Question 41 - Affordable Housing calculation
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 7083
Received: 06/03/2019
Respondent: Ms B Bird
Option c
Option c
Comment
Draft Local Plan - Supplementary Consultation
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.
See attached letter
Object
Draft Local Plan - Supplementary Consultation
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%.
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
Draft Local Plan - Supplementary Consultation
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
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
Draft Local Plan - Supplementary Consultation
Representation ID: 7386
Received: 11/03/2019
Respondent: Golden End Farms
Agent: Delta Planning
Do not agree with the approach.
Do not agree with the approach.
Object
Draft Local Plan - Supplementary Consultation
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.
comment on affordable homes / affordable rent policy - see letter
Object
Draft Local Plan - Supplementary Consultation
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
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: 7670
Received: 12/03/2019
Respondent: Mr N Walters
40% of gross floor area of each dwelling.
40% of gross floor area of each dwelling.
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 7733
Received: 12/03/2019
Respondent: Edward Fraser
Habitable square meterage
Habitable square meterage
Comment
Draft Local Plan - Supplementary Consultation
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.
Please see attached document March 2019 Persimmon Reps Draft Solihull LPR
Support
Draft Local Plan - Supplementary Consultation
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.
See attached document
Object
Draft Local Plan - Supplementary Consultation
Representation ID: 8105
Received: 14/03/2019
Respondent: Terra Strategic
Agent: Delta Planning
Do not agree with the approach.
Do not agree with the approach.
Comment
Draft Local Plan - Supplementary Consultation
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.
see attached document
Support
Draft Local Plan - Supplementary Consultation
Representation ID: 9006
Received: 15/03/2019
Respondent: Councillor Max McLoughlin
(C) Habitable square meterage.
(C) Habitable square meterage.
Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 9144
Received: 15/03/2019
Respondent: Councillor M Wilson
Habitable meterage.
Habitable meterage.
Object
Draft Local Plan - Supplementary Consultation
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.
See Letter
Object
Draft Local Plan - Supplementary Consultation
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.
See attached letter
Object
Draft Local Plan - Supplementary Consultation
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.
See Letters
Support
Draft Local Plan - Supplementary Consultation
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.
See Letter
Object
Draft Local Plan - Supplementary Consultation
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.
see letter of response re: Knowle sites
Comment
Draft Local Plan - Supplementary Consultation
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.
see attached document
Comment
Draft Local Plan - Supplementary Consultation
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.
please see attached document
Object
Draft Local Plan - Supplementary Consultation
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.
the responses in the attached letter have been made by the Knowle Society
Object
Draft Local Plan - Supplementary Consultation
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
See attached documents
Comment
Draft Local Plan - Supplementary Consultation
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
see letter
Object
Draft Local Plan - Supplementary Consultation
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.
Please see attached representations and a detailed promotion document on behalf of my client, Bloor Homes, in response to the Solihull Local Plan Supplementary Consultation document.
Land East of Tilehouse Lane Tidbury Green
Comment
Draft Local Plan - Supplementary Consultation
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.
See details in attached letter
Berkswell Parish Council considers that the issues are important and worthy of deep consideration with an honest attempt by SMBC to conduct a suitable and sufficient review of the draft plan proposals.
Comment
Draft Local Plan - Supplementary Consultation
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.
Ref. Solihull Draft Local Plan Review - Supplementary Consultation January 2019
The Dickens Heath Residents Association welcomes the reduction in planned housing numbers on site 4 and deletion of site 13 with its access onto the B3102 Tanworth Lane Traffic Islands.
However based on the feedback from residents and the lack of information on addressing the existing traffic and infrastructure issues plus very widespread strong objections by the village to the Masterplan proposals to site 4 West of Dickens Heath we are objecting to the inclusion of this site.
In terms of the questionnaire we would respond to the relevant Questions as follows.
Scope of the consultation and overall assessment - while this indicates the objectives of the review when viewed in context it does not address the concerns raised by residents over existing well known traffic congestion issues and an inadequate rural highway network.
Dickens Heath Residents Association therefor strongly object to the Masterplan proposals for site 4.
A petition is being submitted to Solihull Council by Councillor Hawkins indicating some 1150 residents have lodged objection to site 4 in addition to a significant number of Emailed objections submitted to the Parish Council. We have also attended recent meetings at which the proposals have been presented and discussed and noted the level of objection and lack of any public support for the proposal at site 4.
Q 4 Blythe Infrastructure - its indicated highway improvements are only likely to be needed and off-street parking improvements at Dickens Heath only may be needed which does nothing to reassure residents that if site 4 were to be approved and included the council would provide the necessary infrastructure.
On sports and recreation lost provision is indicated as would be replaced but there are no sites indicated in the site 4 Masterplan.
The residents association regard it as a key priority that any future redevelopment ensures the existing sports grounds are retained within site 4
Q12 Site 4 Land West of Dickens Heath - while noting the councils laudable intentions to protect landscape features residents cannot be expected to support the inclusion of site 4 by writing a blank cheque for the proposed housing numbers given the experience of the totally inadequate highway infrastructure provided for the original Dickens Heath village as against its concept plan.
While it is understood that issues of highways and parking will be brought forward it is not possible to envisage how any satisfactory highway scheme could be implemented that would address both the proposed housing and ameliorate the existing congestion issues.
In respect of relocating the long established sports grounds for Old Yardleians Rugby Club, Highgate United FC, and Leafield FC these clubs have significant local support and the Residents Association would require alternative provision to an adequate standard within site 4.
The Residents Association is strongly opposed to an alternative more remote location into green belt countryside elsewhere.
Q14 Site 12 Land South of Dog Kennel Lane - this is adjacent to our Parish and impacts onto the main Dickens Heath traffic access. This site if included would need significant traffic attenuation measures.
Q34 Washed over green belt settlements - the Residents Association support the policy proposals at Whitlock's End and Cheswick Green subject to careful assessment of flooding issues at Cheswick Green sites.
Q38 Amber Sites - the Residents Association support the review and inclusion of all the Amber Sites as proposed.
Q40, 41, 42 & 43 Affordable Housing Policy - the Residents Association supports the retention of the existing unit number policy for measuring affordable housing provision.
Comment
Draft Local Plan - Supplementary Consultation
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
Please find attached Balsall Parish Council response to the SLP supplementary consultation.
Object
Draft Local Plan - Supplementary Consultation
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).
We are instructed by our client, David Wilson Homes Ltd, to submit representations to the supplementary consultation on the Draft Local Plan Review in relation to their interests at their site at Tidbury Green Golf Club (known as Arden Green).