Question 41 - Affordable Housing calculation

Comment

Representation ID: 7083

Received: 06/03/2019

Respondent: Ms B Bird

Option c

Comment

Representation ID: 7091

Received: 07/03/2019

Respondent: Tetlow King Planning

Approach will not overcome the Council's concerns with low provision of smaller market homes. Should the habitable rooms in the open market element of a scheme be quite large but few in number, this will not necessarily equate to an increase in delivery of affordable homes. This may have the unintended consequence of larger affordable homes being provided which do not meet local housing needs, are not affordable and may be difficult to re-let or sell on shared ownership terms.
Setting a threshold based on the habitable floorspace may be too onerous, adversely impacting on scheme densities to the detriment of good design in cases where viability is marginal and the number of units must increase to achieve a policy-compliant level of affordable floorspace.

Object

Representation ID: 7315

Received: 10/03/2019

Respondent: Councillor M Wilson

Affordable housing should not lack what market homes have in terms of space and storage. Housing strategies should set out targets for the provision of housing , which shall be sufficient to meet the needs of the current and future population, taking account of current levels of homelessness, overcrowding, concealed households, affordability, inadequate or unsuitable housing, and households unable to meet their housing needs without some form of assistance, and taking account of the need to protect land for habitats, industrial and commercial uses, and recreation. So, it should be higher than 40%.

Support

Representation ID: 7349

Received: 10/03/2019

Respondent: Michael Moran

I believe any measure is to be encouraged but developers may produce better quality affordable homes if the approach is based on habitable square meterage

Object

Representation ID: 7386

Received: 11/03/2019

Respondent: Golden End Farms

Agent: Delta Planning

Do not agree with the approach.

Object

Representation ID: 7456

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.

Object

Representation ID: 7603

Received: 11/03/2019

Respondent: Solihull Ratepayers Association

Do not support the change of unit measure policy
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

Support

Representation ID: 7670

Received: 12/03/2019

Respondent: Mr N Walters

40% of gross floor area of each dwelling.

Support

Representation ID: 7733

Received: 12/03/2019

Respondent: Edward Fraser

Habitable square meterage

Comment

Representation ID: 7886

Received: 13/03/2019

Respondent: Persimmon Homes Central

The calculation of affordable housing contributions on bedroom numbers, habitable rooms or habitable square meterage are not considered an effective nor appropriate approach.
It is standard practice that affordable housing contributions are calculated on the basis of numbers of units.
The Council's proposed alternative approach will not provide the necessary certainty for developers or decision makers with regard to its implementation.
Alternative approach will cause difficulties in viability negotiations.
Council not provided viability evidence to justify alternative approach.

Support

Representation ID: 8097

Received: 14/03/2019

Respondent: Sheila Cooper

Support the building of primarily smaller homes to buy so that the children of residents can buy a property in Balsall Common.
Support SMBC's wish to build more smaller homes.
Support shared ownership projects, starter homes and discounted homes (as per annex 2 of the 2019 NPPF). These types of property would meet more diverse needs.
Steps should be taken to provide charitably run homes for vulnerable people.
Not qualified to comment in detail on Q41, but developers need to be tied firmly into binding contract to provide smaller affordable homes, not permitted to avoid obligation because of financial reasons.

Object

Representation ID: 8105

Received: 14/03/2019

Respondent: Terra Strategic

Agent: Delta Planning

Do not agree with the approach.

Comment

Representation ID: 8917

Received: 14/03/2019

Respondent: Kler Group - Gentleshaw Lane

Agent: Cerda Planning Ltd

- The calculation of affordable housing contributions on bedroom numbers, habitable rooms or habitable square meterage are not considered an effective approach.
- It is standard practice that affordable housing contributions are calculated on the basis of numbers of units.
- The proposed approach would not provide a clear indication of the number of affordable units that may be required causing difficulties to undertake the appropriate viability assessment when bringing land forward for development.
- Divergence from number of units approach would slow down processing of planning applications and consequently housing delivery since more negotiation would be required.
- Viability evidence as previously undertaken was not based on this proposed alternative. New viability evidence would have to be carried out to support any change.

Support

Representation ID: 9006

Received: 15/03/2019

Respondent: Councillor Max McLoughlin

(C) Habitable square meterage.

Comment

Representation ID: 9144

Received: 15/03/2019

Respondent: Councillor M Wilson

Habitable meterage.

Object

Representation ID: 9162

Received: 14/03/2019

Respondent: The Home Builders Federation Midland Region

The calculation of affordable housing contributions on bedroom numbers, habitable rooms or habitable square meterage are not considered an effective approach.

Object

Representation ID: 9247

Received: 14/03/2019

Respondent: Dickens Heath Parish Council

Oppose change to the unit basis of calculation and consider the existing unit basis at 40% for the affordable element is already exceptionally high.

Support the retention of the unit housing measurement as a clearly understood basis given the system is already required to meet housing size, mix and accommodation standards set down by the local authority.

Object

Representation ID: 9279

Received: 15/03/2019

Respondent: IM Land

Agent: Barton Willmore Planning

We do not support this approach and suggest that a system based on unit numbers, in line with national guidance, is appropriate. If the Council continues with this approach it should demonstrate that the proposed method will not render schemes unviable given the amount of affordable housing may be higher than 40% of the total unit numbers.

Support

Representation ID: 9317

Received: 15/03/2019

Respondent: Spitfire Bespoke Homes

Agent: Ridge and Partners LLP

Spitfire are aware of representations prepared by the HBF and concur with the comments made in respect of Question 41.

Object

Representation ID: 9405

Received: 15/03/2019

Respondent: Mr M Trentham

NO I understand that there are already viability problems on some developments related to the affordable housing requirement. KEEP IT SIMPLE.

Comment

Representation ID: 9455

Received: 15/03/2019

Respondent: Hampton Road Developments Ltd

Agent: Savills

We consider this approach to be unconventional and could lead to a greater than 50% of housing units being provided for affordable housing, where the mix for private includes more 2 and 4 bed houses than is required for affordable. This could negatively affect the overall site mix. We object to this approach until further evidence can be provided to justify a habitable room/floor space requirement. We consider that where the Council seeks to pursue an unconventional approach and a departure from a % of overall dwellings, then a clear justification should be provided.

Comment

Representation ID: 9495

Received: 15/03/2019

Respondent: Catesby Estates Limited

Agent: WYG

Proposed policy threshold above which affordable housing is required should accord with Government policy which states that affordable housing should only be sought on sites of more than 10 dwellings (or where the gross floorspace exceeds 1.000 sqm).
Calculation by floorspace not fully justified or consistent with national policy and confuses requirement with housing mix/type of housing. Alternative approach will not provide clear indication of requirement, and is not justified through viability assessment.

Object

Representation ID: 9515

Received: 15/03/2019

Respondent: The Knowle Society

None of these alternatives.
To provide a 40% true representation of the total number of dwellings proposed for a site, then there should be provided 40% of each house type as affordable, thus by definition achieving a 40% representation of the whole.

Object

Representation ID: 9525

Received: 15/03/2019

Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road

Agent: Savills

We do not consider that the proposed approach is suitable and the Council has not provided any justification /
evidence as to why they are proposing this alternative approach to affordable housing. We consider that the
Council's existing approach to affordable housing is more appropriate

Comment

Representation ID: 9549

Received: 15/03/2019

Respondent: Richard Lloyd

A clear policy detailing the mix of houses to be provided in each part of the Borough
would allow applications for excessive numbers of large dwellings to be refused

Object

Representation ID: 9579

Received: 15/03/2019

Respondent: Bloor Homes

Agent: Savills

Unless there is compelling evidence to support otherwise, we object to a change in the approach to calculating affordable housing. Most LPAs approach affordable housing on a % of the total housing units and we consider that this approach should remain in place to enable housebuilders to compare like for like opportunities across
LPA boundary areas.

Comment

Representation ID: 9597

Received: 15/03/2019

Respondent: Berkswell Parish Council

Residents' interest is primarily smaller homes to buy so that the children of Balsall Common residents can buy a property in Balsall Common. The affordable housing definition does not help this group and that is disappointing
Support higher proportion of shared ownership/Starter/discounted homes.
Plan should make specific reference to providing land on large developments for alms houses by Berkswell Charities.

Comment

Representation ID: 9607

Received: 15/03/2019

Respondent: Dickens Heath Residents Association

The Residents Association supports the retention of the existing unit number policy for measuring affordable housing provision.

Comment

Representation ID: 9624

Received: 15/03/2019

Respondent: Balsall Parish Council

This potential policy proposal to use a percentage of square meter floorspace, percentage of bedrooms or percentage of habitable rooms could lead to undesirable unintended consequences.

Such a scheme should not be used without evidence from such an approach already in use achieving an improvement in provision of affordable housing.

SMBC should have regard to the emerging Balsall Parish NDP Policy H. 7

Object

Representation ID: 9641

Received: 15/03/2019

Respondent: David Wilson Homes

Agent: Barton Willmore Planning

Floorspace calculation will not provide certainty to developers and landowners at point of site acquisition.
This is one of the reasons that Stratford District moved away from this policy to a standard percentage of units-based policy, which was supported during their last Local Plan review.
Change in approach will slow down planning application process, and bring viability matters into play more frequently.
Note that this approach would run counter to the WMS on affordable housing which does not seek contributions on sites of 10 dwellings or fewer (i.e. based on dwelling numbers and not floorspace calculations).