High Halstow Neighbourhood Plan - Regulation 16

Ended on the 30 April 2023

7. Place Quality

Image of house covered in plants

Objective 02:

To preserve and improve sympathetic access to existing green spaces and further provide additional green spaces within the developed environment.

Objective 03:

To maintain and enhance the strong sense of community and maximise the opportunity for engagement.

Objective 04:

To keep High Halstow a rural village.

Objective 05:

To maintain and develop High Halstow as an area rich in history and natural beauty, as well as supporting local leisure and tourism opportunities.

Objective 07:

To provide a sustainable environment for the residents and wildlife of High Halstow whilst being mindful of conserving an ecological balance.

Objective 09:

Housing should be relevant to community need and sympathetic to local styles

High quality design

7.2 Good design has a major role in contributing to quality of life and creating attractive, livable places. This goes beyond the look of buildings and considers: the mix of uses and activities that help create lively and interesting places; the local character and distinctiveness of a place, reflected through its landscape and building materials for example, contributing to healthy lifestyles by making it easy for people to move on foot and by bike; fostering a sense of community through well designed, functional and attractive public spaces; and enhancing the quality of environment.

Concept plan for PLACE QUALITY. A design-led approach to development, supported by Design Review, and responding to the landscape setting. Encourage innovation, places of character and architectural variety - support running of architectural competitions. Protect and enhance the sensitive setting of statutory and local heritage assets. Support a range of house types and sizes, including long-life, loose fit homes, self-and custom build, with associated plot passports, and homes to Passivhaus standards or similar. Left of image is map showing highlighted areas summarising aspirations for design quality in High Halstow to create areas of character in harmony with the whole.

Figure 18: Indicative concept plan showing summary of aspirations for design quality in High Halstow (image source: Google Earth)

7.3 The achievement of high quality design is a core principle of the NPPF. It states, at paragraph 126, that 'good design is a key aspect of sustainable development, creates better places in which to live and work and helps makes development acceptable to communities'. The importance of the design of the built environment and its contribution to making better places for people is emphasised. It goes on to note that 'Neighbourhood planning groups can play an important role in identifying the special qualities of each area and explaining how this should be reflected in development' (paragraph 127).

7.4 In short, good design will help create high quality, safe and successful places where people enjoy living, working and visiting. This is emphasised in the National Design Guide54, which should be referred to by all involved in the planning system when shaping, responding to and considering applications for planning permission. This recognises the importance of local character and the role of the community in the design process. It states (at paragraph 17) that:

'Local communities can play a vital role in achieving well-designed places and buildings and making sure there is a relationship between the built environment and quality of life'.

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Figure 19: Street scene showing recent housing development in High Halstow

7.5 Alongside and in support of this Neighbourhood Plan a Design Code has been prepared. This sets out design guidance, principles and codes for development that may come forward over the Plan period. The codes are informed by an understanding of the local characteristics and qualities that define the area and the qualities that future development should respond to.

7.6 The design code provides a point of reference for design standards in High Halstow. It is expected that all new developments will follow the guidance contained in the Design Code and that applicants will demonstrate how they have taken account of them. This approach is in line with proposed changes to the planning system which emphasise the importance of design and role of design codes55.

7.7 Within the framework of the High Halstow Design Code innovative design, which raises the standard of design in High Halstow, but which also promotes and reinforces local distinctiveness, is welcome. This includes the use of contemporary design approaches where they respond positively to context.

7.8 Architectural competitions are encouraged, providing interest and variety whilst reflecting the key qualities and design cues identified in the High Halstow Design Code and reflecting principles established in Building for a Healthy Life56. Such an approach is particularly supported on proposals for larger schemes and where the scheme can be broken down into different parcels or phases, each creating their own character.

Project / Aspiration HH PQa: Architectural variety and innovation

  1. Site promoters and developers are encouraged to run architectural competitions that lead to variety and interest whilst responding to the positive characteristic features of High Halstow outlined in the High Halstow Design Guide.
  2. Where larger schemes are capable of being delivered in phases and or include several development outlets, support is given to use of multiple architectural practices, each leading on the design detail for one parcel or outlet, but operating within an overarching masterplan for the site that establishes key principles, such as layout, connectivity and green infrastructure.

Policy HH PQ1: Design

  1. Proposals for new development will be expected to respond positively to the setting and character of High Halstow, and reflect the guidance and principles outlined in the High Halstow Design Code (Appendix 4).
  2. Proposals for new development shall meet the following criteria:
    1. Design-led approach: All development should take a design-led approach underpinned by good design principles and reflecting a thorough site appraisal.
    2. Context: Development should create a positive relationship between the site and the existing built-up area, including use of materials and architectural details.
    3. Plot width: Plots should be of sufficient width so as not to cause overlooking and to allow for the separation between dwellings to a scale that reflects the positive character of the immediate vicinity and rural setting of the parish.
    4. Building Line: Where the set-back from the road or pavement of existing buildings is a feature of the area, new development should respect that building line.
    5. Visual separation: New buildings must have similar spacing between buildings to that commonly found on the street frontage.
    6. Building height: New buildings should reflect the height of existing buildings in the immediate vicinity.
    7. Daylight and sunlight: New buildings should not adversely affect neighbouring properties by seriously reducing the amount of daylight available.
    8. Boundary treatment: Boundary treatments along the frontage of the scheme should reflect the immediate area.
    9. Access: Applications for infill developments must have direct access to the highway.
  3. Applicants are required to demonstrate how proposals for development have been informed by the guidance within the Design Code and guidance set out in Building for a Healthy Life.
  4. Development proposals that establish bespoke design solutions and residential typologies that demonstrate an imaginative sense of place whilst respecting the local context are actively encouraged.

Heritage assets

7.9 High Halstow has been occupied since at least the iron age. The Parish Boundary of High Halstow includes several important historic features, some listed and some not. The village was established in the Saxon period, with the historic core of the village found in the area round the Church of St. Margaret and The Red Dog Public House. Both are listed buildings. The Church is a Grade I listed building thought to date from the thirteenth century, remodelled and enlarged in the fifteenth century. The Public House is Grade II listed. In addition, the Halstow Marshes Decoy Pond is a designated Scheduled Monument. It dates from the late seventeenth century and is a very rare example of a well-preserved, near complete duck decoy and the only surviving example of such in Kent.

7.10 Very close to, but just outside the parish boundary, are the remains of the Cooling Radio Station57, which was constructed in 1938 as a short wave radio station and housed 'Multiple Unit Steerable Antenna'. This system was the most advanced and last major technological development in the short-wave communication era. Other than Cooling, there were only two other radio stations built in the world using this system. The Radio Station was used as a means to find and track U-boats in the Second World War.

7.11 Policies set out in the NPPF and Medway Local Plan in respect of listed buildings and designated heritage assets apply for proposals impacting on them. In addition, non- designated heritage assets in the parish shall also be protected and enhanced. Shade House (Figure 20) is particularly significant to the history of the area and is identified in this Neighbourhood Plan as a non-designated heritage asset.

7.12 Shade House was built in the eighteenth century specifically to aid the landing of contraband associated with smuggling activity that was once rife in the area. The windows of this box-like building all face inland, which enable good views of anyone approaching the building. The building is isolated within the marshes, reflecting the malarial conditions once prevalent in this area. Further information is provided in Appendix 5.

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Figure 20: Shade House, Halstow Marsh. Source: http://highhalstow.org.uk/our-village/

7.13 The area also has a strong aeronautical connection. Amy Johnson, the first female pilot to attempt a solo flight between Britain and Australia crashed and passed away in the Thames Estuary. Geoffrey de Havilland, testing the Swallow aircraft also crashed in the area, with the wreckage of the plane landing in the mud at Egypt Bay. There are also thought to be the remains of one or several Spitfire planes in High Halstow. All have significance as part of the history of High Halstow.

Policy HH PQ2: Non-designated Heritage and Archaeological Assets

  1. Development proposals affecting non-designated heritage assets and their settings within the Parish Boundary shall be permitted only if they protect and enhance the historic or architectural interest of the asset and their settings. Shade House, on the High Halstow marshes, is specifically identified as being of importance in respect historic smuggling activities in the area and is a non- designated heritage asset.
  2. Where the remains of any military or other plane crashes are discovered they shall be excavated in line with best practice and records of the damage recorded and published.

Land to the east of High Halstow

7.14 Land to the east of High Halstow is likely to be allocated in an emerging Medway Local Plan for the development of new homes and supporting community facilities. This is reflected in the Hoo Development Framework58 and linked to delivery of new road and rail infrastructure through the Housing Infrastructure Fund awarded to Medway Council. Until such time as the new Medway Local Plan is adopted, with the site allocated for development and the required infrastructure delivered to support development, the site continues to be considered unsuitable in principle for large scale development, on account of its poor transport link, the loss of open and productive high quality agricultural land and the absence of necessary and essential infrastructure. Applications for large scale housing development will be considered premature ahead of the new Medway Local Plan being adopted.

7.15 Land identified for growth immediately adjoins the eastern edge of the village and is bound to the north by Britannia Road, to the south by Christmas Lane, and to the east by Sharnal Street and Fisher's Wood. Britannia Road and Christmas Lane comprise the main points of entry into the site, though both these roads are narrow and currently lack provision for pedestrians and cyclists. The topography of the site slopes towards the east. The site presents a number of opportunities that should be reflected in its design and layout.

7.16 Opportunities for improvement, for High Halstow as a whole, will include:

  • Provision of new community facilities and amenities, including new school places and health facilities, to serve High Halstow residents, and which are accessible to and well-integrated with the existing built-up area. Such facilities should be located in the village centre or, where this isn't possible or practicable, in close proximity to the existing community.
  • Presence of landscape features that give character to the site and which could be connected with the existing village and wider countryside through a network of green infrastructure.
  • A network of ditches which present opportunities to integrate SuDS.
  • A network of footpaths existing across the site which can form the basis of links with the existing village and towards the new railway station to the south of the Parish.
  • Improvements to the movement network that provide opportunities for people to walk and cycle.

7.17 In the event that the site does come forward it should meet the principles of sustainable development, achieve architectural and design excellence, and protection and enhancement of the local ecology.

7.18 Development on the site should aim to minimise and mitigate negative impacts on the rural setting as far as possible and seek to maximise the opportunities that benefit the community as a whole. Existing site features should be incorporated within the site and inform a landscape and design-led approach to development, creating usable green space for leisure, recreation and biodiversity purposes. The provision of new community facilities required by the scale of development will help support the quality of life but should be located to maximise accessibility and use by all, strengthening community cohesion. It is important that such uses complement the existing village centre at the heart of the village.

7.19 The scale of growth and rate of delivery will likely see a phased approach to development, with multiple outlets being developed in parallel. Architectural variety is encouraged, with a mix of housing types and products delivered.

7.20 Future development of the site has been subject to a workshop facilitated by Design South East (March 2021) which recommended that proposals for land to the east of High Halstow should:

  • Be set in the context of wider growth proposed across the Hoo Peninsula and show how links can be made between the site and proposed new railway station to support aspirations for increased movement by active travel modes.
  • Respond to the existing settlement pattern, built form, landscape and rural setting, showing how this is reflected in a place-specific masterplanning response.
  • Ensure maximum connectivity and permeability between the site and existing village, such that it is well-integrated with and becomes part of the village, optimizing connectivity to and the viability of the village centre.
  • Develop a varied street typology to define character and identity, and thus housing typologies and densities in different parts of the site.
  • Design green spaces such that they can be actively used, follow desire lines and provide for a range of recreational uses, including opportunities for play and growing (e.g.: allotments) spaces.

7.21 Key principles to which growth should conform to are set out in Policy HH PQ4. This should be read in conjunction with all policies in the Neighbourhood Plan and which apply equally to land east of High Halstow.

Policy HH PQ4: Land to the east of High Halstow

  1. Applications for development of the site will be considered premature ahead of the new Medway Local Plan being adopted and HIF strategic infrastructure being in place.
  2. A comprehensive masterplan for land to the east of High Halstow shall be prepared prior to the submission of a planning application. The masterplan shall be for a residential-led mixed-use development, with supporting facilities to include a new primary and pre-school. The masterplan shall indicate the location of such uses and provision, either on or off-site, of these, as well as new health facilities and other supporting uses, including a café. Provision of an employment hub is required. The proposed layout and spatial distribution of uses should integrate well with the existing built-form and strengthen the centre of High Halstow.
  3. The masterplan shall take a landscape-led approach to design, responding to the character and setting of the site. It is expected that the masterplan and associated proposals for development shall be based on delivery of bespoke housing types that add to local distinctiveness and positively contribute to the identity of the village.
  4. Development on land to the east of High Halstow should have a sensitive and well-developed relationship with the surrounding countryside at the edge of the site, linking of spaces within the site to the countryside, landscaping within the site, and building form. It should relate well to transport infrastructure, providing access to the surrounding countryside and urban areas by a range of modes and with excellent links to the proposed railway station
  5. The following principles shall be incorporated within the proposals for development on land to the east of High Halstow:
    1. Development shall be integrated into and relate well to the existing Village of High Halstow, strengthening the separate identity of the village as a rural settlement and contribute positively to its distinctive character. It will incorporate a clear and substantial landscape buffer between High Halstow and the Ratcliffe Highway with extensive tree planting and enhancement of the landscape character.
    2. The masterplan shall identify a series of character areas, each with their own identity and a place within a hierarchy of development, which bring richness in design through variety and interest. The use of standard house types is not encouraged. The Character areas shall respond to the overall spatial framework created by the masterplan but allow for each to be designed by different architects or developers. The running of design competitions for different character areas or development parcels is strongly encouraged.
    3. Housing growth will be supported by delivery of community facilities including new pre and primary school places. New primary school places will be delivered either by way of expansion of the existing primary school or delivery of a new primary school on the growth area. Where a new school is provided this should be located in close proximity to the existing village area.
    4. A network of permeable and well overlooked streets, walking and cycle routes shall be provided across the growth area, with all homes in easy walking distance of community facilities and green space, including play space. Cul-de-sac and backland development shall be avoided. Parking shall be unobtrusive and respond to good urban design and placemaking principles. A mix of housing types set around pedestrian and cycle friendly streets and spaces, including mews type streets, play streets and homezones shall be provided. A central route through the site which can incorporate bus movements shall be provided. Wherever possible, bus stops should be located so that all residents are within walking distance of a bus stop.
    5. Existing footpaths shall be extended through the growth area, providing an integrated movement network allowing ease of access by foot and bicycle between the growth area, village, Sharnal Street and new station. Safe crossing points shall be provided along the A228 Ratcliffe Highway and delivered at the outset of development. Equally, safe junctions into the site shall be provided at the commencement of development.
    6. Segregated cycle lanes shall be provided to support safe movement, both within the growth area and along Christmas Lane and Britannia Road.
    7. The biodiversity of the site shall be maximised, including the retention of mature trees and provision of open spaces with enhanced biodiversity, including wildflower meadows and new tree planting. A mix of green spaces shall be provided, including a central green space providing a focal point within the new growth area, and which connects with the existing network of green infrastructure. Allotments shall be provided on site and within walking distance of all new homes. New tree planting shall take place within the site, including along new streets, increasing the canopy cover and responding to the existing character of the village with the built form nestled within the landscape.
    8. Sustainable urban drainage systems (SUDs) should be fully incorporated within the site and integrated with the existing network of ditches and provide a series of north south corridors as part of the network of on-site green infrastructure. SUDs should be multi-functional delivering a range of environmental benefits, adding character and enhancing biodiversity.
    9. Proposals for public art will be supported and encouragement will be given for a percent of the development costs to be allocated for public art. Proposals for public art will be subject to consultation and are expected to contribute to the local distinctiveness of the village and its wider landscape.
  6. The masterplan should respond to the guidance outlined in the High Halstow Design Code. Applications for the development of the site should be subject to the submission of a comprehensive Masterplan for the site and its surroundings, including any off site infrastructure, which should provide the layout of the site and the associated highway, pedestrian, cycle and public transport links and improvements, and any other "off-site" facilities and provision.
  7. It is expected that a Green Travel Plan will be prepared as part of the application material, demonstrating how transport measures within the proposed growth area will contribute towards achievement of zero carbon development.
  8. It is expected that the masterplan, subsequent planning application and any associated design codes will be subject to design review. The panel should include representatives nominated by the local community.

Design review

7.22 The NPPF states (at paragraph 133) that Local Planning Authorities should have access to and make use of tools and processes to assess and improve the design quality of development, including making use of design review arrangements.

7.23 Design review is a way of assessing the design quality of new developments by an independent panel of experts to support high standards of design. Guidance on the Design Review process can be found via the Design South East website59. The requirement for design review shall be determined by Medway Council.

7.24 In High Halstow, it is envisaged that major applications for development, as well as smaller schemes in sensitive or important locations, should be subject to design review. This might include residential, commercial and mixed-use development proposals, infrastructure, community facilities, public realm and open space proposals.

7.25 Design review should take place at the pre-application stage to inform the design process and again following submission of the application, helping to inform officer recommendations. The final proposals submitted should show how comments made during the design review have influenced the proposed development.

Project / Aspiration HH PQb: Design review

  1. Emerging schemes for major development should be assessed through design review. Design review of smaller schemes is also encouraged, including those in sensitive or important locations.
  2. It is envisaged that schemes will be referred to Design South East for review until such a time that Medway Council runs and operates a Design Review Panel.
  3. Encouragement is given to early engagement with the Design Review panel, allowing scope for input into emerging designs. The final schemes submitted to the Council should include a report on the design review process and show how the scheme has responded to this. Design Review of live applications is also encouraged.

Housing mix and type

7.26 Proposals for new development will need to be cognisant of the housing mix and needs established in the Medway Strategic Housing Market Assessment (SHMA)60 2015. This is a high level document that has strategic headlines for the authority area as a whole, noting that approximately half of all new homes should be two-bed properties.

7.27 Although Policy H2 of the emerging Medway Local Plan does not digress into specified thresholds of different types and sizes of houses that are required in large development sites, Policy H3: Affordable Housing does outline that on housing and mixed use development sites of 15 or more residential units the Council will require the delivery of affordable housing. These requirements are; in rural Medway 30% of all residential units of developments of 15 or more dwellings and in urban Medway 25% of all residential units of 15 or more dwellings. As such, in High Halstow, all development sites of 15 or more dwellings shall be required to provide 30% of these as affordable homes.

7.28 The Government has also recently published the 'First Homes' Planning Practice Guidance61, requiring a proportion of all new homes on major sites to be available for first-time buyers at a discounted price and that, in the first instance, these should be available to those people who are in need and can demonstrate a local connection to the area. The Neighbourhood Plan supports delivery of new homes in line with the principles of the 'First Homes' product. For High Halstow, local connection refers to those whom:

  • Have chosen to live in High Halstow and have done so for three of the last five years, or
  • Have immediate family (parents, children or siblings) who live in High Halstow and have done so for at least five years, or
  • Have regular employment in High Halstow.

7.29 In addition to matters of affordability, the aging population of High Halstow manifests itself in challenges for the housing market, with a need for housing for the elderly to be provided. The Medway Village Infrastructure Audit as well as the Kent and Medway Growth and Infrastructure Framework point to a significant increase in the proportion of population aged 65 plus in coming years. Where established in evidence to the emerging Medway Local Plan, proposals for housing in High Halstow should incorporate homes for senior residents. This is reflected in feedback from the community, with consultation responses noting a need for smaller properties for first time buyers and opportunities for older residents to downsize.

7.30 Planning Practice Guidance62 notes that there are a variety of specialist housing types that can meet the needs of older people. This includes, but is not limited to, (1) age- restricted general market housing, (2) retirement living or sheltered housing, (3) extra care housing or housing with care, and (4) residential care homes and nursing homes.

7.31 Housing for the elderly in High Halstow should ideally offer easy access to community facilities, services and good public transport. The design of homes for the elderly should reflect the principles of inclusive design outlined in Planning Practice Guidance63 and those established in the HAPPI (Housing our Ageing Population Panel for Innovation) report64 which are applicable to housing for elderly people and age- friendly places.

Policy HH PQ5: Housing type and mix

  1. New housing within High Halstow will be supported where the following criteria are met:
    1. The size and mix of the housing units and tenure of the affordable housing units must, where viable, be consistent with the most up-to-date evidence of housing need.
    2. Subject to Local Plan thresholds for the provision of affordable housing, the scheme must provide the maximum viable amount of affordable housing.
    3. All affordable housing must be designed such that it is tenure-blind, i.e.: of an equal quality in terms of its design and use of materials compared to the market element and it should be well integrated into the overall proposal.
    4. At least 25% of all affordable homes delivered as part of a development shall be First Homes. In the first instance (a period of three months) these will be made available to those able to demonstrate a local connection to High Halstow, defined as:
      1. People in need of affordable housing who have chosen to live in High Halstow and have done so for three of the last five years, or
      2. People in need of affordable housing who have immediate family (parents, children or siblings) who live in High Halstow and have done so for at least five years, or
      3. People in need of affordable housing who have regular employment in High Halstow.
    5. Where there is an up-to-date evidenced need, the proposal should provide units suitable for senior residents. Such housing provision should be located in easy access of shops, facilities and public transport services. Housing should be well-integrated within the wider neighbourhood and be designed in accordance with the HAPPI principles.
  2. Proposals for new loose-fit, flexible residential typologies that respond to changing lifestyles and demographic life cycles, will be supported. This includes the ability for people to work at home separate from the main living space, as well as opportunities for multi-generation homes that enable part of the home to be subdivided as a separate stand-along unit with its own entrance, allowing older children and elderly family members to live independently. The concept of Lifetime Homes, live/work accommodation and provision of flexible internal layouts are encouraged.

7.32 To support diversification of the housing offer and the ability of people to access a home, the Parish Council promotes opportunities for self-build and custom housebuilding within the village. The Self-build and Custom Housebuilding Act came into effect in 2015 and places a duty on certain public authorities, in this case Medway Council, to keep a register of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects. The Act places a duty on those public authorities to have regard to those registers in carrying out planning and other functions.

7.33 Currently, the Medway Self Build and Custom Housebuilding Register shows a requirement for 105 plots. This is based on the period 1st April 2016 to 30th October 2021. High Halstow accounts for just under 4% of all the total applications as a preferred location for a plot. Nationally, the interest in self and custom-build housing opportunities continues to grow, with Government data for the period October 2020 – October 2021 showing that the total number of individuals on local authority registers increase by 25% over the previous year. The number of groups on registers also grew over the same period.

7.34 In the emerging Medway Local Plan, Policy H2: Housing Mix, states that large development schemes must demonstrate that sufficient consideration has been given to custom and self-build plots as part of housing mix.

7.35 Where self or custom build plots are to be made available a set of plot passports should be produced. These will provide a summary of the design parameters for any given plot and help private housebuilders understand what they are allowed to build on the plot. They capture key information from the planning permission or the site, design constraints and procedural requirements. The passports clearly show permissible building lines within which the new dwelling can be built as well as height restrictions and other details such as parking requirements. Aspects such as materials, roof styles and fenestration are usually left for the plot owner to decide.

7.36 A range of housing and delivery models might come forward on the self and custom build plots, including shared delivery through collaboration. To allow for this, any area of self and custom build should be no smaller than ten plots in size. All plots should also be connected to the utilities network to enable private housebuilders to plug directly into these.

Policy HH PQ6: Self and custom build housing

  1. Provision of plots for self and custom build homes in suitable locations within the village envelope will be supported. Where provided as part of development on land to the east of High Halstow the location of the plots shall be determined through the masterplanning and planning application for that site.
  2. The following criteria shall apply:
    1. Where viable, a minimum of 5% of the plots at land to the east of High Halstow shall be for self and custom building.
    2. Areas for self and custom build housing on land to the east of High Halstow should be no smaller than ten plots in size, allowing opportunities for co-housing and other collaborative delivery models to come forward.
    3. Plot passports shall be prepared by the applicant for approval by the Local Planning Authority. These will establish the form of development and building parameters for each plot, including building heights, footprint, frontages, density and parking requirements.
    4. All plots for self and custom build housing shall be provided with connections to utilities (electricity, water and waste water) and communication infrastructure.
    5. All plots must have access to the public highway.

54 MHCLG, September 2019, National Design Guide: Planning practice guidance for beautiful, enduring and successful places

55 MHCLG, January 2021, National Model Design Code (Consultation version)

56 Design for Homes, July 2020, Building for a Healthy Life: A design toolkit for neighbourhoods, streets, homes and public spaces.

57 More can be found in research published by English Heritage, Research Department Report Series no. 110-2010, Cooling Radio Station, Hoo Peninsula Kent, An Archaeological Investigation of a Short-Wave Receiving Station

58 Medway Council, September 2021, Hoo Development Framework

60 GVA & BiLFINGER. North Kent Strategic Housing and Economic Needs Assessment. Strategic Housing Market Assessment. November 2015

62 MHCLG, June 2019, PPG: Housing for older and disabled people, accessed July 2020

>63 MHCLG, June 2019, Housing for older and disabled people

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