Question 40 - Affordable Housing Approach

Object

Representation ID: 10364

Received: 14/03/2019

Respondent: Gladman Developments

Considers that the need and justification for the proposed approach does not reflect the evidence base supporting the Local Plan. Questions justification for 50% affordable housing requirement when evidence provided within the Part 2 SHMA would appear to indicate that affordable housing needs are much lower at 210 dwellings per annum (roughly 25% of future housing need). No data provided as part of the consultation to illustrate the mix of housing delivered within the Borough in recent years. The Part 2 SHMA sets out that the largest proportion of future housing need is for 4 bedroom dwellings or more. There is not a significant need for smaller housing stock. Concern over how the Council would monitor the implementation of the proposed approach for affordable housing. The total number of dwelling secured would be on a case by case basis therefore the Council would be unable to conclude how effective the Local Plan would be in responding to affordable housing need. This is more problematic for outline planning applications where details relating to the number of
bedrooms, habitable rooms, and floorspace are more likely to be determined later through the detailed application stage. As a result, for outline planning applications the principle of development will be secured without information on the amount of affordable housing to be
provided. The Council is unlikely to know what impact the implementation of this policy would have on viability, harming the soundness of the Local Plan. This absence of viability evidence, together with the variation of conditions in which the policy would be applied would mean that applications would need to be viability tested on a site by site basis. This would substantially increase the length of time it would take for the Council to determine planning applications. A percentage-based policy based on the number of homes delivered, as currently adopted, gives
more certainty and clarity as to the Council's requirements and provides a measurable target for the Council to consider the performance of housing delivery against. The perceived shortage in the delivery of smaller housing types could be more effectively addressed through the application of other policy tools. Starter homes now form part of the definition of affordable housing but do not remain as affordable homes in perpetuity and as such will one day form part of the Borough's supply of market dwellings. Given the restrictions placed on starter homes in terms of price paid, size and type this will increase the supply of smaller stock within the Borough. Density requirements may also be effective in securing a higher proportion of smaller dwellings.