Medway Local Plan (Regulation 18, 2024)

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Comment

Medway Local Plan (Regulation 18, 2024)

Policy T2: Housing Mix

Representation ID: 3043

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

We are pleased to see that the housing mix policy takes account of the fact that the housing mix on a site needs to take account of the size, location and characteristics of the site, rather than simply applying a blanket policy. We are however concerned at the requirement for all development schemes to demonstrate consideration of custom and self-build plots as part of the mix.

Full text:

We are pleased to see that the housing mix policy takes account of the fact that the housing mix on a site needs to take account of the size, location and characteristics of the site, rather than simply applying a blanket policy. It is essential to the viability of any scheme that there is market demand for the type of housing proposed. We support this overall approach.

We are however concerned at the requirement for all development schemes to demonstrate consideration of custom and self-build plots as part of the mix. Some sites will be better suited to self-build than others, depending on the characteristics and location of the site, and also the business model of the developer. We would object to any blanket requirement for self-build on all sites.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy T3: Affordable Housing

Representation ID: 3044

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

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.

Full text:

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.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy T3: Affordable Housing

Representation ID: 3045

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

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.

Full text:

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.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy T7: Houseboats

Representation ID: 3046

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

Our client’s site, CHR20 Temple Sawmill, is located close to an existing houseboat mooring location. It is vitally important that opportunities are sought to deliver improvements that benefit local amenity, improve the quality of the local environment, and to ensure the removal of derelict and/or abandoned boats as sought by this policy.

Full text:

Our client’s site, CHR20 Temple Sawmill, is located close to an existing houseboat mooring location. It is vitally important that opportunities are sought to deliver improvements that benefit local amenity, improve the quality of the local environment, and to ensure the removal of derelict and/or abandoned boats as sought by this policy.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy T9: Self-build and Custom Housebuilding

Representation ID: 3047

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

We have no objection to the policy supporting self-building housing or identifying specific sites where promoters would support this use.

We do however object to the blanket requirement for 4% of plots on all 100+ unit sites to be self-build plots. Some sites will be better suited to self-build than others, depending on the characteristics and location of the site, and also the business model of the developer. A blanket requirement may reduce developer interest, which may then delay the development of complex brownfield sites or, in a worst case scenario, stall progress altogether.

Full text:

We have no objection to the policy supporting self-building housing or identifying specific sites where promoters would support this use.

We do however object to the blanket requirement for 4% of plots on all 100+ unit sites to be self-build plots. Some sites will be better suited to self-build than others, depending on the characteristics and location of the site, and also the business model of the developer. A blanket requirement may reduce developer interest, which may then delay the development of complex brownfield sites or, in a worst case scenario, stall progress altogether.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy T11: Small Sites and SME Housebuilders

Representation ID: 3048

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

While our client can see the benefit of a policy supporting SME housebuilders for smaller site development, the 60-unit cap seems arbitrary and potentially confusing. Whilst the support for SME housebuilders and small sites is welcomed, and important, it is unclear what practical effect this policy has as drafted. Would a high quality 61-unit scheme not be supportable? Why is there a need for a cap at all?

Full text:

While our client can see the benefit of a policy supporting SME housebuilders for smaller site development, the 60-unit cap seems arbitrary and potentially confusing. Whilst the support for SME housebuilders and small sites is welcomed, and important, it is unclear what practical effect this policy has as drafted. Would a high quality 61-unit scheme not be supportable? Why is there a need for a cap at all?

Comment

Medway Local Plan (Regulation 18, 2024)

Policy S11: Existing Employment Provision

Representation ID: 3049

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

As currently worded, the policy does not take account of sites like Morgan Timber (CHR20) which are proposed to be allocated for housing in the Local Plan. There may also be other unallocated sites which are currently in commercial use where there would be planning benefits in being redeveloped for other uses.

The list of bullet points for scenarios where support would be forthcoming should be extended to include:
• The site is identified in the Local Plan as being suitable for other uses
• There would be wider, demonstrable planning benefits in redeveloping the site for a non-employment use.

Full text:

As currently worded, the policy does not take account of sites like Morgan Timber (CHR20) which are proposed to be allocated for housing in the Local Plan. There may also be other unallocated sites which are currently in commercial use where there would be planning benefits in being redeveloped for other uses.

The list of bullet points for scenarios where support would be forthcoming should be extended to include:
• The site is identified in the Local Plan as being suitable for other uses
• There would be wider, demonstrable planning benefits in redeveloping the site for a non-employment use.

Comment

Medway Local Plan (Regulation 18, 2024)

Vision for Access and Movement in Medway

Representation ID: 3050

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

It is concerning that opening points on the vision for access and movement in Medway relate to working from home. It is not appropriate for new residential dwellings to make provision for bespoke working-from-home facilities in residential dwellings where existing areas such as spare bedrooms and other locations in dwellings can be utilised to work from home given the portable nature of professional service work operating in laptops and other devices. We consider that the Council should pursue a policy pursuant to their current adopted policy (Policy ED 10: Working From Home)

Full text:

It is concerning that opening points on the vision for access and movement in Medway relate to working from home. It is not appropriate for new residential dwellings to make provision for bespoke working-from-home facilities in residential dwellings where existing areas such as spare bedrooms and other locations in dwellings can be utilised to work from home given the portable nature of professional service work operating in laptops and other devices. We consider that the Council should pursue a policy pursuant to their current adopted policy (Policy ED 10: Working From Home), which sets out that working from home will be permitted provided that it can be demonstrated that there would not be any detrimental impact/effects on residential amenity, it would not impact upon traffic flows, vehicle parking or the erosion of the residential character of the area.

Comment

Medway Local Plan (Regulation 18, 2024)

Policy DM15: Monitoring and Managing Development

Representation ID: 3051

Received: 06/09/2024

Respondent: Morgan & Company (Strood) Ltd

Agent: DHA Planning

Representation Summary:

Given that the Strategic Transport Assessment referred to in this policy has not been provided as part of the evidence base, the overall requirement is not yet fully known so that no detailed commentary can be made on this policy. However, given that the proposal is in the urban centre of Medway and is an “indicative” site allocation, it should be considered exempt from this policy's requirements due to the site's accessible location.

Full text:

Given that the Strategic Transport Assessment referred to in this policy has not been provided as part of the evidence base, the overall requirement is not yet fully known so that no detailed commentary can be made on this policy. However, given that the proposal is in the urban centre of Medway and is an “indicative” site allocation, it should be considered exempt from this policy's requirements due to the site's accessible location.

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