Medway Local Plan (Regulation 18, 2024)

In a similar response to Policy T1, the criteria in this policy should be reconsidered as some of the criteria would be better suited to a more overarching strategic policy. The last criterion of DM5, is considered to be unnecessary, lacking clarity, and better suited to a strategic policy:
“All new accommodation must, in addition to the general design policy above (T1): ●Design for flexible living, successful places are robust and support 'long-life and loose-fit' neighbourhoods that are flexible and adaptable to rapidly changing circumstances. The physical and social infrastructure provision required to create sustainable communities have been considered”.

This criterion in this policy, setting out theadditional requirements for single aspect homes, seem more like a generic and vague aspiration than those based on a sound evidence base.

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 We consider that this document is outdated, because it doesn’t consider rural brownfield sites.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”.

Policy T11 ‘Small Sites and SME Housebuilders’, we support the inclusion of a policy which supports the provision of development by small and medium sized businesses, as these sites are often built-out quickly and support local jobs. Site HHH41 is considered to fall within the small site policy requirement and has an indicative capacity of 25 units. Its future development by a SME housebuilder would actively support the local economy.

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.