Representation to Swale for Affordable Housing on BMM WESTON Works

Affordable Housing
FCLT have no objection to the principle of residential development on this site but are
disappointed that no provision for affordable housing has been made. We fully support the
representations submitted by Faversham Town Council and reservations expressed therein
and look to expand on them in this representation.

The applicants cite Policy DM 8 in the 2017 Local Plan to justify that no affordable housing
should be provided. The 10 units proposed are under the small site exemption policy
threshold of 11.

The National Planning Policy Framework 2021 changed the small sites exemption restricting
the size of developments from which affordable housing contributions can be sought.
Schemes with 10 or more homes or where the site area is 0.5 hectares, or more are defined
as Major Developments. The subject site is 0.93 hectare and as such with 10 units the
scheme passes both tests and is deemed to be a Major Development. Section 64 states that
the provision of affordable housing should not be sought for residential developments that
are not Major Developments. Current planning guidance indicates that the scheme should not benefit from the small sites exemption policy and affordable housing should be included
in the scheme.

The subject site adjoins a cluster of one of the higher-value housing areas in Faversham. The
scheme mix has been designed to capitalise on this and provides 2 large five-bed homes and
8 large four-bed homes with an average area of 1,971 sq. ft. They range in size between
1,722 sq. ft and 2,799 sq. ft.
This is not a balanced housing mix and contains none of the typologies sought in policy FAV3
of the emerging neighbourhood plan: -
FAV3: Residential Mix and Standards

  1. Residential schemes should include a mix of accommodations to meet local housing needs,
  2. accommodation suitable for families (3 bedrooms) as a predominant part of the
  3. smaller accommodation (2 bedrooms or less) suitable for first-time buyers or
    renters or those seeking to downsize.
  4. accommodation suitable for older people and those with limited mobility.
    We encourage the applicants to reconsider their layout in the light of this policy and
    consider introducing smaller units into the mix. There have been few larger two and three
    bed homes and apartments built in the town (850-1500 sq. ft) and high levels of demand
    from downsizers. These units could be designed to provide accommodation specified to
    meet the requirements of aspiring downsizers. There is a paucity of supply of suitable new
    homes for this demographic who are compelled, through lack of choice, to under occupy
    and overheat larger properties. Addressing this demand would free up larger homes for
    local families with sustainability benefits. The location of the site is particularly suited to this
    equity rich demographic and a premium price for this product would be achieved.
    Replanning with a balanced mix would also increase unit numbers taking the site total above
    11, disqualifying the DM8 small sites exemption and obligating the provision of affordable
    Notwithstanding this the high value profile and burden of maintaining the intended private
    roads deems the site unsuitable for the provision of affordable homes. Accordingly, the
    payment of a commuted sum in lieu would be appropriate in accordance with Policy Fav3 2.
    of the Neighbourhood Plan.
    FAV3: Residential Mix and Standards
    If there are planning reasons for affordable housing provision to be provided separately
    from the scheme, it should be provided nearby and within Faversham Parish, to meet local

The interpretation provisions of Policy Fav2 supports and encourages community-led
housing as part of housing provision. Policy DM8 (Affordable Housing) of the Local Plan
creates an opportunity for commuted sums to be made available to Registered Social
Landlords or other providers. The latter could support community-led housing-providers
and more innovative forms of provision. FCLT is a community led-housing provider and
would welcome access to commuted sums to support a build programme to deliver
genuinely affordable housing in the town to address local housing need.

Office Conversion
The proposed office conversion is not included in the application although parking has been
added to the site plan to accommodate an anticipated residential conversion under
permitted development rights. No plans have been submitted indicating the number of
apartments proposed. The parking for this proposed change of use is referenced in the
Design and Access Statement and confirms that 11 spaces have been provided at a ratio of
1:1. This implies that a considered conversion capacity appraisal has been undertaken
identifying potential for 11 one or two bed apartments. To consider granting consent for
parking to support these without clarification of the unit numbers and sizes would not
represent good practice. Further information should be sought from the applicants.
The combined proposal, which is intrinsically linked by the conversion parking scheme,
proposes 21 homes which are to be provided on one site which clearly comprises a single
planning unit as allocated in the Faversham Neighbourhood Plan.

In the light of this we suggest that the detailed application should be amended to reflect
policy Fav 1 and submitted as a reserved matters application in tandem with an outline
application including the apartment conversion target numbers. All other matters to be
reserved for subsequent approval. This would enable a holistic review of the proposals.

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