Comment

Representation ID: 7090

Received: 07/03/2019

Respondent: Tetlow King Planning

Potential difficulties in designing development schemes and determining whether the policy has led to delivery as identified in the needs assessment.
Schemes would be designed around numbers, not good placemaking or meeting identified needs (and demand). Approach limits the policy's flexibility and the flexibility with which a site can be designed to meet housing needs and still be viable.
Should such a policy be implemented without accompanying guidance on housing mix, relying instead on market forces to deliver this, schemes could be badly skewed towards an arbitrary numerical target instead of housing needs. This could lead to overly dense, or very low density developments which do not reflect actual housing need, with developers seeking to provide larger affordable homes to meet the 40% requirement which may not be affordable.
Need to consider impact on delivering regeneration schemes. If an estate regeneration scheme is measured to avoid net loss of habitable rooms or floorspace instead of unit numbers, this could compromise the ability to effectively meet housing needs. If an estate is currently over-occupied there may need to be a smaller number of larger units provided in the regeneration scheme, whilst another characterised by under-occupation may need a higher number of smaller units. These nuances must be reviewed by the Council in understanding the potential impacts of any change in policy approach to seeking affordable housing from mixed tenure schemes.