities where there will be no adverse environmental impacts.

6.7.7 Particular regard needs to be given to the potential environmental impacts on designated marine and supporting habitats of the estuaries and river.

6.8 Houses of multiple occupation

6.8.1 A House in Multiple Occupation (HMO) is a property that is shared by three or more tenants who are not living together as a family, and who share basic amenities such as a kitchen, bathroom or a toilet facility, but have separate bedrooms. HMOs can provide an affordable type of housing for single people.

6.8.2 HMOs have a role to play in sustainable and inclusive communities, providing accommodation for single people on low incomes, and can also be the accommodation of choice for young professionals moving to an area for work for either temporary or permanent accommodation.

6.8.3 Evidence shows that areas with particularly high concentrations of HMOs can potentially undermine the sustainability of the community, through loss of family housing, or by lowering the standards of amenity experienced by local residents.

6.8.4 Poor management of properties, disturbance and poor provision or use of waste storage facilities can lead to a low-quality feel in relation to the street environment. The Council is also concerned that people have a decent place to live, and the standards of HMOs provide for a safe and healthy environment for residents.

6.8.5 A combination of issues can lead to an area attracting a high proportion of young, single people, which may be linked to short-term tenancies and a relatively high turnover of residents.

HMOs in Medway

6.8.6 HMOs containing five or more residents require a licence. Licensable HMOs in Medway were mapped in 2021, as detailed below. Smaller HMOs do not need a licence, for that reason the total number of HMOs in Medway is not known.

6.8.7 As demonstrated in the map below, HMOs are situated in urban areas and are in close proximity to central areas of Gillingham, Chatham, Rochester and Strood. The highest concentration of licensed HMOs is located primarily within central, urban Medway, specifically areas in Gillingham and surrounding Chatham and Rochester Riverside.

HMOs and planning background

6.8.8 There is a distinction between the planning and licensing regimes for HMOs. Single family houses and flats are classified as class 'C3 dwelling houses' in the Use Class Order. Privately rented HMOs with between three to six tenants are classified as small or 'C4 Houses in Multiple Occupation'.

6.8.9 Planning permission is not required to change the use of a C3 dwelling house to a shared rented house (C4 HMO), unless specifically controlled by condition on a planning application. Planning permission is required however to increase an HMO from six to seven or more tenants. This is because large HMOs are in their own distinct use class 'sui generis'.

6.8.10 A large HMO in England is defined if it is rented to 5 or more individuals who are not from the same household. A large HMO will need a license.

6.8.11 Neighbourhoods containing transient populations can experience issues that conflict with the amenity of more settled residents within the same neighbourhood. A high turnover of residents can undermine the sense of community within an area.

6.8.12 The National Design Guidelines state that waste storage and management should be 'accessible and well-integrated into the design of streets, spaces and buildings, to minimise visual impact, unsightliness and avoid clutter.^[68] Where refuse bins are required to be on a street frontage or in a location that is visible from a street, they are sited within well-designed refuse stores that are easy for occupants to use.

6.8.13 The Council recognises the role of HMOs in providing affordable choice in the housing market, but seeks to avoid unacceptable, adverse impacts on amenity, or loss of family accommodation, through managing the development of new HMOs, and to secure decent living conditions for residents.

6.9 Self-build and custom housebuilding

6.9.1 Medway's vision for 2041 includes an aspiration that all sectors and ages of the community can find decent places to live; as part of this custom and self-building will provide new living opportunities for residents. This is supported by one of the Local Plan objectives of supporting people to lead healthy lives and strengthening communities by providing high quality, energy efficient homes that meet the needs of Medway's communities, reflecting the range of sizes, types and affordability the area needs, including provision for specialist housing, such as custom and self-build; and driving reductions in the carbon impacts of housing by securing opportunities for retro-fitting older properties.

6.9.2 Self-build is generally where the owner is directly involved with and/or manages the design and construction of their new home, while the custom housebuilding approach is where the owner commissions the construction of their home from a developer / builder / contractor / package company who builds the property to the owner's specifications. With custom build the occupants do not usually carry out any of the physical construction work but still make key design decisions.

6.9.3 National planning policy advises that authorities should include people wishing to commission or build their own homes when planning for the needs of different groups in the community.^[69] The Government has also provided additional policy and guidance to support the demand from the self and custom house building market, which advises 'in considering whether a home is a self-build or custom build home, relevant authorities must be satisfied that the initial owner of the home will have primary input into its final design and layout'.^[70]

6.9.4 To identify and provide for people who wish to build their own home, the Council maintains a Register of interested parties and reports the headline data annually on the Council website.^[71]

6.9.5 Self-build and custom build can be an important source of delivering a mix of homes; all self-build proposals in sustainable and suitable locations will be positively considered. The contribution small and windfall sites can make to providing Self-build and Custom Housebuilding plots is encouraged and welcomed; it is also acknowledged that there can be opportunities on larger sites to meet expected demand. Larger site developers are encouraged to work with smaller sized builders to promote site diversity and to offer a range of plot sizes to provide the different types of plots self-builders are looking for. This enables people to have the opportunity to build their own high-quality homes, on a range of different sized developments, which can also boost and support the local economy by providing opportunities for local tradespeople and small and medium sized builders, as well as leading to a good mix of property designs, giving the area visual interest.

6.9.6 To meet the demand on the self and custom build register and to facilitate a wide range of opportunities of different types and tenures for self/custom builders:

• Small site and windfall plot provision in sustainable and suitable locations for self and custom builders is supported and encouraged.
• Sites within Medway will be allocated/part allocated to provide self and custom build plots.
• Sites of 100+dwellings will be required to supply no less than 4% of serviced dwelling plots for sale to self or custom builders, excluding flatted developments.^[1]

6.9.7 This will provide a stream of plots on a variety of sized developments throughout the plan period. Developers and landowners may find it useful to work with a self and custom build 'enabler' for assistance in delivering the self/custom build plot element of the site.

6.9.8 Policy T9 aligns with the government's aspirations in the 'Planning for the Future' white paper, where sub-areas within 'Growth' areas for self and custom build homes are encouraged, so that more people can build their own homes.

6.9.9 The need for plots of land on which people can build their own home has been identified through the Self-build and Custom Housebuilding Register, required by legislation from 1st April 2016.^[72] Medway Council's Self-build and Custom Housebuilding Register is publicised on the website and operates in 'base years', which run from 31 October in one year through to 30 October the following year.^[73] Eligible individuals or associations (groups of individuals) can apply to go onto the Register to record that they are seeking to acquire a serviced plot of land for their own self-build and custom housebuilding.^[6]

6.9.10 From the commencement of the Register in April 2016, the Council has received regular applications from individuals and associations wishing to register their interest in acquiring a plot of land on which to build their own home. Applicants are interested in acquiring plots across the Medway area for building their own house or bungalow, with plot sizes ranging from 0.01ha to 0.2ha and above. As at 30 October 2023, there were 132 individuals and 2 associations who had applied to join the register since April 2016, resulting in an average of 18 applications per year. Around 24% of these applicants have also applied to go onto other authority registers which although could be a double-count of demand, is thought to be counteracted by numbers of people who possibly do not know about the register but still have a desire to build their own home. To date, permission has been granted for 18 self/custom build plots.

6.9.11 The Council wishes to better understand the wider level of demand in Medway, and in 2024 surveyed 44 local land/estate agents on the level of enquiries received on plots for sale. Only one agent responded to indicate any level of interest, and that was after sites were listed for sale.

6.9.12 The evidence so far shows that an average of 18 applications are received to join the register each year, which when projected forwards over the plan period and removing those already permitted to date, amounts to a need of around 430 plots. By allocating the three sites which could deliver between 20-25 plots and introducing a 4% policy on sites over 100 dwellings, this should be sufficient to provide the level of demand needed. When carrying out these calculations, we have only looked at sites over 100 dwellings which could be reasonably expected to provide self-build plots – we have excluded any that are likely to be flatted developments.

6.9.13 In order to assist landowners/developers providing plots and to gain even more of an understanding on what existing applicants to Medway's register are specifically looking for, we are also in the process of arranging for a detailed survey/questionnaire to be sent to applicants for completion before the next stage of the Local Plan – the results from this will inform and finetune the final direction of the policy.

6.9.14 Demand may shift over time, so the policy will be closely monitored and will be reviewed if the level of demand changes significantly.

6.9.15 In previous consultation, there has been support for the principle of the proposed policy, although developers were cautious about a percentage based policy approach and sub allocation of sites because of concern this could impede housing delivery.

6.9.16 Self-build and custom housebuilding policies across the UK have continued to evolve in recent years and there has been a marked increase in adopted plans with percentage based policies. Having a site partially devoted to self-build can help to balance different density requirements across a site and encourage larger house builders to work alongside smaller local house builders, with the potential to work successfully alongside the delivery of mainstream housing. These types of % policies can work most effectively as part of a package approach, which is why as well as applying a 4% requirement to sites 100+, Policy T9 also allocates specific sites for self/custom build development and encourages plot provision on smaller windfall sites, maintaining the key intention of providing self/custom build plots to meet expected demand.

6.9.17 The fundamental purpose of Policy T9 is to deliver self-build and custom build housing in Medway, but it is plausible that due to circumstances out of the control of the Council and landowner, some plots may not receive the interest that has been anticipated and are not taken up by the self and custom housebuilding market. It is important that the land is not left unused or vacant for sustained periods while other essential types of housing are needed, such as 'affordable housing'. This is reflected in the 'cascade' approach.

6.9.18 A 12 month marketing period as a minimum is considered an acceptable length of time to allow potential self/custom builders time to view the site, arrange finances and apply for planning permission to ensure that what they actually want to build on the site is acceptable.

6.9.19 Purchased plots should not be left empty to the detriment of its neighbours or the developers as a whole – however it would prove difficult for the Council to control/enforce a requirement for purchased plots to be built out within a certain timeframe within Policy T9 but instead will include a desirability for a short timeframe for builds (which could be translated into a shorter time limited condition than the standard requirement depending on the site).

6.9.20 Respondents to the Regulation 18 consultation in Autumn 2023:

• Supported a move to provide a choice and mix of homes, particularly self and custom building.
• Said that some allocations of large sites owned by volume housebuilders should have some self-build areas.
• Said that the plan should ensure smaller sites are allocated for growth to give local construction companies the chance to provide good quality, well designed and sustainable homes as alternatives to large scale uniform estates built by one national developer.
• Said that innovation in more energy efficient buildings designed to reflect local distinctiveness, is likely to be achieved in developing smaller sites in Medway's villages for custom or self-built homes.
• Showed concern that there would be considerable noise and traffic generated with longer term custom built self-build projects.

6.9.21 Policy T9 responds to these comments by offering both allocated sites and requiring larger sites to provide an element of self-build as well as supporting small windfall sites to deliver plots. Generally, self-build mortgages are more expensive than standard mortgages, so in most cases builders will be eager to complete the build expeditiously to be able to move across to a standard product as soon as possible; however as mentioned previously, where relevant there could be a condition to require a shorter time for commencement than the standard requirement for builds.

6.9.22 Rural exception sites –These will need to be considered on a site-by-site basis when there is greater certainty on the preferred spatial strategy.

Allocations

6.9.23 Fifteen sites were submitted to provide self-build plots as part of the most recent Call for Sites. The majority of applicants on the register are interested in plots anywhere across the Medway area, with the most preferred sub areas being on the Peninsula and in Rainham. Potential sites for self build have been identified, but further work will be needed on the preferred spatial strategy and site assessment to confirm if these are suitable for possible allocations in the Local Plan.

Sustainable, green and high-quality design

6.9.24 Some self/custom builders seek to be more innovative and adventurous in their design/green credentials, which the policy allows for through the use of design codes where relevant. Using both traditional and modern methods of construction, self and custom builds can often be and most certainly are encouraged to be the pinnacle of energy efficient, environmentally friendly and sustainable standards, demonstrating superb examples of what can be accomplished in both green and high-quality design.

6.9.25 Made and emerging Neighbourhood Plans in Medway are positively promoting opportunities for self and custom housebuilding development, which is supported by the Council.

6.10 Gypsy, Travellers and Travelling Showpeople

6.10.1 Medway Council is tasked with providing for the needs of all its residents including providing housing options for all that require it. Housing provision includes the consideration of the needs of Gypsy and Travelling Showpeople, which is supported by an up-to-date evidence base.

6.10.2 The Council commissioned an updated Gypsy and Traveller Accommodation Assessment (GTAA) to identify the need for gypsy and traveller pitches and travelling showpeople plots, to align with the Local Plan period, and to consider the implications of any changes to definitions or other requirements brought in since the last evidence base update.^[74] 

6.10.3 The definition of pitches and plots comes from national Government policy. A pitch for the purpose of this policy is defined as: 'means a pitch on a "gypsy and traveller" site. A plot is a: 'pitch on a "travelling showpeople" site (often called a "yard")'.

6.10.4 Planning Policy for Traveller Sites (PPTS), updated in 2023, provides a planning definition of gypsies and travellers, and the government's approach to decision making and plan making in relation to traveller sites.^[75]  The overarching aim of the national policy is to 'ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic way of life of travellers while respecting the interests of the settled community. 

6.10.5 For the purposes of the planning system, the PPTS defines gypsies and travellers as:  

Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family's or dependants' educational or health needs or old age have ceased to travel temporarily or permanently, but excluding members of an organised group of travelling showpeople or circus people travelling together as such.

6.10.6 For the purposes of planning policy, the PPTS definition of travelling showpeople is:  

Members of a group organised for the purposes of holding fairs, circuses or shows (whether or not travelling together as such).  This includes such persons who on the grounds of their own or their family's or dependants' more localised pattern of trading, educational or health needs or old age have ceased to travel temporarily or permanently, but excludes Gypsies and Travellers as defined above.

6.10.7 There are a number of gypsy and traveller sites, and one travelling showpeople site in Medway. These include one public site at Cuxton, managed by Medway Council, and a range of permanent and temporary private sites across the authority area. The GTAA identified a need of 31 pitches for gypsy and travellers and 3 plots for Travelling Showpeople, from households that meet the planning definition. There is wider need from undetermined households and those that do not meet the planning definition.

6.10.8 The NPPF requires local authorities to make provision for the specialist accommodation needs of gypsy and traveller communities and travelling showpeople. This is achieved through assessing the accommodation needs of the gypsy, traveller and travelling show person population in their area and to set pitch targets for gypsy and travellers and plot targets for travelling showpeople and demonstrate deliverable sites in the short and long-term.

6.10.9 Responses to previous public consultations raised concerns over the potential for conflict between the settled community and the Gypsy and Traveller communities. In iterative Call for Sites, few sites have been promoted for gypsy, traveller and travelling showpeople uses. The approach to intensify existing safeguarded sites is therefore most appropriate to meet the need outside of permitting new applications meeting the required criteria, however consideration will be made towards the following:

• Overcrowding.
• Accessibility and scale of local amenities to meet the needs.

6.11 Small sites and SME housebuilders

6.11.1 Small sites and SME housebuilders have a key role to play in housing delivery in Medway, and broadening the choice of housing. A five-unit threshold is considered to the threshold for a small site, while a 60-unit threshold is considered to be representative of the general threshold at which a medium sized developer may develop and the point at which sites become too small for larger regional or volume housebuilders.

6.11.2 Delivery of housing by a limited number of volume housebuilders will struggle to meet full housing needs. SME's offer the opportunity to supplement quality housing delivery and diversify the market which supports increased delivery.

6.11.3 Medway will pro-actively support well designed new homes on small sites through both planning decisions and plan-making in order to:

• Increase the contribution of small sites to meet Medway's needs.
• Support and increase SME Housebuilders and associated local businesses delivering in Medway.
• Diversify the locations, type and mix of housing being delivered in Medway.
• Support self and custom build housing developments as well as community-led housing projects.

6.11.4 In the Regulation 18 Local Plan consultation, responses showed support for small sites, particularly in rural areas. The NPPF also supports the development of small sites. Small sites can help to diversify housing options, create opportunities for smaller developers, and contribute to the overall character and identity of Medway's neighbourhoods.

6.11.5 Moreover, developing small (and medium) sites may help to make the best use of existing infrastructure and resources, minimise environmental impacts, and prevent urban sprawl. SMEs are more intrinsically linked with the local supply chain and are more likely to invest in local materials and construction, offer apprenticeships and utilise wider Kent based partners from concept through to sale.

---

---