Policy T3: Affordable Housing

The plan approach to affordable housing sounds encouraging, although the 30% for suburban greenfield sites, and 10% for lower value areas/brownfield seems upside down - i would have thought a greater amount of social rented accomodation is needed in lower value areas, where car ownership cannot be assumed, and local facilities are more accessible on foot/by public transport?

The government together with local councils must take responsibility for "affordable housing" rather than attempt to pass the responsibility on to the private sector. The housing crisis has been created by the policy of successive governments to sell off the council housing stock and their failure to replace the housing stock that has been sold. Only by creating an adequate supply of social housing can we stop the continuing spiral of increasing rents and house prices. People in "affordable housing" also need green space and access to sports and other recreational facilities - these must be provided.

All plans for new housing or industry need to include provision of recycling water and use of soler panels on roofs or other structures. To achieve net zero rainwater harvesting and solar generation are easy gains. For new property it would be ideal to offer incentives or discounts to local people, otherwise new build drive up house prices as we become an extension of London.

I support the split in affordable housing provision depending on value. Not seen this anywhere else before so possible a first. I hope it holds up at inspection! The figure should be viewed as a minimum. Should a viability assessment be required to ensure developers aren’t cheating us?

The Medway Development Company do not appear to build affordable housing or they push them out to White City Estate. I had hoped this would be changed. Site costs, affordability assessments also keep affordable housing numbers down.

Would argue that is be 35% of greenfield due to the massive efflux of young people from rural areas due to not being about to afford housing. This will also encourage developers to work with brownfield sites where they can get a higher profit.

As with my previous comment…how can you ensure that the affordable homes come to Medway and not the London Boroughs?

Will local residents have priority over any new affordable developments or will they be given to other London borough tenants.

the affordable and local homes to be resident to the following categories:

1. Medway residents already
2. Key workers
3. Family connections, or educated in Medway.

Local residents are often frustrated when previously green land is used for housing developments that have homes built on them that few of the local residents would be able to afford. The site off Pear Tree Lane is a good example of this. The need for housing is clear. The need for executive sized homes is less clear. There is also a lack of public transport available to these out of town sites which therefore put more pressure on the road system.

Good evening I am writing this e mail to say i would not like the build to go ahead opposite Binney road
We have 9 houses just been built and still one is still on the market after a year ,
It is hard enough to get a doctor and dentist on the peninsula without adding more houses , we only have a one water waste pump station that has to have a Mts lorry to pump it out every year so I think with more houses being built it will only get a lot worse ,
The roads are awful always a burst somewhere in the village
if there is a accident on the peninsula no one can get off and if there’s traffic sometimes it can take over an hour to get to my work on Medway city estate,
The local secondary school is full to capacity and the buses get full as it is ,
People don’t want to live this far out hence why still houses for sale around the area
There is a lot of wildlife that will suffer
Yours sincerely Tina

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”.

We object to the proposed affordable housing policy, T3, which requires rates of 30% affordable housing in the Hoo Peninsula. This proposed policy is based on outdated evidence and does not take into account rural brownfield sites, which generally cost more than greenfield sites to be bought forward. It is considered that this approach could be considered in tension with the GO 3 growth option which promotes brownfield first principles for development.

We the support the approach that Brownfield inner urban sites should deliver 10% affordable housing. However, Policy T3 should make it clear that this should be subject to viability testing.

Please see covering letter from The Planning Bureau dated 6th September which includes the following recommendation:

Recommendation:

Add the following text to Policy T3:

‘Specialist housing for older people is exempt from providing affordable housing’.

In response to Q11

This policy will need to be compliant with the draft NPPF (July 2024), particularly with regard to the emphasis on Social Rent homes (NPPF paragraphs 63 and 64) and the need for a minimum proportion of Social Rent homes required.

However, setting a target is not enough. The Council will be aware that the development industry is already not building the houses it has planning permission to build. In Kent alone, there are some 86,262 houses either with planning permission or identified within five-year supply statements ready to be built, yet currently the industry is only delivering 8,624 new houses a year. Of these, only 13.1% are affordable houses under the current definition, reducing to 8.6% which are genuinely affordable houses managed by Registered Providers.

Targets do not build homes. How will the Council ensure that affordable homes get built, without delivery delays (to market housing)?

The percentage affordable housing should be set at one figure, as a target. In the event that this is not viable on a site by site case basis evidence should be sought as to how a 30% provision would impact viability. Only then should 10% provision be allowed in lower value areas.

In response to Q12
This policy will need to be compliant with the draft NPPF (July 2024).

In response to Q13

CPRE acknowledges the Council’s preference (as set out in paragraph 6.3.13) for affordable housing to be provided on-site in the first instance and that if this cannot be delivered, provision being made off-site and then via developer contribution.

However, the Council will be aware that the development industry is already not building the houses it has planning permission to build. In Kent alone, there are some 86,262 houses either with planning permission or identified within five-year supply statements ready to be built, yet currently the industry is only delivering 8,624 new houses a year. Of these, only 13.1% are affordable houses under the current definition, reducing to 8.6% which are genuinely affordable houses managed by Registered Providers.

How will the Council ensure that affordable homes get built, without delivery delays (to market housing)?

Our client welcomes the differentiation policy when delivering affordable housing on greenfield (30%) and brownfield sites 10%. We also support the proposal to allow a viability assessment to be undertaken if affordable housing delivery is not possible even at the 10% level for viability reasons.

It is considered that the policy should use percentages led by the need requirement set out in Table 7.1 of the Local Housing Needs Assessment to inform the percentages to accompany Policy T3.

10 or more units affordable housing . What percentage if just 10?
Didn't we have issues with the Victory Pier development over the change in position from providing a percentage of affordable housing, then changing their minds in nearly finish build. Also re Section 106 on a development . Should be as close to where the build is to take place as far as possible. What redress is there for those developers who do not fulfil their Section 106 obligations?
Housing for Looked After children, more residential ? Smaller homes for two or three children as well.

There is no such thing as "affordable housing". No new houses.

Agree

Although guidelines are set for the amount of affordable houses in any development, Medway Council admit that getting developers to adhere to these is a problem.

Our client welcomes the differentiation policy when delivering affordable housing on greenfield (30%) and brownfield sites 10%. There is, however, some potential for ambiguity in the policy, which would benefit from being clearer that 10% affordable housing should be sought from all brownfield sites. We also support the proposal to allow a viability assessment to be undertaken if affordable housing delivery is not possible, or not possible at the level required, for viability reasons.

It is considered that the policy should use percentages led by the need requirement set out in Table 7.1 of the Local Housing Needs Assessment to inform the percentages to accompany Policy T3.

If houses are to be built it should be on brownfield and affordable and built to a fit standard. Realistic many feel this won't be the case and they're usually right

What does affordable housing mean? Instead of keep building new homes on the peninsular, how about sorting the infrastructure out first. When there is an accident, no one can get in or out. It is an absolute joke. Public transport is a terrible. No one can get an appointment at the Dr's.
But most importantly, the wild life and it's habitat will suffer hugely. I am seeing more and more road kill every day, and more houses will mean more of the same.
Why are you looking at building on farm land? We need farm land.

Housing cannot be deemed "affordable" unless a mortgage on a property can be afforded by people on the average household income of local residents. On that criteria there is no affordable housing available locally, thus exposing the hypocrisy of the term: "affordable".
There is a clear need for a massive increase in Social Housing or, better still, Council Housing.

AGREE

If only we had actual "affordable housing " rather than the ludicrous interpretation of "affordable" that we have at present . We need social housing that is not sold off .We need social housing that is for the community that actually needs it .Small families , single parents ,the disadvantaged elderly .