Policy P4A Meeting Housing Needs – Affordable Housing

Support

Representation ID: 14930

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Policy P4A (Bullet Point 7):
The Council’s policy approach on social rented mix is inflexible and overly prescriptive. The HEDNA 2020 set out a range of housing mixes.

Object

Representation ID: 14931

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4C (Bullet Point 8):
Council’s policy approach on shared ownership mix is inflexible and overly prescriptive. HEDNA provides a range of figures.
Inconsistent with national policy.

Object

Representation ID: 14949

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4A (2):
- References to SPDs and guidance are inappropriate and non-compliant with the Regulations.
o Regulations are clear that development management policies should be set out in Local Plan policies. Council’s approach of requiring compliance with adopted SPDs is giving Development Management Plan Document (DPD) status to documents which are not part of the Local Plan, and have not been subject to the same process of preparation, consultation and examination.
o For policy to be effective should be clearly written and unambiguous, set out in sufficient detail, so it is evident how a decisionmaker should react to development proposals and not reliant on other criteria or guidance set out in a separate SPD.
o NPPF and PPG confirm scope and nature of SPDs and that they should not introduce new planning policies nor add unnecessary financial burdens on development.

Support

Representation ID: 15010

Received: 14/12/2020

Respondent: IM LAND - Land at Rumbush Lane, Earlswood

Agent: Turley

- Pleased to note that SMBC have reverted back to 40% of overall dwellings
- Support built in flexibility to allow negotiations on site by site basis

Object

Representation ID: 15108

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strongly support delivery of affordable housing as part of residential developments. However, a number of concerns over the detail (or lack of) contained
within Policy P4A which are considered unsound as drafted.
Part 2
This part of the policy states that the definition of ‘affordable’ will be set out in a Meeting Housing Needs Supplementary Planning Document (SPD), which will be
updated periodically to ensure it is up to date. While in principle this is accepted, due to the significant viability implications affordable housing can have on a
development, the SPD should be made available now or the contents of the document included in the Local Plan and available for review/comment. It is not a
sound approach to not publish a fundamental part of the evidence base prior to the submission and adoption of the Local Plan.

Object

Representation ID: 15109

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strongly support delivery of affordable housing as part of residential developments. However, a number of concerns over the detail (or lack of) contained within Policy P4A which are considered unsound as drafted.
Part 3
To be Sound, the level of affordable housing proposed needs to be justified by the evidence and currently the Local Plan does not appear to tie in with the more
recent Viability Study. At the current time, there are concerns with some of the details in the Viability Study (the ‘evidence’) that need to be addressed to make
the evidence base robust and the Policy Sound. These are summarised below and explain in more detail in the Bruton Knowles ‘Response the Cushman Wakefield
Study’ attached to these representations:
1. Typologies to include the entire range of potential sites from the largest to the smallest, so that parameters can be tested.
2. Housing mix to reflect need and demand.
3. Consistency regarding Benchmark Land Value.
4. Infrastructure costs to be revised to 2020.
5. Consistency regarding construction costs.
6. Contractors profit to be reinstated for base build costs.
7. Transparency regarding cashflow modelling, enhancements, etc.
8. Consistency with retirement care homes.
9. Sensitivity testing to be undertaken.

Object

Representation ID: 15110

Received: 14/12/2020

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strongly support delivery of affordable housing as part of residential developments. However, a number of concerns over the detail (or lack of) contained within Policy P4A which are considered unsound as drafted.
Part 6/7/8
These parts of the policy define the amount and type of affordable housing to be delivered.
However, these policies make specific reference to certain types of affordable housing which is not consistent with Part 1 which lists the various types
of affordable housing such as “social rented, affordable rented, intermediate tenure and Starter Homes, which is available at below market price or rent and which is affordable to households whose needs are not met by the market.”
These parts of the policy should be amended to refer to: affordable housing for rent (to include either social and affordable rent) and intermediate housing. The inclusion of Starter Homes is questionable.
With regards to the housing mixes specified for both affordable products, it is considered unnecessary to define these in a policy and certainly not applied to
each and every site that comes forward. The mixes proposed are appropriate for the whole Borough and each site with have different characteristics that may make them more suitable for a certain mix than others (ie central urban sites would be more suitable for 1 and 2 bed homes, whereas greenfield urban sites would be more suitable for larger family homes. The mixes would not be the same for each location, but the blended mix would achieve the needs of the Borough as a whole). Overall, mix should be linked to SMBC latest Strategic Housing Market Assessment (SHMA)/Housing and Economic Development Needs Assessment (HEDNA) (or other future relevant evidence base document) but not applicable in the same mix for each site location. This will ensure this policy aligns with the latest evidence base and remains effective and deliverable over the
lifetime of the Local Plan.

Support

Representation ID: 15121

Received: 13/12/2020

Respondent: Woods Farm (Christmas Trees)

Agent: Twelve Twenty One Planning Services

Supported on the basis that 40% affordable housing is the level necessary to address the issue of affordability which is the most acute in the West Midlands.

Object

Representation ID: 15151

Received: 14/12/2020

Respondent: Redrow Homes Ltd

Agent: RPS Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Disagree with the approach to Policy P4A Criteria 11 in terms of the following sentence ‘The cost of the Council’s qualified valuer will be met by the applicant’. This could lead the decision-taker to conclude that viability of development is threatened, and that the policy requirement should not be sought based on that evidence. In such cases the costs should be shared fairly between the applicant and the Council.

Policy P4A Criteria 12 is contrary to national policy and practice guidance which clearly define supplementary planning documents as not forming part of the development plan but which provide detail in support of it.