Policy T3: Affordable Housing: We object to the wording of this policy particularly the first two bullet points which set out the requirement for the level of affordable housing. This sets out that the Hoo Peninsula should provide 30% affordable housing and lower value areas, such as brownfield inner urban sites, provide 10% affordable housing.
This reduction to 10% affordable housing provision should also cover brownfield sites found elsewhere within the rural part of the district. The costs of remediation work required on rural brownfield sites, is no less than that of urban areas, and the requirement for providing 30% affordable housing in the Hoo Peninsula area could impact viability of these rural brownfield sites from the outset.
We represent a rural brownfield site, HHH41, which is located on the Hoo Peninsula, whereby the provision of 30% affordable housing on top of potential remediation works (unknown at this stage) could impact viability. It is important that the policy enables flexibility for these rural brownfield sites whilst viability assessments and surveying work are in their early stages.
In accordance with the Viability background document, the rates for affordable housing provision are based on the Medway Council Affordable Housing and CIL Viability Testing Report (GVA, January 2016), which was consulted on in 2019. This document sets out what is considered a higher or lower value area. We consider that this document is outdated, because it doesn’t consider rural brownfield sites. The potential to update the document to consider this further should be provided.

In addition to an updated background document, we also propose that the policy is reworded as follows:

“● In high value areas, including the Hoo Peninsula and suburban greenfield sites, 30% of all residential units proposed.
● In lower value areas, such as brownfield inner urban sites and rural brownfield sites, 10% of all residential units proposed”.