Draft Local Plan - Supplementary Consultation

Comment

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.

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.

Comment

Representation ID: 7092

Received: 07/03/2019

Respondent: Tetlow King Planning

Further analysis is required to understand what the impact of any of the proposed measures would have been, had these been introduced and imposed on schemes already subject to planning applications, and in the future for those sites already known to be coming forward. Similar work has been conducted in London in response to the London Plan policies; This should be reviewed and similar analysis undertaken by the Council to understand the potential impact in Solihull. Viability testing should be completed to ensure that any proposed approach would act to maximise affordable housing delivery, and not disincentivise delivery.

Comment

Representation ID: 7094

Received: 07/03/2019

Respondent: Tetlow King Planning

The Council should seek to understand the impacts of any change in the affordable housing threshold measure by calculating how this would have impacted on development proposals that have already been assessed at application stage, and those likely to come forward through this Plan Review. Once this work has been completed the most appropriate mechanism to use will become clearer.
Consider a combination of policies on expected housing type, size and tenure mix together with an appropriate threshold measure. The use of the optional National Space Standards across all tenures may be a useful measure where this is justified by local need, and is viable. This may assist in coordinating floorspace across tenures. Introducing this for single tenures is generally resisted as this can have the impact of reducing scheme viability.