It is not clear why the requirement for dementia-friendly standards has been included in a general housing design policy. This policy requirement would be more relevant to Policy T4.

The M4 building standards for dwellings can be incorporated into Policy T2: Housing Mix, setting out the mix of M4 (2) and M4 (3) homes, which are all designed to adapt to various living situations.

We are concerned at the proposal that no more than 5% north-facing single-aspect homes within any one development will be considered. Whilst the premise of this policy is in accordance with paragraph 135 (f) of the NPPF, seeking to create places that are of a high standard of amenity for existing and future users, the hard 5% limit appears unnecessarily arbitrary.

The last bullet point of the policy seeks a design for flexible living: successful places that are robust and support long life and loose-fit’ neighbourhoods that are flexible and adaptable to rapidly changing circumstances. Our client has concerns regarding the deliverability of this part of the policy. What standards does the Council intend to apply to help determine whether something is flexible living, and what are the key design criteria for long-life and loose-fit neighbourhoods? The Council should consider the production of the Supplementary Planning Document (SPD) or details within a Design Code to clearly set out how they wish housing standards to meet such fluid design criteria to help applicants understand what is required of a planning application which may help facilitate the long life and loose-fit neighbourhoods set out in the policy.

Ultimately, the last part of this policy currently appears to be intangible. The Council needs to provide further guidance about how long-life and loose-fit neighbourhoods will manifest themselves in the Medway towns.