Object

Representation ID: 9172

Received: 14/03/2019

Respondent: stantec

Agrees that the delivery of smaller homes as part of a balanced mix of housing is important. However, requiring affordable housing as requirement based on a proportion of net residential floorspace would not incentivise the delivery of smaller market homes. It could act to discourage the delivery of some types of homes. A block of small apartments can have a higher net residential floor area than the equivalent land-take for family homes therefore would require a greater amount of affordable housing but with less revenue with implications for economic viability which would conflict with paragraph 67 of NPPF. Placing too much emphasis on the delivery of smaller homes or requiring affordable housing as a proportion of net residential floorspace would not achieve the policy objective to meet in full the identified housing requirements in terms of numbers, sizes, tenures and types. it is not an effective, justified or sound policy basis to ensure that the identified housing requirement will be met in full over the plan period. Paragraph 60 of the NPPF states there should be an evidence based approach to determine the minimum number of homes that are needed. An affordable policy requirement based on a proportion of net residential could also make it difficult for the LPA to assess the effectiveness of the plan. The wording of any affordable housing policy should also take into account the updated and wider definition of affordable housing set out in Annex 2 of the NPPF.