Medway Local Plan (Regulation 18, 2024)

In response to Q8
No

In response to Q10

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)?

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)?

In response to Q28

No.

Please see CPRE Kent's specific comments on development at the Hoo Peninsular in response to the Council’s preferred spatial strategy at section 3.2 of the Plan.

While addressing the needs of existing residents is to be welcomed, this draft policy should not be seen as a green light accepting a development strategy which in its own right is unsustainable (in terms of identifying the Hoo Peninsula as an area of significant growth for housing).

Residents may well want better shopping facilities that are easily accessible (15-minute walk), but not at the expense of an environmentally damaging and unsustainably located large-scale housing development.

If the Council drew up a strategy that placed the environment at the heart of its sustainability objectives, there would be no requirement for infrastructure to support new growth on the Hoo Peninsula.

Paragraph 8.12.1 of the draft local plan confirms that a development strategy has not yet been finalised. If this is the case, it’s not clear why the first sentence contradicts the second by saying that there is potential for significant development on the Hoo Peninsula.

For any major growth to take place, it follows that it should be accompanied by the day-to-day services and facilities that new residents would need. However, to specifically identify the Hoo Peninsula as a location for new (shopping) centres undermines the consultation currently being undertaken whereby views are being sought on the Council’s preferred option for development. Nothing is yet set in stone.

For the purposes of this consultation, this policy should have been firmly caveated in terms of Hoo being one of many potential growth sites - and a similar policy drafted for the other potential locations across the district.

While CPRE welcomes proposals to address existing deficiencies to meets the needs of existing local residents, it cannot support the Council turning its back on these communities and siting such provision outside existing village centres (paragraph 8.2.1).

In response to Q42

Agree that infrastructure needs must be identified. this will need to apply across the whole of the district, including focusing on broad locations for development and strategic sites.

In response to Q43

The Council will need to align infrastructure provision with growth, by, as set out in the daft policy ensuring that there is a timely delivery of infrastructure, with on-site delivery made ahead of occupation.