Whilst Richborough agrees that residential development in urban areas presents opportunities for regeneration, the quantitative and qualitative needs for housing in Medway cannot be met only in these areas.
The PPG provides guidance (paragraph: 018 Reference ID: 3-018-20190722) on assessing the suitability of sites and highlights the following factors for consideration:
• appropriateness and likely market attractiveness for the type of development proposed;
• contribution to regeneration priority areas;
• environmental/amenity impacts experienced by would be occupiers and neighbouring areas.
Urban core developments are typically high density apartment-led schemes, which deliver smaller homes with limited private amenity space.
Table 6.1 of the Local Housing Needs Assessment (LHNA) (October 2021) provides the overall annual dwelling type and tenure mix recommendations and shows that 15-20% of new housing is recommended to be 1 bedroom flats and 20-25% 2 or more bedroom flats. While this shows that there is an identified need for smaller flatted development in Medway, the majority of the need remains for larger houses. These typologies clearly do not accord with town centre locations.
Paragraph 5.11 of the LHNA confirms that the expected housing choice for 65.3% of older households is to downsize. The stakeholder engagement summary provided at paragraph E9 suggests this is a desire to downsize to bungalows or small units in “community-based” developments. These identified needs do not necessarily align with significant urban area growth and would more likely be met through suburban development.
In respect of affordable housing need, Table C9 of the LHNA provides a comparison of existing affordable housing stock against annual need by bedroom numbers and it is clear that there is a particular shortfall of 4 or more bedroom affordable dwellings. Given the high density nature of residential developments in urban locations, due to land availability and viability pressures, it is unlikely that this shortfall in qualitative affordable housing need is going to be met in urban areas. Richborough is also concerned about the potential for such schemes to deliver any affordable housing at all given the possible viability issues. Further work is needed to be able to demonstrate that the affordable housing need can viably be met at both a Borough-wide level, but particularly on sites in the urban area. If affordable housing cannot viably be delivered in these areas, additional residential allocations will be required in more viable suburban or rural areas to ensure the Borough’s qualitative housing needs are met.
With regard to the delivery estimations for land in the urban area, such as Chatham Waterfront for example, there are inherent risks associated with relying on new residential markets to emerge in town centres in order to meet a Borough’s housing requirement. This approach places significant burden on these locations given the context of them not being established residential locations with appropriate services and amenities and being reliant on developers providing or contributing to new residential markets from a standing start. It would therefore be prudent for the emerging Local Plan to progress with conservative estimations on delivery in these unproven locations so that if delivery falls short this does not undermine the delivery of the Borough-wide housing requirement. It is for these reasons that Richborough has suggested applying a non-implementation discount to sites in the urban area. For instance, the Submission Version Local Plan for Dover District Council has included a 5% non-implementation discount on sites in certain areas within the housing trajectory.
The urban areas have acknowledged availability and viability challenges and an out of date Local Plan that has relied too much on residential development in this location has failed to address the market attractiveness of the claimed supply. Richborough are therefore promoting a mixed spatial strategy for residential development, with growth being appropriately spread across the Borough to urban, suburban and rural locations.