5.16.1

It is accepted that clear guidance should be provided on affordable housing provision so it can be accounted for in the calculation of land value. However, the cumulative impact of affordable on viability must also be taken into account with other planned increases in development costs including education and health contributions as outlined in this consultation. These two increases from that which is set out in the approved Medway Contributions Guide will alone increase the per dwelling S106 costs from circa £17,000 to circa £31,000 per unit. This significant circa £14,000 increase per dwelling is not accounted for in the Viability Assessment report that underpins the emerging local plan which already proposes to increase the S106 costs from the Capstone Valley allocation to £21,131 per dwelling. It is therefore important for policy makesr to appreciate that S106 contribution increases more generally together with proposed changes to the affordable tenure split to increase the percentage of social rent as well as the 5% increase in overall affordable provision has collective impacts by placing greater pressure on the delivery of housing in Medway for both affordable and open market provision. For this reason whilst the tenure mix and increase in overall affordable quantum by 5% has been accounted for in the evidence base in the Viability Assessment the proposed significant health and education contribution increases, the subject of this consultation, have not and this threatens plan housing delivery of which affordable is a part. The proposed health and education contribution increases of circa £14,000 per dwelling must be considered having regard to this wider context.