Questions: Housing
Yes
More affordable housing needed on brownfield. Most brownfield is closer to mainline stations and other amenities. It therefore makes sense for a higher percentage of brownfield to be affordable. That said, the developers won’t like it, but it’s not up to them.
20% on both at least.
20%
20%
No idea
No.
I believe it is effective only for the current, relatively poor, Medway economy. If the local plan is made more ambitious, to encourage much more upgrading of Medway's economy to higher value industry, then the median Medway wage will rise vs. the national median, and this may permit a lower proportion of affordable housing. The mix should be subject to revision. The greater the economic ambition/success of the Local Plan, the lower the need for affordable housing. An excessively high proportion of affordable housing may limit the attractiveness of Medway for those in well paid jobs, considering relocating here.
Yes, but not for the reasons I suspect these requirements have been arrived at. I expect the biggest boost to Medway's economic productivity to come from regeneration of brownfield sites (which I do not think are "low value"), therefore I agree with the lower affordable housing requirement for brownfield development.
A thorough economic analysis of development on Medway's brownfield and greenfield sites would give much greater clarity on this. My company [REDACTED] would be happy to provide this on a non-profit basis.
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HMOs should only be permitted on a temporary basis (e.g. 6 month licenses). This would allow HMOs to be part of the housing mix for the workforce needed for the large-scale building works of the Local Plan itself, but would mean that communities cannot be permanently blighted.
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Yes
Yes
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Should be assessed against the evidenced need, we can’t impose a split that isn’t required! Build what is needed not what people comment
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I think it should be viewed as within a 1km radius. If it is excessive then it’s wrong location.
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yes
This is broadly correct, however, we must consider the importance of ensuring viability of the overall plan too.
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50% 50%, albeit noting that this requires RPs and others to deliver this.
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HMOs create issues when in clusters, in areas that don't fit the character, or whereby it substantially alters the character of the area in which they are concentrated.
Would love to see some in Rainham.
No, it leavers to many loop holes and will not be delivered effectively.
no, these figures are too low and should be increase to 20% and 50% respectively.
there should be a focus of ensure that affordable housing is provided local residents and key workers in Medway.
of the total development 25% should be for social/affordable rent and 25% should be for low-cost home ownership.
of the total development 25% should be for social/affordable rent and 25% should be for low-cost home ownership.
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The spatial option 3 is the best way forward to obtain the correct housing mix. I wish to place my objection to Site ID CHR4 Form Submission ID 253 This site was allocated for a possible new cement works at a public inquiry with the proviso that when the works were finished it reverted back to its previous usage. If a minimum of 1000 new dwellings are built on this site then Snodland and Halling are being physically joined into one urban area. To describe this as a possible housing development as " part of a larger oppotunity which includes land to the south within Tonbridge and Malling administration area. The larger oppotunity could deliver an urban extension to Snodland providing 5000 new homes, new schools, community and commercial facilities as well as exensive green infrastructure. The uploaded Prospectus describes both possibilities" While appreciating neigbouring authorities need to consult each other a 4000 new homes development to the South of Medways boundary will swamp Snodland and destroy not only Green Belt Land but will also be built on Areas of Outstanding Narural Beauty. I totally object to this proposal.
There ought to be the highest requirement for both urban brownfield sites as well as greenfield sites of 50%.
Unless the amount of affordable housing is increased throughout Medway then the waiting lists will not shorten. It may be prudent to build less in some areas but make the numbers up in other areas.
60%- 40%
At least 60% social / affordable rent to 40% intermediate/ low cost housing.
No more than 20% of HMOs in a community.
No
I am not entirely sure what the thinking (nationally and locally) is on the requirements of the people. At the end of the day, if we need to build at the scale that I believe central government are looking to do, the only real way of doing that is to create whole new towns akin to Milton Keynes rather than a thousand houses here and there. I see lots of flats ("affordable" in the wider sense of the word no doubt) popping up near the town centres and along the river, but I don't know that anyone (on a national scale) has really been asked what they want. Presumably, our current mix is broadly in line with national requirements given the number of flats being built, and that new developments can accommodate "exec" housing, but surely given the scale of urbanisation in Medway already, there is an argument to spread that building up north, along what was the HS2 beyond Birmingham (and dare I say, into Scotland too).
Not specifically. I think it depends on the development in question as to what is sensible. You'd not build 10 5 bed exec houses on the river front in favour of 50 flats for instance (or vice versa). I think the infrastructure is more of a key requirement in Medway - plenty of flats have been (and are being) built already and presumably, by definition, they should be more affordable than a detached house with a garden. My view is that if it's greenfield, it's not built on full stop. Medway is as populated as London in parts (and without the huge royal parks etc or infrastructure).
As above - site by site approach - but why not force the developers to pay proper contributions towards affordable housing (so that derelict properties, or for that matter those shops that are in our dead Gillingham High Street for example can be bought up and made into affordable housing - for local people). Seeing certain London council vans parked up around Medway, they may be people living here and working in London, but they may also be picking up local affordable housing for their own requirements?
The first thing to do is to ensure that any affordable housing that exists (or is created) isn't picked up by London councils for instance. I think council houses (for local people) are an often overlooked thing more generally - particularly near to infrastructure (such as shops and reliable transportation).
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I suspect HMO's have their place, but if you allow them in areas with already limited parking or without decent transport links (so people can arguably go without a car - potentially replaced by a Zipcar type solution?), you will put undue pressure on surrounding houses/people.
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What consideration is given to unforseen changes in the dynamics of Medway population.
No; percentage is too high for greenfield and urban locations.
More consultation for residents and request for residents proposals.
Greater priority to intermediate/low cost housing.
Depends on the area in consideration and existing residents views.
Yes; there should be limited HMOs in a community.
Limited greenfield sites
[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.43 The supporting text to Policy T2 states that the housing mix is informed by the Local Housing Needs Assessment (2021) and that the Council will update this evidence before finalising the Plan to accurately reflect needs. This is considered the correct approach to ensure the policy is informed by the most up to date evidence and Catesby Estates awaits this information before commenting further. 3.44 In addition, given the Council’s preferred option for growth is a blended strategy, the policy should also allow for considerations pertaining to local market and demand, to ensure there is a correct understanding on what is appropriate in urban areas vs suburban/rural areas. This flexibility is important as urban needs will rarely align with suburban/rural needs.
[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.45 Policy T3 requires different levels of affordable housing based on the value of the area within which a particular site sits. This is 30% provision in high value areas and 10% provision in low value areas, said to have been informed by the Local Plan Viability Assessment. 3.46 The Local Plan Viability Assessment (including CIL) – December 2021 concludes that the Residual Value on the greenfield typologies assessed is above the Benchmark Land Value. Paragraph 6.3.11 states: “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.” 3.47 The cost implications of delivering strategic sites which accord with the Council’s vision, for example, providing increased areas of open space, biodiversity net gain and access to sustainable transport corridors, will also need to be considered. 3.48 The Council includes the opportunity to provide a viability assessment to justify a lower provision, which is considered a sound approach in order to provide a mechanism to consider this on a site by site basis. 3.49 It is also noted reference is made to a 2022 Viability Assessment, which is not included within the consultation evidence base.
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[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.50 The split of tenures should be informed by up to date housing needs assessments or SHMA. Flexibility should also be incorporated into the policy to allow for the changing circumstances/demand across the Plan period and for differing individual site characteristics.
[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.51 Catesby Estates considers that there may be occasions where onsite provision of affordable housing is not suitable or viable and so mechanism for securing off site affordable housing is considered acceptable. 3.52 In relation to the cascade principle, Catesby Estates supports the provision that local people in need of housing in their local area should have first refusal on new affordable housing and that where surplus affordable housing remains, this should then be allocated based on the Council’s housing needs register.
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[TO BE READ ALONGSIDE FULL REPRESENTATIONS SUBMITTED TO THE COUNCIL ON 06/09/24] 3.53 Catesby Estates notes the inclusion of its land (site AS22) within Policy T9: Self-build and Custom Housebuilding, for the provision of 5% of the dwellings proposed. This is supported in principle, provided there is an identified need. 3.54 Policy T9 states that the landowner/developer is required to market the plots available for self/custom-build for a minimum period of 12 months. The policy then states that if any plot(s) remain unsold after being marketed for this 12 month period, they can either remain for sale as a self/custom build plot or be offered to the Local Authority to acquire for the provision of affordable housing (separate from any relevant affordable housing requirement for the Development as applicable), before reverting back to the land owner to build out on the plot or sell without restriction. To prevent the delay of housing delivery, the Local Authority will be given a time period of three months to acquire the vacant plot(s). 3.55 Whilst this mechanism is well considered, should plots not be required by self-builders or the Council, the policy effectively places a pause on these plots for 15 months, before they revert to the landowner/developer. The Council should consider whether this is feasible for the developer to return to these plots after this period has elapsed. It is considered a 12 month period for both self-build and Local Authority interest may be sufficient. 3.56 The policy is also designed to cater for self-build need, therefore the ability for the Council to secure these plots for affordable housing will need to considered in further detail. For example, how will this relate to the construction of the wider site?
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7.5 CCE support the importance given in the Reg 18 B Plan to affordable housing, it being a ‘key priority’. CCE’s strategic landholdings provide the opportunity to make a significant contribution to affordable housing in Medway. There is a need to provide the right homes in the right places to meet Medway’s growing affordable housing needs. Policy T3 Affordable Housing proposes 30% affordable housing in ‘high value areas’ including the Hoo Peninsula and suburban greenfield sites. The policy states: ‘A viability assessment in line with national policy and guidance should be submitted to the Council to be independently verified if the affordable housing proposed does not meet that which is required.’ The policy should be amended to make it clear that, should the viability assessment demonstrate the requirement for affordable housing is not achievable, then a lower level could be acceptable. 7.6 On Tenure mix, Policy T3 refers to ‘49% affordable home ownership, including First Homes’. Medway will be aware that the Government’s proposed changes to the NPPF (2024), would remove the requirement for ‘First Homes’. Should this change be published within an updated NPPF towards the end of the year, the Regulation 19 Plan will need to be updated accordingly. 7.7 In addition, the Policy refers to the ‘Local Plan Viability Assessment’, which was undertaken in 2022. An updated Viability Assessment will need to be prepared and published with the Regulation 19 consultation later this year, and Policies reviewed in line with this document to check the 10% and 30% requirements remain achievable.
Support the importance of delivering Affordable Homes in Medway. CCE’s strategic landholdings provide the opportunity to make a significant contribution to affordable housing in Medway. There is a need to provide the right homes in the right places to meet Medway’s growing affordable housing needs. An updated Viability Assessment will need to be prepared and published with the Regulation 19 consultation later this year, and Policies reviewed in line with this document to check the 10% and 30% requirements remain achievable.
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7.6 On Tenure mix, Policy T3 refers to ‘49% affordable home ownership, including First Homes’. Medway will be aware that the Government’s proposed changes to the NPPF (2024), would remove the requirement for ‘First Homes’. Should this change be published within an updated NPPF towards the end of the year, the Regulation 19 Plan will need to be updated accordingly.
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There should be no required housing mix so no
No all housing should be on brown field sites
No green fields should be built on, that's more effective
What? That question is just gobbledy gook and makes no sense
Again that makes no sense
Not really no
Brown sites
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In response to question 14, the adopted Arches Chatham Neighbourhood Plan defines the threshold for an over-concentration of HMO as: ‘20% HMO on the road of the planning application, ensuring that only 1 out of a consecutive row of 5 units is converted to C4. Two C4s should not adjoin and no C3 property should be sandwiched between two HMO.’ This threshold was developed by reviewing successful policies of other LPAs, such as Enfield Council and Oxford City Council. We recommend this approach and welcome any criteria that goes further.
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No infrastructure and health facilities not taken into account
No, should be no development on greenfield sites
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No infrastructure and health facilities not taken into account
No no development on greenfield
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Based on the information provided, the current policy does not effectively address the housing mix in Medway. The proposed developments often consist of small, uniform houses with inadequate space and parking, which fail to meet the needs of the growing and changing population. Many new houses are priced beyond the reach of local residents, given the average salary in Medway, leading to affordability issues. Additionally, the lack of suitable housing for the elderly and insufficient facilities highlight that the policy does not adequately cater to diverse housing needs. A more comprehensive approach is needed to ensure a balanced and sustainable housing mix that truly benefits the community.
I have reservations about the proposed requirements for affordable housing. While a 10% requirement on urban brownfield sites may reflect the need to balance development pressures with affordability, it may not be sufficient given the high demand for affordable housing. The 30% requirement for greenfield sites and higher value urban locations seems more appropriate but still may not fully address the affordability crisis, especially in areas where housing costs are high. To truly meet the needs of the community, the percentages should be re-evaluated, potentially increased, and tailored to ensure that affordable housing is effectively provided across all types of sites.
An effective alternative approach would involve a more nuanced and flexible strategy for affordable housing that takes into account the varying value areas and specific needs of each locality within Medway. This could include: 1. Tiered Requirements: Implementing a tiered approach where affordable housing percentages are adjusted based on the location's market value and the existing demand for affordable housing. 2. Incentives for Developers: Offering incentives such as expedited planning permissions or financial benefits for developers who exceed the minimum affordable housing requirements. 3. Community Needs Assessments: Regularly conducting detailed assessments to understand local housing needs and adjust requirements accordingly. 4. Mixed-Income Developments: Encouraging mixed-income developments that integrate affordable housing with market-rate units to promote diversity and inclusion. By tailoring affordable housing requirements to different value areas and incorporating flexibility, Medway can better address local housing needs and ensure that new developments are more effectively balanced and equitable.
An effective split between social/affordable rent and intermediate/low-cost home ownership housing should balance immediate affordability needs with long-term home ownership opportunities. A recommended approach might be: 1. Social/Affordable Rent: Allocate 60-70% of affordable housing to social and affordable rent tenures. This addresses the urgent need for rental accommodation among lower-income households and those on waiting lists for social housing. 2. Intermediate/Low-Cost Home Ownership: Allocate 30-40% to intermediate or low-cost home ownership options. This supports households who are not eligible for social housing but struggle to afford market prices, offering pathways to ownership and stability. This split provides a balanced approach, catering to both immediate rental needs and long-term home ownership aspirations, ensuring diverse and inclusive communities.
An effective split between tenures for affordable housing should consider both current demand and future sustainability. A balanced approach could be: 1. Social/Affordable Rent: 60% of affordable housing should be allocated to social and affordable rent. This caters to those in immediate need of affordable rental options, particularly lower-income households and those on waiting lists. 2. Intermediate/Low-Cost Home Ownership: 40% should be dedicated to intermediate and low-cost home ownership. This supports those who are not eligible for social housing but still need assistance to access home ownership, thus encouraging long-term housing stability and community integration. This distribution ensures that both rental and ownership needs are addressed effectively, promoting a well-rounded approach to affordable housing.
Defining limits to the over-concentration of HMOs (Housing in Multiple Occupation) in a community is crucial for maintaining residential balance and ensuring quality of life. Recommended criteria for managing HMO concentrations include: 1. Proportion of HMOs: Limit the percentage of HMOs within any given area or street, ensuring they do not exceed a certain threshold (e.g., 10-15%) of total residential properties. 2. Distance from Schools and Family Areas: Restrict HMOs within a certain distance from schools, parks, and family-centric areas to minimise impact on local families and children. 3. Impact on Local Services: Evaluate the effect of new HMOs on local services and infrastructure, including waste management, parking, and community facilities, to prevent strain on existing resources. 4. Community Feedback: Incorporate feedback from local residents regarding the perceived impact of existing HMOs, considering their views in policy decisions. These criteria help to manage the balance between different types of housing and maintain community cohesion.
Based on the information provided, I don’t have specific sites to promote for self-build allocation. However, I would recommend focusing on identifying and promoting: 1. Unused or Underutilised Land: Sites that are currently vacant or underused, especially those in more central or accessible areas within Medway, can be ideal for self-build projects. 2. Brownfield Sites: Repurposing previously developed land that may not be suitable for large-scale housing but could be ideal for individual self-builds. 3. Smaller Plots in Urban Areas: Areas where infrastructure is already established and where self-builds can integrate into existing communities. 4. Community-Initiated Projects: Engage with local groups or communities who might have identified potential sites for self-build developments. Focusing on these types of sites ensures that self-build allocations are practical, beneficial, and align with community needs and infrastructure capabilities.
I think this policy requires further consideration but provides a starting point.
I'm not sure a varied approach will be effective. What makes the council think that those in need of affordable housing would be less likely to want to live in the urban setting? Is it that the urban setting close to transport links would encourage more people from outside the area? Surely this would create a bedroom community offering little in the way of advantages for Medway.
I think any new housing should be offered to those living in Medway for at least 3-5yrs so that those residents are not forced out of the market by buy to let landlords and/or those migrating from other areas of Britain. There are too many people being ousted from London by either London councils or for financial reasons who are taking new builds and not giving locals a chance. This also increases the local population and so the housing need is never met unless existing Medway residents leave the area.
It is known that the current rental market is out of control. Monthly rents far outstrip mortgage repayments therefore I think a split should reflect this. Once people are submerged into the rental market it is unlikely they will ever be able to transfer to home ownership. More home ownership might have the effect of bringing down the cost of buying a home; adding to the rental stock would not necessarily have the same effect. Buy to lets should be restricted, council tenancy increased, home ownership increased.
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I think there are too many HMOs in existence in Medway. There appear to be high concentrations in the more deprived areas of the Towns. Those I have known living in these accommodations (some of which have been professional people waiting for more permanent accommodation) do not feel safe in their own home, often saying that there is high drug usage, a high number of the disenfranchised and a high number of unscrupulous landlords. No-one should live this way. HOs should be not be encouraged but if they are allowed should have an overhaul in the regulations governing HMOs and a percentage of concentration in areas set so that whole streets, or group of streets,are not given over to HMOs often making them 'no go' areas for other residents. I myself have stood alone on one of these streets waiting for someone and I immediately felt unsafe and phoned for help.
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The guidance can only be effectgive if after following it, it results in being able to access the housing solution that you require. Otherwise it is just written guidance. It may outline the Mix, but are they available. If I follow the guide will I get the plot I desire. Guide with no outcome is pointless.
Many of the greenfield areas tend to be a bit more remote, in terms of access to schools and transport and amenities. Would it be wise to put affordable housing in these areas. I'm just thinking that it would probably young families who cannot go to the oppen market to purchase. I also think that building on greenfield should be ecofriendly and blend into the scenery ie not turn it into a concrete jungle, but larger plots which can maintain a lot of the greenery.
The greenfield should be larger plots, maybe oak framed building to blend back into the environment and keep the greenery. They definately should not be any multible living like apartments. It appears that affordable housing would probably fit better elsewhare.
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Don't know and do not want to give arbitrary answers
The answer is to make more houses that people can access and make more plots available so that people like myself can build and free up the one that I am currently in. People live in HMO's because they cannot afford a whole house for themselves. Nobody wants to live with people that they do not know. When you put the limits, where do people live. I do not agree with limits with no alternative.
No, But I am wondering what land the Council has that they are not using. I am also wondering if the Council has looked into what sites utility companies may have in Medway that they have forgotten about. Maybe out on the Hoo peninsula.
No. We don't need any more high rise blocks of flats.
No. It's a bit too simplistic. Why not allocate these as the minimum affordable housing but retain the ability to require a higher proportion. Also, affordable housing should be houses not flats so that people can't be hit with excessive leasehold or maintenance charges. Obviously this impacts on the amount that developers can borrow against the development that's just the way it works but some corporate social responsibility wouldn't go amiss
No this is a terrible approach that will create pockets of deprivation
Ideally people should have the opportunity to buy their own homes because there is no security for renters at the moment. Realistically, shared ownership is the only way they will be able to afford to buy.
20%/80%
HMOs are cash cows for their owners so they should be made to meet standards of safety, health and maintenance.
No
No, this needs to be more balanced with the affordable housing and housing for purchase at higher prices.
No this needs to be higher.
Urban brownfield sites should have 30% and greenfield or high value sites should have 50% affordable house, ensuring local houses for local people, reducing the available of large numbers moving from inner London to Medway.
Leasehold properties should be excluded as this is additional charges on household for services which are usually covered in the council tax bills. Housing association properties should constitute 60% of the affording housing with the rest being made up of part buy part rent accommodation.
Leasehold properties should be excluded from any developments as they often charge high ground rent and service charges for things covered by council tax. The split should be 60% for housing associations and the rest for low cost part buy part rent properties.
Having more than 5 within an area of 3 mile radius from others
No