Question 40 - Affordable Housing Approach
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 7082
Received: 06/03/2019
Respondent: Ms B Bird
Developers will always look for the means of making most money. Young people who have grown up locally should have a chance to buy a property here.
Developers will always look for the means of making most money. Young people who have grown up locally should have a chance to buy a property here.
Comment
Draft Local Plan - Supplementary Consultation
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.
See attached letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7301
Received: 12/03/2019
Respondent: Mrs Sally Woodhall
Affordable housing needs to be spread through all new housing developments not concentrated in any one area
Affordable housing needs to be spread through all new housing developments not concentrated in any one area
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7314
Received: 10/03/2019
Respondent: Councillor M Wilson
As part of the starter homes initiative the government have made changes to the section 106 agreement to include starter homes as part of the affordable homes requirement for new developments. We need to ensure that the social and affordable homes built are to a standard comparable with more expensive homes and rents capped at affordable levels.
Clearly, habitable size needs to be adequate and comfortable for the inhabitants and those nearby. We need new developments to contribute to ending fuel poverty, so any affordable homes need to have enough space for living/storage and be energy efficient.
As part of the starter homes initiative the government have made changes to the section 106 agreement to include starter homes as part of the affordable homes requirement for new developments. We need to ensure that the social and affordable homes built are to a standard comparable with more expensive homes and rents capped at affordable levels.
Clearly, habitable size needs to be adequate and comfortable for the inhabitants and those nearby. We need new developments to contribute to ending fuel poverty, so any affordable homes need to have enough space for living/storage and be energy efficient.
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 7348
Received: 10/03/2019
Respondent: Michael Moran
Any measure to ensure housing is more affordable for younger people is welcome in order to reduce the obscene disparity in property ownership bewteen age groups in Solihull
Any measure to ensure housing is more affordable for younger people is welcome in order to reduce the obscene disparity in property ownership bewteen age groups in Solihull
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7368
Received: 11/03/2019
Respondent: Mr Esak Shabudin
40% affordable housing is too high and must be reduced to 20%,comment applies to 40to43 questions.
40% affordable housing is too high and must be reduced to 20%,comment applies to 40to43 questions.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7385
Received: 11/03/2019
Respondent: Golden End Farms
Agent: Delta Planning
No. Such an approach is highly complex and open to abuse.
We disagree that the existing approach of a percentage calculated on unit numbers leads to an incentive on developers to increase the size of units and reduce numbers. Developers ultimately seek to build houses and will bring forward schemes that reflect market demand and what they can sell in terms of size and mix of new homes. Oversizing of units is not in a developer's interest.
Please see full representation.
No. Such an approach is highly complex and open to abuse.
We disagree that the existing approach of a percentage calculated on unit numbers leads to an incentive on developers to increase the size of units and reduce numbers. Developers ultimately seek to build houses and will bring forward schemes that reflect market demand and what they can sell in terms of size and mix of new homes. Oversizing of units is not in a developer's interest. The existing Meeting Housing Needs SPD for affordable housing requires the private and affordable to be similar in size and this is a more straightforward way of securing more smaller units and higher densities.
An affordable housing target calculated based on floorspace has been tried by Stratford-upon-Avon Council for example, but was dropped in favour of the more straightforward and equally effective approach based on unit numbers and separate policy on unit type and mix.
It is also important to bear in mind that a high density development will not be the best option for every housing development in every location across the District. Other considerations need to be taken into account such as the need to respect local character, a key priority expressed for example in the Knowle, Dorridge and Bentley Heath Neighbourhood Plan. This specifically states that emphasis within the Neighbourhood Plan is on respecting the existing character and appearance of the Area (and the generally lower than average housing density), while recognising that higher density housing has its place. There clearly needs to be a balanced approach to ensure that the right size and mix of both affordable and market housing is provided across the district without overriding other policy priorities.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7444
Received: 11/03/2019
Respondent: Mrs Marilyn Jones
As a lay person I can't really comment on which approach should be used re affordable housing. However I do feel that affordable housing should not just be directed to first time buyers/renters etc but consideration should be given to families needs. Therefore I would want to see 3/4/5/6 bedroom affordable housing to be made available for families.
As a lay person I can't really comment on which approach should be used re affordable housing. However I do feel that affordable housing should not just be directed to first time buyers/renters etc but consideration should be given to families needs. Therefore I would want to see 3/4/5/6 bedroom affordable housing to be made available for families.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7455
Received: 11/03/2019
Respondent: Rentplus
Agent: Tetlow King Planning
Approaches based on the square meterage or habitable rooms/floorspace are not generally supported due to the inherent difficulties in designing for the policy, which causes developers to calculate the appropriate level of delivery by reference to optimal market floorspace instead of baseline numbers. This also causes difficulties in decision making and monitoring of delivery, and therefore in setting appropriate responses to underdelivery of affordable housing. Requiring the balance of market and affordable housing to be calculated by reference to such detailed calculations as floorspace will inevitably result in a reduction in the quality of placemaking.
comment on affordable homes / affordable rent policy - see letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7501
Received: 11/03/2019
Respondent: Portland Planning Consultants
No. The appropriate mechanism for securing smaller market housing is achieved using density policy. It is a requirement of plan making that account is taken of national policy. The approach to increasing densities is set out at paragraphs 122 and 123 of the National Planning Policy Framework. As is evident from those paragraphs it is necessary to approach the articulation of density policies having regard to several factors including the character of the surrounding area.
No. The appropriate mechanism for securing smaller market housing is achieved using density policy. It is a requirement of plan making that account is taken of national policy. The approach to increasing densities is set out at paragraphs 122 and 123 of the National Planning Policy Framework. As is evident from those paragraphs it is necessary to approach the articulation of density policies having regard to several factors including the character of the surrounding area.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7602
Received: 11/03/2019
Respondent: Solihull Ratepayers Association
No
Members supported the retention of the existing unit system as well established and easily understood, it was also felt the present 40% affordable policy was at the very top end of the scale with concern expressed at the level of cross subsidy from market housing falling especially heavily on younger and first time buyers rather than general taxation
The Solihull Ratepayers Members Forum and AGM on 8th March considered a presentation on the Solihull Local Plan Review Consultation and the presentations of our views are set out in the attached letter
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 7669
Received: 12/03/2019
Respondent: Mr N Walters
Yes it should, there needs to be a rebalance as new developments provide too many 4,5 & 6 bed housing to compensate for the 40% affordable contribution.
Yes it should, there needs to be a rebalance as new developments provide too many 4,5 & 6 bed housing to compensate for the 40% affordable contribution.
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 7731
Received: 12/03/2019
Respondent: Edward Fraser
Habitable square meterage of the site should affordable housing
Habitable square meterage of the site should affordable housing
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7885
Received: 13/03/2019
Respondent: Persimmon Homes Central
The Council's proposed approach is confused.
The Council is attempting to deal with identified issues associated with market housing mix including more smaller market dwellings, increasing housing densities on all sites and minimising release of Green Belt land via an alternative approach to affordable housing contributions. These matters are separate and should not be co-joined.
No justifying evidence for proposed alternative approach.
It is noted that the wording of Question 40 states a requirement for affordable housing contributions on the total square meterage or habitable rooms/floorspace.
Proposal would not comply with Written Ministerial Statement 28.11.14 of Para.64 of NPPF.
Please see attached document March 2019 Persimmon Reps Draft Solihull LPR
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 7986
Received: 13/03/2019
Respondent: Mrs Olga Cawdell
We do not need large areas of affordable housing. I believe this will just create another Chelmsley Wood. Affordable housing needs to be spread over all new sites with plenty of green open spaces.
We do not need large areas of affordable housing, i believe this will just create another Chelmsley wood. Affordable housing needs to be spread over all new sites with plenty of green open spaces.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7990
Received: 13/03/2019
Respondent: Mrs Alex Woodhall
Affordable housing is almost non existent in solihull. I think the decision where and how many affordable homes should not be made by any one party only, especially not the builders.
Affordable housing is almost non existent in solihull. I think the decision where and how many affordable homes should not be made by any one party only, especially not the builders.
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8104
Received: 14/03/2019
Respondent: Terra Strategic
Agent: Delta Planning
No. Such an approach is highly complex and open to abuse.
We disagree that the existing approach of a percentage calculated on unit numbers leads to an incentive on developers to increase the size of units and reduce numbers. Developers ultimately seek to build houses and will bring forward schemes that reflect market demand and what they can sell in terms of size and mix of new homes. Oversizing of units is not in a developer's interest.
Please see full representation.
No. Such an approach is highly complex and open to abuse.
We disagree that the existing approach of a percentage calculated on unit numbers leads to an incentive on developers to increase the size of units and reduce numbers. Developers ultimately seek to build houses and will bring forward schemes that reflect market demand and what they can sell in terms of size and mix of new homes. Oversizing of units is not in a developer's interest. The existing Meeting Housing Needs SPD for affordable housing requires the private and affordable to be similar in size and this is a more straightforward way of securing more smaller units and higher densities.
An affordable housing target calculated based on floorspace has been tried by Stratford-upon-Avon Council for example, but was dropped in favour of the more straightforward and equally effective approach based on unit numbers and separate policy on unit type and mix.
It is also important to bear in mind that a high density development will not be the best option for every housing development in every location across the District. Other considerations need to be taken into account such as the need to respect local character. There clearly needs to be a balanced approach to ensure that the right size and mix of both affordable and market housing is provided across the district without overriding other policy priorities.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8185
Received: 14/03/2019
Respondent: Mr Richard Drake
I would agree the existing target incentivises inappropriate development
I would agree the existing target incentivises inappropriate development
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8213
Received: 14/03/2019
Respondent: Mrs Sally Wilcock
Beyond my knowledge base. As observation, one sees huge 5/6 bedroom developments as for example in Tanworth in Arden and Knowle when in reality, that land could have been used for smaller affordable housing.
beyond my knowledge base. As observation, one sees huge 5/6 bedroom developments as for example in Tanworth in Arden and Knowle when in reality, that land could have been used for smaller affordable housing.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8505
Received: 15/03/2019
Respondent: Simon Taylor
- Not convinced approach incentivises smaller market housing.
- Developers could simply increase scale of larger homes to increase overall meterage, so that smaller homes were medium sized.
- SMBC's Meeting Housing Needs SPD states the need vs supply of smaller housing is greater in Dorridge and elsewhere than Dickens Heath, so why is no housing proposed for Dorridge, where the need for smaller houses is higher?
I'm not exactly sure how this approach would incentivise smaller market housing. Based on the above, if developers were savvy, they could simply increase the scale of larger homes to increase the overall square meterage, therefore allowing what are envisaged as smaller homes to actually be medium sized (based on the 40% of total square meterage formula)
In addition, I believe thought should be given to the shortfalls of smaller housing in certain areas as part of the developer incentivisation. Solihull MBC's own Supplementary Planning Draft Document cites that the supply versus demand for Dickens Heath represents a 14% shortfall on 1 bed property and 4% shortfall on 2 bed. Contrast this to Knowle/Dorridge/Bentley Heath for instance and there is a 17% shortfall on 1 bed property, and a 25% shortfall on 2 bed. The differences are stark, and are of equal proportion within other regions, why is it therefore that substantial developments are proposed for Dickens Heath (and South Shirley) with 40% affordable homes allocation, when there are none proposed for Dorridge where the requirement is far higher?
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8528
Received: 15/03/2019
Respondent: Joelle Hill
Whilst I feel this is the right approach, it would appear that it is relatively easy for developers to gradually whittle down the affordable element of developments once the process has begun. Evidence of this can be seen across the country where affordable % have been reduced on the basis of not being "commercially viable" to the developer and then the whole development being held to ransom on this point. What evidence can Solihull Planning department give to support that they would be able to robustly enforce this approach in the face of opposition from the developers on commercial grounds?
Whilst I feel this is the right approach, it would appear that it is relatively easy for developers to gradually whittle down the affordable element of developments once the process has begun. Evidence of this can be seen across the country where affordable % have been reduced on the basis of not being "commercially viable" to the developer and then the whole development being held to ransom on this point. What evidence can Solihull Planning department give to support that they would be able to robustly enforce this approach in the face of opposition from the developers on commercial grounds?
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8768
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Fulford Hall Road
Agent: Barton Willmore Planning
No. This approach would cause uncertainty for developers and the Council and is not likely to work in practice. It would not be clear how much affordable housing will be delivered through the draft Plan. If the Council allocate sufficient sites which have proportionate evidence regarding their viability and deliverability, this would be the best way of addressing the delivery of much-needed affordable housing.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8792
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land at Widney Manor Road
Agent: Barton Willmore Planning
No. This approach would cause uncertainty for developers and the Council and is not likely to work in practice. It would not be clear how much affordable housing will be delivered through the draft Plan. If the Council allocate sufficient sites which have proportionate evidence regarding their viability and deliverability, this would be the best way of addressing the delivery of much-needed affordable housing. Our Client's site LAND AT WIDNEY MANOR ROAD: SITE REFERENCE 407 can deliver affordable dwellings on a suitable site in a sensitive and well-designed manner.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8809
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land North of School Road
Agent: Barton Willmore Planning
No. This approach would cause uncertainty for developers and the Council and is not likely to work in practice. It would not be clear how much affordable housing will be delivered through the draft Plan. If the Council allocate sufficient sites which have proportionate evidence regarding their viability and deliverability, this would be the best way of addressing the delivery of much-needed affordable housing.
Please see covering letter
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8829
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land West of Stratford Road
Agent: Barton Willmore Planning
No. This approach would cause uncertainty for developers and the Council and is not likely to work in practice. It would not be clear how much affordable housing will be delivered through the draft Plan. If the Council allocate sufficient sites which have proportionate evidence regarding their viability and deliverability, this would be the best way of addressing the delivery of much-needed affordable housing.
Please see covering letter
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8847
Received: 15/03/2019
Respondent: Rainier Developments Ltd - Land Fronting Waste Lane
Agent: Barton Willmore Planning
No. This approach would cause uncertainty for developers and the Council and is not likely to work in practice. It would not be clear how much affordable housing will be delivered through the draft Plan. If the Council allocate sufficient sites which have proportionate evidence regarding their viability and deliverability, this would be the best way of addressing the delivery of much-needed affordable housing.
Please see covering letter
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 8912
Received: 15/03/2019
Respondent: Mr Eric Homer
I am in favour of supporting the Council delivering the affordable housing it needs. I would be in favour of changing affordable housing contributions on qualifying sites to 40% of habitable development area if this helps to meet affordable housing needs.
I am in favour of moving from a percentage calculated on unit numbers if this will incentivise developers to build more, smaller homes, increase the numbers of open market houses, increase housing density, reducing the amount of green belt land that needs to be used for development. This will also support the Council delivering the affordable housing it needs.
I am in favour of supporting the Council delivering the affordable housing it needs. I would be in favour of changing affordable housing contributions on qualifying sites to 40% of habitable development area if this helps to meet affordable housing needs.
I am in favour of moving from a percentage calculated on unit numbers if this will incentivise developers to build more, smaller homes, increase the numbers of open market houses, increase housing density, reducing the amount of green belt land that needs to be used for development. This will also support the Council delivering the affordable housing it needs.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 8914
Received: 14/03/2019
Respondent: Kler Group - Gentleshaw Lane
Agent: Cerda Planning Ltd
- The Council's proposed approach is not clear. The Council is attempting to deal with identified issues associated with market housing mix including more smaller market dwellings, increasing housing densities on all sites and minimising release of Green Belt land via an alternative approach to affordable housing contributions. These matters are separate and should not be co-joined. It is inappropriate to deal with these matters via the Council's affordable housing policy.
- No justifying evidence that the proposed alternative approach will incentivise developers to build smaller market housing.
see attached document
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 8939
Received: 15/03/2019
Respondent: Mrs Linda Homer
I am in favour of supporting the Council delivering the affordable housing it needs. I would be in favour of changing affordable housing contributions on qualifying sites to 40% of habitable development area if this helps to meet affordable housing needs.
I am in favour of moving from a percentage calculated on unit numbers if this will incentivise developers to build more, smaller homes, increase the numbers of open market houses, increase housing density, reducing the amount of green belt land that needs to be used for development. This will also support the Council delivering the affordable housing it needs.
Q 40 - Affordable Housing Policy and Open Market Housing Mix
I am in favour of supporting the Council delivering the affordable housing it needs. I would be in favour of changing affordable housing contributions on qualifying sites to 40% of habitable development area if this helps to meet affordable housing needs.
I am in favour of moving from a percentage calculated on unit numbers if this will incentivise developers to build more, smaller homes, increase the numbers of open market houses, increase housing density, reducing the amount of green belt land that needs to be used for development. This will also support the Council delivering the affordable housing it needs.
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 9005
Received: 15/03/2019
Respondent: Councillor Max McLoughlin
This is a question that developers will need to answer.
The intentions are good and I am glad that SMBC are asking this question. As to whether it will cause "someone else" to take a different course of action, it is the "someone else" alone who can answer.
It will need to be reviewed as to whether it does produce the desired effect in addressing affordability. There needs to be an evidence base to be reassured of the results it will produce.
This is a question that developers will need to answer.
The intentions are good and I am glad that SMBC are asking this question. As to whether it will cause "someone else" to take a different course of action, it is the "someone else" alone who can answer.
It will need to be reviewed as to whether it does produce the desired effect in addressing affordability. There needs to be an evidence base to be reassured of the results it will produce.